Measuring effectiveness
103. The Environment Agency is a very large
body, employing some 10,000 people and spending over £600
million of public money each year. It also plays a vital role
in regulating some of the major industries which contribute billions
of pounds every year to the UK economy. It is very important therefore
that it be able to demonstrate clearly that it is offering value
for money and operating effectively.
104. The Agency has a number of performance indicators
across the range of its functions against which it can be measured
and its contribution to sustainable development assessed. 'Key
performance targets' are published in the Agency's Corporate Plan,
along with an assessment of the Agency's progress so far towards
them, and proposed future action. Progress against 'key performance
targets' is also reported in the Agency's Annual Report. The Report
provides a useful means of assessing the Agency's performance,
although the most recent Annual Report omits to mention some areas
where progress has been less satisfactory: there is no information,
for instance, on the time taken to determine applications for
waste licences, nor on the Agency's progress in completing the
four-year statutory reviews of IPC authorisations - both areas
where the Agency has been severely criticised in the past for
inadequate performance.
105. Some attempts at providing targets for the
Agency have been crude and counter-productive. These problems
have not been entirely of the Agency's making. Witnesses, for
example, referred to the unhelpful targets for numbers of waste
management inspections set in DETR's Waste Management Paper 4.
The imposition of these apparently arbitrary targets encouraged
staff to visit the largest possible number of sites in the shortest
possible time, and discouraged visits to what may be the more
"difficult", time-consuming sites.[200]
This has been a major contributory factor to the problems which
the Agency has experienced in the waste management sector.
106. The problem is not confined to the waste
management sector, however. We have already discussed the problems
which the performance-related pay system as it is currently operating
throughout the Agency has caused, noting that Agency staff operate
in a framework of performancerelated incentives which attach
more importance to quantity rather than quality of work done.[201]
Alan Broughall of UNISON told us, "Within the organisation
we have what are termed operational performance measurements,
OPMs, and there seems to be an obsession with these statistical
pieces of information which is generally measuring quantity and
not quality of the work that has been undertaken. Achieving quantity
targets is detrimental to high quality work."[202]
The same point was made by the Chemical Industries Association,
who wrote, "a 'check-list' approach gives easily reported
performance data, but does not necessarily result in improved
environmental performance."[203]
107. The Agency should be taking further steps
to measure its effectiveness by outcome, rather than by process.
The problems which the Agency have experienced in the waste management
sector have shown what can happen where quantity is given precedence
over quality. Naturally it is important that the Agency continue
to monitor its performance against its statutory responsibilities,
such as that to respond to applications for waste management licences
within four months. Nevertheless, its primary statutory responsibilities,
as we have already noted, are to "protect and enhance the
environment", and to "contribute to sustainable development".
These are the primary criteria against which the Agency's performance,
across all its functions, should be judged.
108. We recognise that the Agency has already
taken some steps towards ensuring that its performance is judged
by outcome, rather than by activity. It has, for example, set
itself targets for achieving reductions in substantiated water
pollution incidents, and for reducing emissions of various air
pollutants.[204]
The Chairman of the Agency also indicated to us during oral evidence
that he expected further progress to be made when the Agency's
new draft environmental strategy was published.[205]
We commend the progress which the Agency has been making in
this area, and we recommend that it continue to develop and refine
indicators against which its performance in protecting and enhancing
the environment and contributing to sustainable development across
the full range of its duties can be measured.
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