Memorandum submitted by The Chartered
Institution of Water and Environmental Management
"WORKING TOGETHER FOR THE ARTS"THE
ARTS COUNCIL OF ENGLAND
The Chartered Institution of Water and Environmental
Management (CIWEM) is the independent pre-eminent body for professionals
engaged in the stewardship of environmental assets and sustainability.
CIWEM's Royal Charter remit includes recreational aspects of the
environment and many of our members are involved in the cultural
industries. Most recently we have been supporting projects and
programmes which bring together artists and environmental issuesmostly
at a local levelto develop some innovative community arts
initiatives in order to raise the profile of environmental affairs.
I write in response to the Arts Council of England's
(ACE) consultation document, "Working Together for the Arts",
in which it presents proposals to disband the 10 Regional Arts
Boards (RABs) and replace them with a new single national body
which will assume the current functions of ACE and the RABs. I
welcome the opportunity to alert the Culture, Media and Sport
Committee of the House of Commons to the views of CIWEM, and others,
on this important matter and hope that they will be taken in to
account. This written evidence is based on CIWEM's response to
the Arts Council's document "Working Together for the Arts".
I comment on the Arts Council's restructuring
plans in my capacity as Executive Director of this Institution
(CIWEM), as an Adviser to Southern Arts (but not for Southern
Arts) and as Chair of ILAM South East, the regional arm of the
institute of Leisure and Amenity Management (ILAM), representing
cultural services in the South East of England. I have consulted
widely with colleagues and stakeholders of each organisation and
this response reflects many strongly held views.
I read the Arts Council's proposals with great
interest and welcome the fact that more time was given to the
consultation process. Two themes stand out from the text of the
consultation document. Firstly, the stated commitment to subsidiarity.
(This is mentioned several times in the document). Secondly, the
document refers to the difficulty of harmonising the views of
ACE with those of the RABs because of the latter's independent
status. I would like to deal with each of these in detail then
follow with some general comments which I have been asked to make
you aware of and which I support entirely:
Although the proposals reinforce a continued
commitment to the principles of subsidiarity, as a key feature
of the need for change, there is in fact very little evidence
of this in the document. Proposals for the organisational structure,
governance, appointment of senior staff and appointment of members
of the proposed new Regional Councils of the national body all
indicate a strong desire for central control with an ability to
take away those roles and responsibilities the new national body
proposes to delegate. As the consultation document statesthe
governing council of the national body "will retain the right
to revoke any delegated decisions". This makes a mockery
of the stated commitment. The independent status of the 10 RABs
represents subsidiarity in action and is an outward and visible
sign of local determination by committed representatives of local
communities. A real test of subsidiarity is the extent to which
real independence and self determination, in response to local
circumstances, exists. What is being proposed does not meet this
Presentation is important and this document
has failed to hide ACE's frustration with arts funding and administration
in the Regions. Neither does it disguise the "London knows
best" attitude which prevails. I suggest that the tone of
the document will anger those consultees ACE presumably wishes
to win over. This, together with recent previous discredited attempts
to sell proposals for change to the arts funding system, says
a great deal about the culture of ACE and colleagues have drawn
their own largely negative conclusions in this regard. Which is
a pity given the important role of ACE and the public support
and confidence it needs.
Art in the Regions will only be truly vibrant
and successful if it is funded and supported by an independent
and locally managed system. I see no real or sustainable alternative
to the RABs. What does bear examination though is how the RABs
can best contribute to ACE and its remit based on a "bottom
If ACE has real problems working with the RABs
who is to say that the fault does not lie with ACE? In my varied
management experience successful working relationships are achieved
despite organisational arrangements and not because of them. So,
why change what works well for local communities? In my opinion
it is for local people and the arts community, locally, to determine
the need for change and to take the lead.
I can well understand the frustration of ACE
in trying to harmonise the national strategic view with those
of the RABs. However, I regard it as something akin to arrogance
for ACE to assume, by implication, that the fault, if any, lies
with the RABs. Notwithstanding my earlier comments, if there are
real difficulties this could be resolved by creating a national
body which comprises stronger representation of the RABs. I have
long doubted the balance of the current composition of ACE and
it is disappointing that other options for a more effective arts
funding system have not been objectively debated in the public
domain. If we are to have a review then I believe that this must
be managed and undertaken independently of those most likely to
be affected. I do not regard ACE as independent in this context.
4. OTHER COMMENTS
(a) The proposals are based on many assertions
which are untested. No new organisation can guarantee to "respond
more quickly and effectively to new developments across the country".
Where is the evidence for this? To base proposals for major reorganisation
on such thin and subjective assumptions is naïve, in my opinion,
and should be discounted for this reason alone.
Proposals for change, from whatever source, must,
like a business plan, be well researched, be sustainable, be properly
costed, be supported by evidence, have wide ownership and inspire
confidence. The proposals must also be based on a clear vision.
In this case I see no vision just a rather dubious attempt by
ACE to extend its sphere of control.
(b) The proposals say that the new body will
work with local authorities to promote the arts to other agencies.
The RABs already do this very effectively. The proposals do not
evidence the new arrangements or show how they would improve on
what is being achieved already.
(c) If financial and other sorts of accountability
are an issue then I am sure that the RABs would be happy enough
to let the National Audit Office examine the way they utilise
public money and appear before Parliament. My view though is that
there are already sufficient safeguards and tests in place to
negate such a move.
(d) The consultation document is neither
a detailed plan or a blueprint. It contains very little financial
data and hardly anything in the way of outcomes or outputs supported
by evidence or performance indicators. As I have pointed out earlier,
in (1) above, the proposals meet none of the established criteria
for making a business or strategic case for change.
(e) Despite the claim to support the subsidarity
principle this is a proposal based on centralist control which
flies in the face of this Government's devolution agenda. I also
doubt that what is being proposed is sustainable. How can a single
national body be as effective as the RABs in working with the
merging regional structures? If these are adopted I believe that
further re-structuring would be necessary in a few years time.
A point well made by Southern Arts and one which I reiterate.
Reasons why the Arts Council's proposals for
restructuring of the Arts funding system should be rejected:
Research shows that the majority
of artists and arts organisations do not believe that the proposals
for change will benefit them or their stakeholders;
A business case has not been made
and the proposals are based on many assumptions. A clear programme
of improvements to the existing structure would be more effective
than the creation of a single organisation;
Any proposals for change must be
independently investigated and customer driven. The Arts Council
cannot be regarded as independent in this context. It has a vest
The proposals run counter to the
Government's policy of regional self determination and should
be dismissed on that count alone.
The suggested cost saving benefits
of the proposals have not been proven. A single organisation is
likely to be costly and more bureaucratic than the present structure.
I hope these comments are helpful to the Culture,
Media and Sport Committee. If you would like clarification of
any point please do not hesitate to contact me.
7 January 2002