Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence


Memorandum submitted by English Nature (G2)


  1.1  The DEFRA vision is good, but service delivery has been patchy in some areas and organisationally it remains too process driven. It must become more outcome focused. Its programmes, activities and staff/financial resources need to be re-aligned to deliver the vision, aim and objectives.

  1.2  DEFRA needs to develop its culture to become a service orientated organisation, less risk averse, more outward looking and innovative in its policy making and ways of working. It should be more open to using and trusting its agencies and NDPBs in contributing to policy development and delivering its objectives.

  1.3  DEFRA has made some welcome efforts to be more open and inclusive but it must extend its range of partnerships to achieve sustainable agriculture rather than maintain its traditional focus on established partners such as the NFU, CLA and the agri-food business.


  2.1  English Nature is the statutory body that champions the conservation and enhancement of the wildlife and natural features of England. We do this by:

    —  advising—Government, other agencies, local authorities, interest groups, business, communities, individuals;

    —  regulating—activities affecting the special nature conservation sites in England;

    —  enabling—others to manage land for nature conservation, through grants, projects and information; and

    —  advocating—nature conservation for all and biodiversity as a key test of sustainable development.

  2.2  In fulfilling our statutory duties we:

    —  establish and manage National Nature Reserves;

    —  notify and safeguard Sites of Special Scientific Interest (SSSIs);

    —  advocate to Government departments and others effective policies for nature conservation;

    —  disseminate guidance and advice about nature conservation; and

    —  promote research relevant to nature conservation.

  2.3  Through the Joint Nature Conservation Committee, English Nature works with sister organisations in Scotland, Wales and Northern Ireland to advise Government on UK and international conservation issues.

  2.4  We welcome this opportunity to comment on the role of DEFRA. Our response is framed around the questions posed by the Committee.


  3.1  The vision set out in "Working for the Essentials of Life" is sound and the supporting aim and objectives are clear, transparent and fit for purpose. We were consulted in developing the vision and we strongly endorse it. Placing sustainable development as the overarching theme of the vision, aim and objectives is the right basis for planning all of DEFRA's work and should ensure that the Department's broad range of economic, social and environmental responsibilities are fully integrated.

  3.2  Some notable examples of progress towards achieving the vision include:

    —  international leadership on recent climate change and world trade negotiations, and in the preparations for the World Summit on Sustainable Development in Johannesburg;

    —  robust and effective engagement with the EU Commission to develop proposals for reform of the Common Fisheries Policy;

    —  integration of sustainable development reports as part of all Departments' SR2002 bids to Treasury, although we believe these reports should be published in future and used to inform the Government's Annual Report on Sustainable Development;

    —  preparation of a draft DEFRA Sustainable Development Strategy (March 2002) to start the process of embedding sustainable development within the Department; and

    —  strong support from the Department, close personal involvement of the Environment Minister and provision of additional funds to enable English Nature to achieve a negotiated cessation of peat extraction from three internationally important SSSIs.

  3.3  There are clear links between DEFRA's vision, aim and objectives and Public Service Agreement (PSA) targets, but policy making within the Department does not yet appear to be fully integrated and we believe it has some way to go in aligning its programmes, activities and staff/financial resources in a prioritised way to deliver its aim and objectives.

  3.4  The sheer weight of consultations during the Department's first year caused some concern and confusion, adding to the impression that new policy initiatives are not joined up. However, we warmly welcome the efforts made by DEFRA to consult more openly with stakeholders and partners, particularly in developing its vision, aim and objectives, through the Agri-Environment Review (see case study 1), the Science in DEFRA initiative (see case study 2) and in its consultation on the draft DEFRA Sustainable Development Strategy which was facilitated by Green Alliance. This signals a very positive change from the former MAFF culture.

  3.5  We would like to see more evidence that DEFRA is developing practical approaches to implement the vision, becoming more outcome focused, less risk averse and more fleet of foot. There has to be greater willingness to implement change in a shorter time frame thus maintaining the momentum behind Ministers and senior officials working so hard to secure changes at EU level.

  3.6  The culture change sought has not yet pervaded all parts of the Department. This has been typified by the sluggish response to the opportunities for change presented by the report of Commission on Farming and Food (the Curry report) and the National Sheep Envelope (case study 3).

  3.7  Inertia led to a six month delay in developing a coherent policy response to the Curry report proposals. DEFRA must not "cherry pick" from the Curry report and should ensure integration with other programmes that might be affected by too sharp a focus on its proposals, for example tackling diffuse pollution, water and flood management. We hope that the proposals emerging from the consultation on "Sustainable Food and Farming—Working Together" will signal an integrated approach with a clear action plan and desired timetable for delivery set against the resources likely to be available under SR2002.

  3.8  In contrast, we believe the "Safeguarding the Seas" marine strategy (May 2002) produced by the Water and Land Directorate was a good example of objective, evidence based policy making, developed through an open process which engaged other Departments, NDPBs, voluntary conservation organisations and industry. It builds on the aim and objectives with:

    —  clear, evidence based (albeit somewhat optimistic in our view) analysis;

    —  long term, hard targets;

    —  policy proposals that are tied in to spending decisions; and

    —  an ecosystem based approach set in a context of sustainability.

  3.9  Overall, we would like to see wider adoption of an ecosystem based approach to policy making, and more evidence of horizontal integration between Directorates (particularly Water and Land, Livestock Products, Land Management and Rural Development, and Wildlife, Countryside and Flood Management) at Grades 5-7 internally and with their counterparts in other Government Departments.

  3.10  We believe DEFRA needs to continue to develop a broader range of partnerships to secure delivery of its policy objectives. In some parts of the Department there still appears to be a preference to work with the traditional partners such as the NFU, CLA and agri-food businesses, and a reluctance to establish new relationships with a broader range of stakeholders who can contribute to the development of sustainable agriculture. At a recent seminar held by the Department on the environmental impacts of the sugar regime English Nature was the only non-farming organisation involved (see case study 4).

  3.11  An example of where the Department is doing better is the current joint working with the Environment Agency and English Nature to develop policy mechanisms and practical approaches to address diffuse pollution from agriculture.

  3.12  Over next the 12 months we would expect to see DEFRA:

    —  aligning its resources behind the vision, aim and objectives (apparently this was done for the DEFRA SR2002 sustainable development report to Treasury, but the result was not published or made available for external scrutiny);

    —  developing deeper and broader intellectual and practical partnerships with its agencies, NDPBs and other partners to help deliver its vision, aim and objectives;

    —  implementing a performance management system for all Directorates and Divisions and reporting annually on progress against the aim and objectives, PSA targets and the business strategy set out in "Working for the Essentials of Life".


  4.1  The Department is well led and has a strong Management Board, including non-Executive Directors. There are good, clear links between the Ministerial portfolios and the functions of the Directorates General.

  4.2  A greater sense of strategic direction and determination to succeed now needs to permeate throughout the Department. This will require staff at Grades 3-7 to provide leadership, solutions and mechanisms to enable DEFRA to deliver its vision. We believe the Department needs to invest in culture change and a senior staff development programme to facilitate this transition.

  4.3  English Nature has seconded three Grade 7 staff into DEFRA, but there has been no reciprocal movement the other way, despite several opportunities being offered. We believe that partnerships and shared understanding with DEFRA, and the competency of its staff would benefit from more secondments into its agencies and NDPBs.

  4.4  We see little evidence of staff resource shift within DEFRA to achieve its vision. When the Department was created there were around 9,000 staff focused on agriculture against 600 working in Environmental Protection and Land Use and Rural Affairs. This has not substantially changed. The Food, Farming and Fisheries Directorate General has 18 Grade 5 led Divisions working on agriculture and five on fisheries, but only two on food and drink. In contrast, one Grade 5 and six staff administer the England Rural Development Plan. With the future prospect of modulation and anticipated changes at the EU level as a result of the mid-term review of Agenda 2000 and further CAP reform in 2006, the balance of staff resources within DEFRA must be addressed soon.

  4.5  The DEFRA culture still favours the status quo in its approach to agriculture, and continued susceptibility to the politics of the farming lobby has diluted the Government's commitment to change. This is evidenced not only by the slow response to the Curry Report, but also the current proposals for the Environmentally Sensitive Areas review where the preference is to do no more than roll over existing Tier 1 agreements for another 10 years despite the advice of English Nature and the Environment Agency, and National Audit Office recommendations to the contrary. Another example is the late implementation of the EU EIA Directive on agricultural land (see case study 5).


  5.1  The environment more generally, and nature conservation in particular, appears less visible in DEFRA than in DETR. European Wildlife Directorate remains out on a limb from the rest of the Department both geographically and metaphorically. Evidence of this is the failure of some DEFRA officials to recognise and understand the importance of the SSSI PSA target or the responsibilities of the Department and its agencies under EU Directives and UK nature conservation legislation B for example, the recent DEFRA consultation on the sustainable development duty of the Environment Agency made no reference to its Section 28G responsibilities under the Countryside and Rights of Way Act 2000 to conserve and enhance the special interests of SSSI, particularly as an operator in flood and coastal management. The new Department with a new culture also needs to understand its own responsibilities for delivery of the UK Biodiversity Action Plan targets in England.

  5.2  We anticipate real benefits in due course from moving the Flood and Coastal Defence Division into the Wildlife, Countryside and Flood Management Directorate. This should secure better integration of flood management and floodplain/river restoration, and managed retreat on the coast as well as minimising flood risks to people and the built environment. We hope to see early evidence of a new integrated approach to policy making, scheme design and delivery in this area acknowledging that:

    —  wetlands can play an important role in reducing flood risk, and maximise the environmental benefits from natural flooding; and

    —  coastal erosion is important for the conservation of biodiversity and natural features, and can help reduce flood risk elsewhere.

  5.3  DEFRA needs to take a strong position on environmental integration within the newly created Department for Transport and the Office of the Deputy Prime Minister Government, notably with regard to ports and transport infrastructure development, the future of the planning system (for example by pressing for early review of PPG9) and protected species licensing functions. It should also be more challenging in its relationship with business to engage companies, rather than just trade associations, and the CBI and the DTI in positive action to help deliver the UK Biodiversity Action Plan and the forthcoming England Biodiversity Strategy.

  5.4  We would also like to see DEFRA being more assertive in its leadership role as the Government's champion for sustainable development and integrated policy appraisal across Government, for example through Cabinet Committee (ENV) and the Green Ministers Cabinet Sub-Committee ENV (G). It has made a good start by re-energising the Green Ministers process with bilaterals to review Departments' sustainable development reports, and is in leading by example through its own draft Sustainable Development Strategy and the use of integrated policy appraisal for each DEFRA spending proposal in its SR2002 submission.


  6.1  DEFRA cannot allow itself to be typecast in Government or in the public mindset as primarily a rural affairs or food and farming Department. It needs to engage strongly with other Government Departments on major structural economic issues to promote "a better quality of life" and a wider range of public benefits for all in sustainable urban and rural areas. However, a key priority for DEFRA is to find the right language to convince the Treasury and farmers about the benefits of an early expansion to modulation.

  6.2  The Department is working with English Nature, the Environment Agency and the Countryside Agency to develop a range of national, generic products to deliver integrated advice to farmers through an Internet based approach to whole farm plans. Subject to funding through SR2002, this exciting initiative would integrate IACS and ERDP scheme data, environmental regulation, Nitrate Vulnerable Zone requirements, designated sites (SSSIs and Scheduled Ancient Monuments) and vocational training relevant to individual farms/rural businesses. We would expect DEFRA to share the site related environmental data and information with its agencies and NDPBs.

  6.3  We have several concerns about other aspects of DEFRA's strategy for improved farm business advice, particularly the environmental expertise of the Small Business Service/Business Link staff who are charged with its delivery, the extent to which wider environmental issues are being identified and built into action plans (outside designated sites) and quality assurance of the advice given.

English Nature

30 May 2002

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