APPENDIX 2
Memorandum submitted by English Nature
(G2)
1. EXECUTIVE
SUMMARY
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. INTRODUCTION
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. WHETHER THE
VISION FOR
THE DEPARTMENT
IS APPROPRIATE
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. WHETHER FARMING,
FOOD, ENVIRONMENTAL
AND CONSERVATION
CONCERNS, AND
RURAL AFFAIRS
ARE EACH
GIVEN PROPER
WEIGHT BY
THE DEPARTMENT
AND WHETHER
THE DEPARTMENT
IS ENGINEERED
TO DELIVER
ITS OBJECTIVES
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. WHAT HAS
BEEN THE
IMPACT ON
THE ROLE
AND INFLUENCE
OF THE
ENVIRONMENTAL PROTECTION
GROUP AND
THE WILDLIFE
AND COUNTRYSIDE
DIRECTORATE OF
THEIR TRANSFER
FROM THE
FORMER DETR?
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. WHAT OBJECTIVES
THE DEPARTMENT
HAS SET
IN PURSUING
THE "RURAL
AFFAIRS" AGENDA
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
| 
