APPENDIX 22
Memorandum submitted by the Environment
Agency (G25)
1. The Environment Agency welcomes this
opportunity to comment on the role of DEFRA. In doing so we have
responded to the questions posed by the Committee.
2. Whether the DEFRA Vision for the Department
is appropriate.
2.1 This Vision was developed in an open
consultative way, which indicated a change of style from that
of MAFF. The Vision rightly has sustainable development as its
overarching theme. We particularly welcome the emphasis on achieving
sustainable food, fishing and farming industries that are not
dependent upon production related subsidies.
2.2 The Vision was sound, however as yet,
it is too early to judge DEFRA's success in delivering its Vision.
We believe the Vision should be backed up with clear statements
of outcome targets. The recently published DEFRA prospectus "Working
for the Essentials of Life" made considerable commitments
in relation to the main themes of the vision. This is welcome
elaboration, but there needs to be indication of a desired timetable
for delivery.
2.3 We would suggest DEFRA should publish
an annual progress report similar to that produced by the former
Department of the Environment for "This Common Inheritance".
2.4 Such processes are useful, but will
only be successful if Departmental culture is aligned with the
Vision. Such a change from MAFF and DETR cultures will take time
and resources to achieve. There are some indications of such change,
for instance, the increasing integration of work on the economics
of environmental protection, agriculture and flood defence and
initial work on diffuse pollution. In contrast, some policy groups
remain disjointed. For example the recently issued revised "Prioritisation
Guidance for Flood Defence Capital Projects", has not accepted
the need to address the three recognised elements of sustainable
development. Economic factors still dominate with little emphasis
on either social or environmental issues. Such culture change
could be encouraged by the systematic use of a sustainable development
checklist for all policy and guidance.
2.5 A potential disadvantage of the creation
of DEFRA was the separation of Environmental Protection and of
the Countryside and Wildlife directorates from what was DTLR and
now the Office of the Deputy Prime Minister (ODPM) and the Department
of Transport. Many of the mechanisms for delivering sustainable
development, as well as a number of key environmental impacts,
are the responsibility of ODPM (eg local government, planning,
regeneration) and the Department of Transport. The extent to which
forthcoming policies in these areas embrace sustainable development
will be an important test of the Government's wider environmental
credentials and a clear barometer of DEFRA's influence across
government.
2.6 Finally, in a period of change DEFRA
have had some notable successes, not least in international negotiations
on climate change (Marrakesh and Bonn) and on trade (Doha). The
Curry Commission on the Future of Agriculture has set out a workable
blueprint for agriculture reform.
2.7 To implement the Curry Report, and to
deliver the agenda set out in the Rural White Paper, DEFRA will
need to make full use of the expertise in its Agencies as well
as securing adequate financial resources.
3. Whether farming, food, environment
and conservation concerns, and rural affairs are each given proper
weight by the Department, and whether the Department is engineered
to deliver its objectives.
3.1 The DEFRA aims and objectives cover
all these areas and appear to give them proper weight. There are
encouraging signs of integrated thinking, for example, "Sustainable
Food and Farming—Working Together" and initiatives
on diffuse pollution. As well as tackling the sustainability of
agricultural production, DEFRA might do more to promote environmental
good practice in other parts of the food chain, particularly amongst
companies involved in food production.
3.2 In contrast, recognition of the potential
cross-cutting impact of the Birds and Habitats Directives remains
low. Similarly, few directorates have taken on board the principles
of the "UK Soil Strategy", and the implementation of
the Waste Regulations to farms has only been tackled in an integrated
way latterly.
3.3 On conservation issues, the picture
is mixed with greater impetus apparent on the Biodiversity Action
Plan in England and the Biodiversity Strategy. However, there
is still no overall compliance plan for the Habitats and Birds
Directives and the separation from the former Department of Transport,
Local Government and the Regions has sidelined DEFRA on major
planning decisions involving wildlife sites.
3.4 DEFRA faces a difficult task in successfully
carrying forward the "Greening Government" agenda. As
a less powerful and less wealthy department (compared with DETR),
it will need to work hard to continue to influence other departments.
(A robust output from the cross-Government working group on procurement
will be a key test here). It will also need to lead by example
and ensure that its own sustainable development strategy is fully
implemented.
3.5 DEFRA will need to consider how to regroup
to encourage the achievement of its Vision and of more integrated
and sustainable policies. This will involve the introduction of
a new culture. Any such change is time consuming and requires
adequate resourcing.
4. What has been the impact on the role
and influence of the Environment Protection Group and the Wildlife
and Countryside Directorate of their transfer from the former
DETR?
4.1 So far, there has been little obvious
change either in culture or way of working. The addition of Flood
Defence and Coastal Protection to Wildlife and Countryside Directorate
offers the potential for greater conservation gain from flood
defence works, but as yet no change is apparent.
4.2 One significant impact has been a high
level of vacancies and increased staff turnover especially in
Environmental Protection. A significant number of staff successfully
transferred "back" to DTLR. This appears to be driven
by the poorer salary structure in DEFRA (inherited from MAFF).
For example this, combined with normal civil service change, means
that most of the Water Supply and Regulation team has changed
in the last 12 months.
4.3 The lack of pre-planning for the department
and the scale of staff changes has reduced continuity of policy
development and disrupted progress. There also appears to be areas—such
as the provision of legal support—where Environment Protection
did not receive its pro-rata share from DETR. This has also constrained
progress.
5. What objectives has the Department
set itself in pursuing the "rural affairs" agenda?
5.1 Rural affairs are directly reflected
in DEFRA's Vision and objectives. There is a specific objective
to enhance opportunity and tackle social exclusion through promoting
sustainable rural areas. The prospectus expands on this, making
a series of commitments to improve rural areas.
5.2 As yet it is too early to see effective
progress. Success in reforming the Common Agricultural Policy
should provide funding for rural development. Key to this, is
the expansion of modulation which will require Treasury agreement.
5.3 It has been disappointing to see almost
no consideration of the environment in the "rural proofing"
checklist. There has also been a reluctance to communicate clearly
with the farming industry over the need for environmental improvement
and compliance with EU Directives. This is now being addressed
by the development of a strategy for improved advice linked to
demonstration farms.
May 2002
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