Memorandum submitted by the Countryside
Agency
PREFACE
1. The main statutory duties of the Countryside
Agency can be summed up as:
— as statutory champion and watchdog,
to keep under review and advise Government on all matters relating
to the social, economic and environmental well-being of the countryside;
and
— to influence and inspire rural solutions
through our know how and through demonstration projects assisted
by grant aid.
2. In line with our statutory remit, we
have based this evidence on how the Review recommendations would
make the quality of life better for people in the countryside;
and whether they would make the countryside itself better for
everyone—resident or visitor. While our views on the Report
are critical in part, we need to draw a distinction between those
and our current work with Defra and partner organizations in preparing
a full response; and implementing changes in the best interests
of rural people and the rural environment. We are encouraged in
this, as the Secretary of State has herself decided not to accept
all the recommendations of the Review and is engaging us and others
in the preparation of a detailed implementation plan.
3. The Review is essentially more to do
with government machinery and inevitably dwells more on process
than outcomes. Nor has any properly informed cost benefit analysis
been provided. Nonetheless it is vital to try and understand what
the review might mean in terms of practical change on the ground.
This is what is of interest to people and it is also the basis
on which government ultimately decides to make changes: an assessment
of the costs and benefits to the public[8]
4. Rural people and businesses will find
much to applaud in the diagnosis of what is wrong with rural delivery
arrangements provided by the Review. Several reviews of rural
policy since 1997[9]
that have consistently identified the same defects; central government
is remote, not well attuned to rural concerns, inflexible in its
response to different rural circumstances and it works through
a confusing and probably inefficient web of delivery organisations.
5. There is also much to welcome in the
broad approach proposed in the Review, particularly the ideas
of creating a more integrated approach to the management of natural
resources and devolving responsibilities to bodies which are closer
to rural communities.
6. Above all, rural communities and interests
want to see visible improvements on the ground. We believe that
the Government's objectives for rural areas are widely regarded
as sound; the question mark is over delivery. Key indicators of
biodiversity, countryside quality, rural services and rural productivity
are showing improvements but slowly. We had hoped that the Rural
Delivery Review would say clearly where the current delivery arrangements
are an obstacle to achieving measurable progress and recommend
substantial changes where necessary.
7. In our view, it does not live up to this
challenge, for two main reasons:
— The "big ideas" were not
thought through sufficiently, against the main goal of progress
on the ground, creating the risks that the recommendations may
not result in substantial improvements and may have unintended
consequences.
— There is a lack of real evidence
in the report, particularly on the nature and scale of the benefits
that would justify the cost of the proposed changes; much of the
evidence is anecdotal rather than relying on proper evaluation.
8. Under these two themes, there are eight
areas where we feel the Review requires further examination. To
a considerable extent the Government has recognised these shortcomings
and we welcome the decision of the Secretary of State to delay
a full announcement until the details have been properly worked
through.
V.
Risks of inadequate capacity and added complexity
in the proposed regional and sub-regional arrangements.
VI.
Lack of clarity about roles and accountability
of Rural Priority Boards and Regional Rural Affairs Fora.
VIII.
A methodology, which falls short of Government
guidance and provides insufficient evidence.
A fuller explanation of these eight points follows.
We can provide a more detailed analysis of the individual recommendations
and whether the intended benefits are likely to be realized, if
the Committee wishes.
I. THE BALANCE
AND INTEGRATION
OF ENVIRONMENT
AND SOCIO-ECONOMIC
INTERESTS
9. Perhaps the greatest challenge for rural
policy is to reconcile conservation and development objectives.
The recommendations in the Review would have the effect of altering
the balance of power between socio-economic and environmental
structures. Currently, there are two large national agencies championing
environmental issues, English Nature focusing on nature conservation
and biodiversity and the Environment Agency. Neither is specifically
rural. The Countryside Agency, on the other hand, champions sustainable
development through its comprehensive remit embracing rural communities
and businesses as well as the environmental dimension of landscape
and its enjoyment. The recommendation to dissolve the Countryside
Agency would skew the national agency structure in favour of environmental
interests.
10. To some extent this is a consequence
of guiding principles of the review being applied inconsistently.
Devolution and the separation of policy and delivery are applied
vigorously to socio-economic arrangements, yet the proposed means
of improving environmental delivery is to create a new national
agency that will undoubtedly play a significant role in policy.
11. A second effect of the Review would
be to separate socio-economic and environmental roles. Greater
clarification of roles may be advantageous in some respects (eg
less risk of overlap between bodies), but would cut across the
Government's approach of sustainable rural development—the
concept of the living countryside—which is only now beginning
to be appreciated.
12. In our view, the Review does not do
enough to explore and resolve these issues. One approach would
have been to mainstream socio-economic affairs firmly into other
parts of Government, particularly the main spending departments
such as DTI, ODPM, DfES and Health. The Review makes a nod in
this direction. Government departments are asked to enter into
joint PSAs with Defra, but there is not the substantial transfer
of responsibilities and accountability that would justify the
weakening Defra's delivery structures for rural communities. In
particular, the proposed removal of the Countryside Agency would
take out the independent assurance that the public can take from
our annual report on the Government's progress in rural proofing
its policies and delivery.
13. An alternative approach would have been
to ensure that socio-economic aspects are sufficiently prioritized
amongst the national bodies within the Defra family, but the deliberate
separation of environmental and socio-economic functions militates
against this. So, for example, the proposed new integrated agency
is described as first and foremost an environmental organisation,
although it would have responsibility for access and national
trails (which recent research shows are very significant economic
drivers).
14. We think that the shake-up proposed
by the Review presents a tremendous opportunity to create a new
culture and approach to land management. But that must mean the
new integrated agency developing a strong social and economic
dimension to its work. It needs to become a positive force for
recreation and the enjoyment of the environments that it is charged
with conserving, for the benefit of rural people and businesses.
15. Even so, the new integrated agency will
not take on many aspects of the rural affairs agenda that are
currently managed by the Countryside Agency, rural services for
example. This function, of central importance to rural communities,
would lose a national champion under the proposed changes.
16. In our view there remains a need for
an institution within the Defra family that can take a sustainable
rural development perspective, as champion and watchdog, considering
social, economic and environmental matters together, just as they
are on the ground.
II. THE IMPORTANCE
OF INDEPENDENT
ADVICE
17. The Review underestimates the importance
of independent advice in the policy process. The strong environmental
lobby ensured that this point was highlighted with respect to
English Nature, but it applies equally to the socio-economic aspects
of rural affairs. The recommendation to dissolve the Countryside
Agency, with its policy and research functions transferring to
Defra and the Integrated Agency, would have meant the loss of
the statutorily independent adviser on rural affairs. We therefore
welcomed the Secretary of State's decision to reject this recommendation.
18. In general, big questions about the
purpose and proper functions of NDPBs, and the key question of
how Defra should maintain strategic oversight without micro-managing,
have not been considered in enough depth. Without a detailed understanding
of how the more focused Countryside Agency and other altered bodies
will work it is difficult to judge the implications of the proposals.
Further work is required, informed by past agency reviews and
current thinking on agency models.
19. The Review acknowledged the need for
some independent advisory function and proposed that the Rural
Affairs Forum for England should fulfill this role. RAFE provides
voluntary stakeholder representation, which is important, but
it is not the same as independent policy advice. Government aspires
to "evidence-based policy making" and independent advice
needs also to be based on objective analysis and expertise. It
requires a body with the capacity to develop an objective, independent
perspective on the countryside, integrated and listening hard
to the first class advice that stakeholder groups such as the
Rural Affairs Forum can provide.
III. THE SEPARATION
OF POLICY
AND DELIVERY
20. The notion of separating policy and
delivery, which the Review takes as a guiding principle, has been
widely criticised. Indeed it has not been adopted wholeheartedly
in the review itself.
21. The Review treats the policy process
in a linear way whereby policy is developed in the centre and
delivered by specialist agencies. In reality, the process is iterative
and complex; policy is developed at all levels and is both strategic
and operational; there is a circle of ideas, experimentation,
implementation, evaluation and further development. All organisations
involved in this cycle contribute, to a greater or lesser extent,
to both policy and delivery and modern policy making encourages
this.
22. This is especially true in post-MAFF
era when Defra's family is increasingly devolved and extended
to include partners such as local authorities, regional assemblies
and the private sector. In this new context, the distinction between
policy and delivery is hardly the issue. More important is the
development of new relationships and structures with which Defra
can engage successfully with its increasingly diverse and autonomous
partners. `Command and control' is no longer the appropriate approach.
23. Where a clearer distinction of roles
results in greater clarity and accountability it has merit, but
it is dangerous when it means that the realities of delivery and
outcomes get divorced from policy making. The Review runs this
danger because it stretches the policy process in two directions;
policy making and strategic planning is centralised in Defra at
the same time as delivery is pushed further down to regional and
sub-regional bodies. This places greater demands on links between
policy and practice and between the centre and localities that
are already weak.
24. The Review recognises this risk, but
in our view does not do enough to counteract it. It provides no
assurance about how delivery can be guaranteed through this extended
chain. The recommendation that Defra staff gain delivery knowledge
through training and secondments is well-meaning but not sufficient;
staff in government departments are often moving between posts,
which means that their degree of experience in their current policy
area is often well short of more specialized organizations.
25. A structure and process is required
to maintain and strengthen links between rural policy and practice.
The need is for a national organization that has its roots in
both policy and practice, and which has the capacity to gather
expertise from research, data gathering, evaluation, strong links
to regional and local bodies and the piloting of new approaches.
IV. OVEREMPHASIS
ON BENEFITS
TO FARMERS
26. The new Integrated Agency, the centre-piece
of the Review, will be of direct benefit mainly to farmers as
it is intended to provide a more streamlined way of delivering
agricultural support in the form of environmental payments. This
is a convenient response to the redirection of CAP support into
agri-environment payments, but it is not by itself an adequate
rationale for a major new agency. The protection and production
of public environmental goods in the countryside depends increasingly
on a healthy and "green" rural economy. It is disappointing
therefore that the integrated agency described in the Review has
a very limited remit on the economic side. We think that it should
develop a leading role in access, recreation, local food sourcing
and other such strands of the economy that encourage the maintenance
and production of an attractive countryside.
27. A consequence of the farm-focus is that
there is much less in the way of specific reforms that would benefit
the 96% of rural people who are not farmers. The general approach
of devolving rural programmes and services to regional and local
bodies could potentially be of great benefit, but exactly how
this would improve delivery is left for these bodies to determine.
This is understandable, given the principle of devolution, but
it does mean that the practical implications of the proposals
are very difficult to discern.
V. RISKS OF
INADEQUATE CAPACITY
AND ADDED
COMPLEXITY IN
THE PROPOSED
REGIONAL AND
SUB-REGIONAL
ARRANGEMENTS
28. Under the proposals for devolving responsibilities
recommended by the Review most delivery will be done by regional
and sub-regional bodies, particularly on the socio-economic side.
Yet the focus of the review is very much on national structures,
particularly a handful of national NDPBs. Relatively less attention
is paid to regional/sub regional structure and as a consequence
the proposals are less specific and the implications harder to
gauge.
29. A particular problem that arises is
the capacity of regional and local bodies—not just to take
on and deliver existing programmes, but also to make noticeable
improvements at the same time. The Review recognises this challenge,
most of the recommendations for `making it happen' are about preparing
the RDAs and Local Authorities to take on additional responsibilities,
but it does little to guarantee a successful outcome.
30. One overlooked issue in this question
of capacity is the cost of mainstreaming programmes of the type
that have been demonstrated by the Countryside Agency. The funding
for demonstration projects has never been as widely available
as would be needed if the approach was to be mainstreamed for
delivery in all areas of need. Devolving programmes to RDAs and
local authorities will either require greater funds or lead to
smaller individual payments as the resources are spread thinner,
which in turn will make the demonstration of good practice hard
for individual authorities to champion.
VI. LACK OF
CLARITY ABOUT
ROLES AND
ACCOUNTABILITY OF
RURAL PRIORITY
BOARDS AND
REGIONAL RURAL
AFFAIRS FORA
31. The proposed new regional Rural Priority
Boards are described as a simplification of regional arrangements
because they are intended to subsume three or four existing groups
in each region, depending on the regional set-up. However, an
important distinction between the existing groups (eg Regional
Rural Strategy Boards, ERDP Programming Group, Sustainable Food
& Farming Strategy Group) and the proposed Priority Boards
is that the former are there to serve a specific purpose. The
Priority Boards on the other hand are there to act as an umbrella
for these groups—coordinating rather than delivering. Before
creating new bodies, which will add to the complexity and cost
of regional arrangements, the purpose and the value they add should
be crystal clear. The Review does not provide this clarity.
32. Given the Review's guiding principle
of devolution, the recommendation that central Government dictates
regional arrangements is somewhat contradictory. If the design
of partnerships was left to delivery bodies it is unlikely that
they would invent Rural Priority Boards. In reality, deliverers
form partnerships as and when they are required and formal partnership
arrangements imposed by Government tend to receive no more than
token support. If the principle of devolution is to be followed,
delivery bodies should be left to design and run their own arrangements.
33. In the short-term at least, the creation
of new Priority Boards will confuse, rather than simplify regional
arrangements. The Review does not consider in sufficient depth
the relationship with other local groups such as Local Strategic
Partnerships and Regional Rural Affairs Fora. The latter are currently
a mix of delivery bodies and "customer" representatives
and under the proposals they will have a clearer remit to serve
the interests of the "customer", with Priority Boards
becoming the group for the delivery bodies. This distinction may
ultimately help but it will take time to be implemented and understood.
In the meantime the recommendations will be seen as adding to
confusion and complexity, rather than reducing it.
34. Creating new bodies to coordinate regional
delivery is less important, in our view, than ensuring that there
are effective arrangements for ensuring that policy is being delivered
in a way that benefits rural people. The review has little to
say in this regard other than that the existing Regional Rural
Affairs Fora should be made more "customer" focused
and effective. Yet the proposed arrangements for the Rural Affairs
Fora muddle responsibilities and accountability in a way that
is likely to be detrimental to performance. The proposal is that
the secretariat for Rural Affairs Fora be provided by the new
Rural Priority Boards, but these are to be chaired by the Government
Offices (or elected Regional Assemblies when these are in place).
Hence Government and delivery bodies would be intimately involved
in RAFs, blurring lines of accountability and the identity of
RAFs as a voice for the "customer".
35. Before the Review recommendations are
acted upon, we think it would be wise to develop a deeper understanding
of the current arrangements, what's needed, what works now, what
doesn't work and what could be achieved through reforms. We think
the Secretary of State was right to avoid making firm decisions
on regional and sub-regional arrangements at this stage.
VII. THE RURAL
AFFAIRS FORUM,
AS PROPOSED,
WOULD NOT
PROVIDE AN
EFFECTIVE VOICE
FOR RURAL
COMMUNITIES
36. Having recognised that a Government
Department cannot also act as an independent champion or "watchdog",
and having proposed that the Countryside Agency be disbanded,
the RDR recommends that an enhanced Rural Affairs Forum for England
take on the role of scrutinising Government on rural matters.
37. The Rural Affairs Forum as it stands
is a meeting place for separate bodies with diverse interests.
At best it is a sounding board and organisations attend mainly
for the opportunity to network. To make it capable of performing
a watchdog role, its constitution and functions would need to
change. The proposed body would need to be chaired by someone
other than a Defra Minister; it would need a Board with a single
mission and it would need the resources and staff necessary to
monitor rural issues, monitor Government's response, evaluate
the effectiveness of delivery and produce reports on this. It
would also need a research capacity to ensure that its contributions
were evidence-based. In effect, it would require the re-creation
of existing Countryside Agency functions.
VIII. THE METHODOLOGY
AND QUALITY
OF THE
REVIEW DOES
NOT LIVE
UP TO
GOVERNMENT GUIDANCE
38. The basis on which Government decides
on changes to policy or structures is a systematic appraisal of
benefits and costs to the public. Government guidance describes
the essential technique as; "option appraisal, whereby government
intervention is validated, objectives are set, and options are
created and reviewed, by analysing their costs and benefits. Within
this framework, cost benefit analysis is recommended, as contrasted
with cost-effectiveness analysis"[10]
39. The Review does not include a cost benefit
analysis. Expected improvements are identified, but these are
intangible, unquantified or focus on process rather than outcomes.
This makes it extremely difficult to judge the value of the proposals
but it also means that, at times, the wider perspective of the
public good is not considered. For example, the aim behind several
proposals is to reduce the number of farm visits by inspectors.
Clearly this would benefit farmers and it may benefit the public,
but not if it leads to greater pollution or food safety problems.
A proper appraisal of benefits and costs to the public would have
flushed out such issues, even if they could not be fully quantified.
40. A business case is referred to but not
published in the Review. This is not a business case as defined
in guidance but an initial cost effectiveness analysis. From what
we have seen of this analysis it appears to be based on very bold
assumptions and the risk of error is extremely high. For example,
it seems to assume that a very large number of buildings will
no longer be needed, yet it provides relatively little resource
for the extra travel costs (or redundancy as an alternative) that
affected staff from those offices will be entitled to receive.
41. Nor is there a consideration and analysis
of a range of options. The Review considers "no change"
and the proposed model, but does not look at other options for
meeting its objectives. For example, increasing environmental
burdens from Europe are cited as the main reason why changes are
needed, but the option of simply beefing up the current arrangements
is not considered.
42. Other aspects of method undermine the
quality of the evidence presented. For example, the publication
of anecdotes to justify the recommendations. The views of people
are important and it is right that the Review team should use
these interviews to form and test ideas but by themselves they
do not amount to satisfactory evidence.
43. The shortcomings in the review have
been costly. The Government has been forced to delay decisions
by approximately six months, further analysis has had to be undertaken,
the period of uncertainty for staff and other people affected
by the potential changes has been lengthened and there has been
a great distraction from delivering normal business.
44. Overall, the review does not provide
enough evidence to allow final decision to be made on most of
the recommendations. We therefore approve of the Secretary of
State's decision to delay a detailed response until further work
has been done; we welcome Defra's commitment to engage the Agency
properly in this stage of the Review; and we are playing a constructive
part in the work Defra has now started.
Countryside Agency
December 2003
8 HMT (2003) Green Book: Appraisal and Evaluation in
Central Government. Back
9
The Rural White Paper in 2000, the preceding public consultation;
the Rural Economies report from the Cabinet Office Performance
and Innovation Unit, adjustment of objectives when Defra was created
and following the work of the Rural Recovery Task Force, The Office
of Public Sector Reform review of Defra's delivery Landscape (2002)
and the review of the Rural White Paper commissioned in the 2002
Spending Review. Back
10
HMT (2003) Green Book. Back
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