Memorandum submitted by the Public and
Commercial Services Union (PCS)
INTRODUCTION AND
SUMMARY
1. The Public and Commercial Services Union
(PCS) is by far the largest civil service trade union with a total
membership of almost 300,000 working in the civil service and
related areas.
2. This submission has been created by PCS
representatives based in the Department for Environment, Food
and Rural Affairs (Defra). It may be useful for the committee
to note that PCS also represents executive, administrative and
support grades in the Countryside Agency, English Nature, the
Forestry Commission, Government Offices in the Regions, the Environmental
Agency, the Regional Development Agency and English Heritage.
3. Lord Haskins submitted his final report
to Defra on 11 November 2003. Secretary of State Margaret Beckett
has made it clear that she will not be in a position to respond
formally to the report's recommendations until spring 2004. In
the meantime, she and her officials have signalled that while
they may take on board much of the thinking behind the report,
Defra will not necessarily either accept or reject specifically
each and every one of Lord Haskins' recommendations.
4. It is almost certain, therefore, that
the official response from Defra this spring will in effect amount
to the department's own report and recommendations based partly
on the themes and ideas in the Haskins Report and partly on Defra's
own ideas and developing policies.
5. PCS will respond to Defra's ideas and
proposals when they are made known, but in the meantime it seems
appropriate for us to respond to the Rural Delivery Review report
as it stands. As we cannot assume that any of its recommendations
will be accepted or rejected it is incumbent on us to make our
position known publicly in respect of the report and its recommendations.
In doing so we would hope to make a positive contribution to both
the department's thinking and the wider public debate.
6. We have concentrated our efforts on identifying
the main issues that involve actual or potential impact on our
members' job security, terms and conditions. We have structured
the submission to responding specifically to each of the Review's
recommendations.
THE RURAL
DELIVERY REVIEW—RIGOUR
AND ACCURACY
7. There are numerous instances where we
consider the Haskins' report to be questionable and lacking in
rigour in its research and levels of accuracy. For example, paragraph
1.19 of the report demonises the Ministry of Agriculture, Fisheries
and Food (MAFF) as having been "a very centralised department",
leading to "excessive bureaucracy, an inability to recognise
distinctive local needs, slowness to react, frustrating inflexibility
and low levels of credibility". PCS believes that this perception
of MAFF is inaccurate. MAFF was one of the more decentralised
and regionalised departments within the civil service, with a
large and proactive regional organisation.
8. PCS believe a myth has been created about
MAFF, both within and outside Whitehall, and Lord Haskins has
perpetuated it in his report. The key factors that contributed
to the myth were, firstly, Bovine Spongiform Encephalopathy (BSE)
and then Foot and Mouth Disease (FMD). MAFF caused neither crisis,
but if there were problems with its handling of these issues then
the blame lies at the door of ministers and senior management
(ie those who determined the policy—not with the generality
of the staff or with MAFF's regional organisation). Indeed, without
MAFF/Defra's regional organisation and structure and its ability
to respond quickly, flexibly and in a co-ordinated fashion, the
government would have been far less able to tackle the FMD crisis
to the extent that it did, and the consequences would have been
far worse.
9. The real negative legacy of MAFF was
under-funding and under-resourcing rather than any inherent structural
or organisational weakness. That, we believe, is the crucial factor
that any implementation of the Haskins recommendations must take
into account. Whilst we would not condone waste or inefficiency,
neither can we support false economies and arbitrary cuts that
invariably turn short terms savings into longer-term losses—sometimes
with disastrous consequences.
10. In Table 1, the report asserts that
objectives 3 and 6 do not contain a "strong rural element".
Objective 3 relates to "a sustainable, competitive and safe
food supply", while objective 6 relates to "environmental
impacts" and "standards of animal health and welfare".
We struggle to see how these can be said not to have a "strong
rural element".
11. Another example of the report's lack
of consistency is that in paragraph 2.12 it includes Rural Development
Service (RDS) as one of "a number of national agencies"
funded by Defra, as distinct from Defra's "in-house delivery
agents" identified in 2.13. Later on, however, RDS is correctly
identified as being "part of Defra" (ie an "in-house
delivery agent").
A PCS RESPONSE TO
THE RECOMMENDATIONS
Recommendation 1: Defra should review
and clarify its rural policy remit in order to ensure that it
is consistently understood by all concerned, including those who
deliver its policies.
12. We recognise this as a sensible proposal.
Recommendation 2: Defra's prime responsibility
should be the development of policy, and it should arrange for
the delivery of its policies through national, regional and local
agencies. Policy and delivery functions should be managed separately
so that accountability for policy and delivery is clearly defined.
13. PCS believes the report's argument about
the separation of policy and delivery is simplistic and based
on unsupported assumptions. Separating the policy and delivery,
as proposed, assumes that they are entirely separate and separable
elements. Policy and delivery are part of a continuum and both
impact on each other. Separation would result in "ivory towers"
or "silo working" that would be the opposite of Haskins'
vision. Whilst recognising this in part, the report is very thin
on how the necessary linkage would be maintained.
14. The requirements of paragraph 4.18 would
necessitate additional funding regimes, thus increasing bureaucracy.
15. Paragraph 4.20 refers to a "dedicated
team". Is the work of this team policy or delivery? We would
need to know where such a team would be based, (ie in Defra or
elsewhere). Likewise, would the "controls, sanctions and
incentives" be wielded by Defra or someone else?
Recommendation 3: The separation of
policy and delivery functions should oblige Defra to consult delivery
organisations at the earliest stages in policy formulation and
to ask the latter to put forward proposals for the effective delivery
of policy. In this way delivery organisations will be more accountable
for effective management of programmes, and there should be less
duplication of existing regional and local schemes. Defra will
continue to appoint members of the various boards and to hold
them accountable for their performance.
16. We believe this approach runs the risk
of over-complication, confusion, tensions between various interest
groups and, ultimately, waste and more bureaucracy.
17. Paragraph 4.29 says that "Defra
will make the new policy-delivery relationship work by acquiring
the right balance of skills in its staff." This is a bold
statement, but is it deliverable? In fact, we believe that Defra's
staff already has the right balance of skills.
Recommendation 4: Defra policy officials
should develop a good understanding of delivery issues through
a programme of training and secondments to delivery organisations.
An understanding of delivery issues must be given higher priority
in the assessment of individual performance. Secondments and recruitment
from delivery organisations should also be encouraged in order
to improve mutual understanding.
18. In principle PCS does not oppose the
idea of interchange and skills transfer. The recommendation can
therefore be welcomed as a good idea, but it will require sufficient
funding. We could not countenance compulsory secondments (either
implicit or explicit). Forcing people to take on secondments,
or other forms of `interchange', which are geographically remote
from home or require work outside their normal pattern of hours,
would have obvious equality and work-life balance implications
which will need to be considered.
Recommendation 5: Deliverers should
agree targets with Defra, working with the Treasury, rather than
having unrealistic ones imposed on them by Whitehall. This would
include Defra's rural Public Service Agreement. In this way delivery
organisations will accept greater ownership of these targets,
which will be more achievable and less vulnerable to manipulation.
There should be greater emphasis on setting rural targets that
are linked to real outcomes rather than outputs (such as the number
of grants processed).
19. This is not wholly in Defra's gift.
It will rely on Treasury buy-in. As with the majority of Haskins'
recommendations, if the Treasury cannot guarantee the necessary
co-operation then it is not workable.
Recommendation 6: Delivery organisations
should have the maximum flexibility to allocate resources in the
most effective ways, whilst keeping the necessary discipline over
administrative costs.
20. How will this flexible allocation of
resources be funded, and who will monitor that the "necessary
discipline" is being applied?
21. PCS believes the problems with England
Rural Development Programme (ERDP) delivery referred to in paragraph
4.39 simply reveal the negative impact of the Treasury's imposed
cuts and constant bullying of Defra. Nothing in Haskins' recommendations
will change that reality.
22. There are risks, similar to those mentioned
in paragraph 4.40, inherent in Defra's whole E-nabling programme
which could impact negatively on Defra's ability to deliver effectively.
23. The implementation requirements in paragraphs
4.44 and 4.45 are again entirely in the gift of the Treasury,
not Defra. We are clear, though, that without proper initial and
long term funding, the crux of Haskins' whole approach is probably
undeliverable and certainly unsustainable.
Recommendation 7: Defra should agree
shared targets with other government departments and their delivery
organisations in order to secure better delivery of its rural
policy objectives. This will substantially strengthen Defra's
ability to influence outcomes.
24. This is a recommendation that goes wider
than just Defra. How will other government departments (OGD) and
their delivery organisations be brought on board and made to agree
joint targets? The implementation requirements in paragraphs 4.50
and 4.51 are completely outside Defra's power to deliver.
Recommendation 8: Defra should improve
the quality of its management information in order to take better
informed decisions and to control the administrative costs associated
with the schemes and services that it funds.
25. This is a sensible recommendation, but
would need to be considered and adopted as part of Defra's IT
strategy and, importantly, feature in the outsourcing contract
requirements. This then has implications for the scope of the
programme and the extent to which non-Defra organisations can
interface with the Defra IT system.
26. Paragraph 4.56 shows a touching faith
in the clarity of Defra's IT strategy, as well in the ease of
obtaining additional funding for "new resources". Such
funding is, however, crucial.
Recommendation 9: In pursuit of the
objectives of separating policy from delivery and of devolving
delivery, the functions of the Countryside Agency should be transferred
to the appropriate specialist organisations. Thus:
— policy development (including
the commissioning of pilots and demonstration projects), together
with the promotion of rural proofing, would pass to Defra and
the Government Offices for the Regions;
— social and economic programmes
would pass to regional and local networks of Regional Development
Agencies (RDAs), local authorities and the voluntary and community
sector;
— environmental, landscape, access
and recreational programmes would pass to the new, integrated
agency proposed below (see Recommendation 16);
— review of rural proofing, challenge
and external advice would pass to a reformed Rural Affairs Forum
for England. In the light of these changes the Countryside Agency
would cease to be required as a separate organisation.
27. In respect of paragraph 4.60, the Haskins'
view is made clear elsewhere in the report that Defra isn't doing
this work properly either, so PCS asks where is the logic in transferring
it from one supposedly "ineffectual" organisation to
another?
28. The arguments used against the Countryside
Agency in paragraph 4.63 would seem to mitigate against the new
agency as well, and in favour of keeping the work in Defra.
29. Illustration 6 goes into detail which
shows why policy development needs to take due account of results
rather than mere processes. What it doesn't do is provide any
justification for changes to organisational structure in order
to achieve this.
30. Illustration 7 similarly has a fundamental
flaw, in that it fails to recognise that funding is the key to
all this and that this will always be a top downwards process
(ie from, and controlled by, the Treasury).
31. It is not at all clear to what end staff
would transfer to the government Offices.
32. Would the Rural Affairs Forum's permanent
secretariat be civil servants, and where would they be based?
These sorts of details have been dismissed in the past by Lord
Haskins as being management problems and therefore up to Defra
to sort out. Given the extent to which such details affect the
practicality, cost and effectiveness of his recommendations, that
seems a rather negligent approach.
33. In respect of Defra taking on the funding
of National Parks and AONBs, the department's parlous and worsening
financial state will create undesirable conflicts of interest
between need and affordability. Another reason why full and proper
funding of not only Haskins' implementation but also Defra's other
work, is essential.
Recommendation 10: Regional Development
Agencies should play a key role in the devolution of Defra's rural
economic and social agenda. They must therefore demonstrate, and
where necessary develop, their capacity to contribute to sustainable
development in addressing rural needs.
34. Haskins regularly uses "regional"
and "local" as though they were interchangeable, meaning
one and the same thing. This is not the case. There is therefore
no guarantee that RDAs will be any better placed to understand
and address local delivery needs and problems than Defra.
35. We would also need to know whether it
is the intention that Defra staff would go to RDAs with the work
and, if so, on what basis?
36. In paragraphs 5.2 and 5.9, the report
talks about the need for RDAs to demonstrate their ability and
readiness to take on the work envisaged for them. How are they
to do that, and within what timescale? What if some or all of
them are unable to do so? RDAs would also need a massive injection
of funding to match even the resources currently available to
RDS.
37. Given DTI's role as "sponsor"
of RDAs, they will need to be consulted on and buy in to the strategy.
Recommendation 11: A concordat with
Defra must be established as a first step towards making the Regional
Development Agencies accountable for their part in achieving Defra's
policy objectives on rural sustainable development.
38. It is not clear who this "concordat"
would be between: Defra and DTI? Defra and each individual RDA?
Recommendation 12: The successors
to the existing business and farm diversification schemes (the
so-called "Project-Based Schemes") that are administered
by Defra's Rural Development Service under the England Rural Development
Programme should become the responsibility of Regional Development
Agencies, which will arrange for their delivery.
39. The success of this recommendation would
hinge on the issues raised in response to recommendations 10 and
11.
40. Paragraph 5.26 casually introduces a
fundamental change in policy towards agricultural businesses.
It is a far-reaching political statement that requires careful
consideration and wide consultation.
41. Paragraph 5.32(d) refers to ensuring
consistency in the delivery of future schemes, but as this will
be the province of the new agency and/or the RDAs, what role can
Defra, as a mere policymaker, play in this?
Recommendation 13: Regional Development
Agencies should have the lead responsibility in co-ordinating
public sector rural business support and advice. To that end they
should take direct responsibility for Business Links. They should
also take steps to improve the quality and consistency of business
support and advisory services.
42. We have no comment on this.
Recommendation 14: Local authorities
and local partnerships should assume the main responsibility for
delivery of schemes and services to rural communities. They should
be fully consulted by Defra and the Regional Development Agencies
about any changes to policy and delivery arrangements and should
be given the necessary flexibility to address local needs. The
potential of Rural Community Councils as partners in community
based delivery is underestimated and should be enhanced.
43. How is the necessary funding to be effectively
assessed, accounted for and audited? It would also seem inevitable
that this recommendation will involve considerable duplication
of effort. The public will need, and deserves, convincing evidence
that the benefits of this recommendation significantly outweigh
the increased costs to the taxpayer in duplicated administration
and bureaucracy.
44. Do all Local Authorities have the necessary
resources and skills to be able to deliver on this recommendation?
What if some do but some can't (or just don't want to)? It would
surely require legislation to require Local Authorities to meet
these new responsibilities and to carry on doing so. They will
also, quite rightly, need and expect increased funding from government
to carry out this new role properly and without adding to Council
Tax bills.
45. In paragraph 5.47, it is not clear what
significance Lord Haskins is placing on the fact that seven Councils
out of thirty applications had been awarded "Beacon Status"
in the latest round of assessments. This means that 23 of the
Councils applying were not awarded Beacon Status. PCS asks what
point is the report making? The situation described seems to be
a clear example of the current state of unpreparedness, if not
unsuitability, of Local Authorities to take on the key role that
Haskins assigns to them.
46. Paragraph 5.50 refers to the government's
aim of "promoting the voluntary and community sector".
Haskins sees a role for the voluntary sector in respect of the
delivery of the government's rural policy. The flaw here is that
the question of the extent to which delivery of services can be
(a) required or (b) guaranteed from organisations that, by definition,
rely on volunteers is totally ignored. We are concerned that use
of the voluntary sector is merely a means of getting the work
done on the cheap. But it might also allow a ready-made excuse
if there were delivery problems, as that could conveniently be
blamed on the lack of volunteers. We have serious concerns about
continuity of service and of government accountability, both to
the public and to parliament, in respect of this whole approach.
47. Paragraph 5.51 specifically identifies
Groundwork Trusts in England as playing "a central role for
Defra in community regeneration" under Haskins' envisaged
arrangements. But, as with many other of his suggestions, there
is no explanation of what that role might consist of, how it would
be co-ordinated and monitored, nor how it would be resourced.
It is mentioned that these Trusts are currently "supported
by the national and regional offices of Groundwork UK, which is
part-sponsored by the ODPM". At the very least, the issue
of their role for Defra, whatever that may be, would require co-ordination
between Defra and ODPM over both strategy and the funding of Groundwork
UK.
48. Paragraph 5.52 expresses Lord Haskins'
belief that "local flexibility is essential to target and
meet need effectively". We would agree with the need to target
and meet need effectively by properly addressing real and identified
needs on the ground. But there also needs to be national consistency
and co-ordination to ensure value for public money, avoidance
of unnecessary duplication, and harmony with other and wider government
priorities and initiatives. What the Haskins Report also fails
to address is the balance between unique local issues and common,
cross-national ones.
49. In paragraph 5.54, Lord Haskins introduces
a curious counter-philosophy, (ie that "Defra must accept
some inconsistencies . . . as a natural corollary of more local
delivery"). He advocates this in order to justify greater
use of Local Authorities and other localised delivery organisations.
However, there is surely a significant risk in any such approach
that it would lead to the sort of postcode lottery that is becoming
increasingly a source of criticism in respect of the delivery
of health care and, to an extent, of education. Whilst the principle
of local delivery might be a laudable one, we must nevertheless
express as a primary concern the fear that local inconsistencies
will lead to variable standards and to some recipients of rural
services from Defra, and/or other organisations, suffering arbitrarily
from an inferior service. It is surely harder to deliver a multiplicity
of diffuse localised services to a consistently high and regular
standard than it is to deliver such a service centrally but utilising
a number of co-ordinated units within a single department and/or
several linked and co-ordinated Agencies.
Recommendation 15: As part of the
next round of local public service agreements Defra, working with
other government departments and the Local Government Association
should agree joint Whitehall targets for the delivery of rural
policies by local authorities. Develop a more integrated approach
to sustainable land management by rationalising agencies with
overlapping agendas (see Chapter 6).
50. This recommendation would require some
difficult and complex negotiation between independent parties.
Who would have the responsibility and, most importantly, the authority
to ensure successful delivery of "joint Whitehall targets"?
Recommendation 16: The government
should establish an integrated agency to promote sustainable use
of land and the natural environment. This is necessary in order
to prepare for the expanding land management agenda and to improve
co-ordination and service delivery to customers. This would be
achieved through a merger of English Nature, Defra's Rural Development
Service and some functions of the Countryside Agency. Its remit
should embrace biodiversity, historical landscape, natural landscape,
natural resources, access and recreation.
51. The concept of a new "integrated
agency" is something about which we should remain neutral.
Our focus of interest at present is in ensuring that:
— Such an agency would be properly
funded;
— The agency could reasonably be expected
to last for a significant period of time;
— The terms and conditions of staff
employed in the agency would be harmonised quickly and on the
basis of the best obtaining amongst the "exporting"
departments, Agencies and NDPBs;
— TUPE terms would apply as appropriate;
and
— There would be full and proper involvement
of the trade unions.
52. The recommendation refers to the new
agency's remit including the "historical landscape".
This term is not defined in the report, but it is clearly the
current province of English Heritage. The connection is further
underlined by the references to English Heritage in paragraphs
6.4, 6.12, Illustration 8 and Table 4. And yet there is no mention
of English Heritage becoming part of the new agency. There is
a need for clarification of the potential impact of the new agency's
role and responsibilities upon the work and resources of English
Heritage.
53. In paragraph 6.14 Lord Haskins claims
that "it is not possible to obtain the full benefits of integration
without substantial structural reform". We would challenge
that assertion, because in our view it would be entirely possible—and
arguably more desirable and more effective—to achieve the
same ends through closer partnership working between existing
organisations. We believe that separation of policy and delivery
is too simplistic a notion. These two aspects, as stated above,
are elements within a continuum. Separation of policy and delivery
would actually be counterproductive and damaging. What is needed
is to provide a degree of separation between the policy makers
and the deliverers that allows the deliverers a certain latitude
to address specific local needs, but that maintains the essential
linkage between the creation of policy and its application in
practice. Also, not separating policy and delivery removes the
necessity subsequently to reinvent and re-establish a linkage
in order to allow the deliverers a mechanism for informing and
influencing policy-making.
54. The creation of the new agency as an
NDPB, as suggested in paragraph 6.35, gives us some problems.
From a Defra perspective, it would mean that any staff transferring
to the new agency would cease to be civil servants. Alternatively,
if the new agency were to be an executive agency then it would
mean a change of employment status for our colleagues in Countryside
Agency and English Nature (which are themselves NDPBs).
55. Paragraph 6.35 attempts to provide an
objective justification for NDPB status. Haskins argues that making
it an executive agency of Defra "would not provide the level
of independence that is necessary for such a body to work".
In PCS's view that appears to reveal both a degree of naivety
on Haskins' part, and a basic misconception of how executive agencies
operate. The agreement setting up such an agency will set out
the extent of its functions and its distance or otherwise from
the parent department. It would be entirely possible to draw up
an agreement for the new agency that guaranteed it the necessary
operational freedom and independence.
56. Haskins envisages the new agency maintaining
"an arm's length relationship with Defra (from which it would
receive its funding)". That is precisely how many executive
agencies operate—some of them even less tightly linked by
direct funding. But it is precisely that funding position that
would allow Defra to exert directing pressure on the new agency,
should it choose to do so and whatever its status, thus negating
the very independence that Haskins believes NDPB status accords.
The choice between executive agency and NDPB therefore seems fairly
academic, but it would have real and significant implications
for the staff.
Recommendation 17: Defra should establish
close collaboration between the Environment Agency and the new,
integrated agency so that their activities complement each other.
57. Notwithstanding our caveats about the
new agency, we could support this recommendation because the principles
of close collaboration and complementary activity are what, we
have argued, form the basis of an alternative to the Haskins approach.
Recommendation 18: Consistent with
the principle of clear separation of policy from delivery functions,
the policy development role of the Forestry Commission in England
should be transferred to Defra.
58. This would involve additional work coming
to Defra but, as it would have an impact on members in Forestry
Commission. We therefore remain neutral on this recommendation
for the time being.
Recommendation 19: Following the creation
of the new integrated agency, it is logical to integrate or closely
align the delivery functions (regulation, incentives, advice)
of the Forestry Commission in England with those of the new agency.
59. This recommendation affects the Forestry
Commission alone and PCS would like to suggest that more consultation
on this issue takes place.
Recommendation 20: Defra should seek
opportunities to rationalise the various levy-funded organisations
that it sponsors in respect of certain agricultural sectors for
marketing, developmental and other purposes. There is scope to
share resources (administrative, economic and research) between
the various boards and to strengthen support for industry programmes
if savings are realised through rationalisation. Improve the co-ordination
of delivery by enhancing the role of Government Offices for the
Regions as co-ordinators and monitors (see Chapter 7).
60. We have no comment on this.
Recommendation 21: The Government
Offices for the Regions should be given a stronger remit to promote
co-ordination of and monitor rural delivery and to promote rural
proofing on behalf of Defra. Regional Rural Priority Boards, chaired
by Government Offices for the Regions and including key regional
and local bodies responsible for rural regeneration and service
delivery, should be set up to provide strategic co-ordination
and monitoring.
61. Again we have no specific comment on
this in principle.
Recommendation 22: Delivery agencies
should strengthen joint working through the development of joint
regional delivery plans. These would include designated lead delivery
partners, agreed joint targets, shared resources and clear accountability
for delivery.
62. We support this recommendation as it
makes sense and it can be applied irrespective of other recommendations,
eg the plans for the new agency.
Recommendation 23: Defra must consult
earlier and more closely with the Government Offices for the Regions
to ensure more co-ordinated policy development and strategic planning
at the national level and reduce the number of strategies that
are handed down to the regions.
63. Again we support this recommendation
as it makes sense and it can be applied irrespective of other
recommendations.
Recommendation 24: The Government
Offices for the Regions should focus on their role as co-ordinators
and monitors of programmes affecting rural areas and not be involved
in direct delivery. They should disengage from their current role
in the administration of EU Structural Funds if and when these
are replaced by a national programme of regional regeneration,
as the government has proposed.
64. We have no specific comment on this.
Recommendation 25: Regional Rural
Affairs Forums (RRAFs), comprising representatives of rural customers
and beneficiaries, should become the forums in which national
and regional delivery of rural policies is reviewed and reported
on. Their key duties would be:
— to highlight important issues
and priorities for rural development and service delivery;
— to comment on the effectiveness
of rural development and service delivery in their region and
identify areas for improvement;
— to comment on the impact and effectiveness
of existing policy developments and generate new ideas;
— to provide leadership to help
drive rural development at regional and local level. The RRAFs
would receive secretariat services from the proposed Rural Priorities
Board secretariat (see Recommendation 21).
65. Pending more detail, we remain neutral
on this recommendation for now.
Recommendation 26: The Government
Offices for the Regions should work with regional and local organisations
to develop a more co-ordinated approach to front line delivery.
This should include spreading best practice between regions on
integrated delivery and facilitation, recognising what is practical
and affordable.
66. Again, pending more detail, we remain
neutral on this recommendation for now.
Recommendation 27: Defra, as the lead
body, should accelerate the development of a "whole farm"
approach that will ensure better co-ordination of government regulation
and compliance, subsidy, advice and financial incentives linked
to farm businesses. This would require:
— the development of an integrated
rural database linked to land-based business (to which the Environment
Agency would have access), subject to resolution of data privacy
constraints;
— Risk-based self-assessment backed
up by audit, preferably using such independent bodies as FWAG
and LEAF;
— encouraging more rapid uptake
of internet use by farmers and rural businesses in general;
— the creation of a farm advisory
service in the light of the recent settlement on CAP reform; this
would logically fall under the control of the new, integrated
agency (see Recommendation 16).
67. There are serious issues of practicality
and realism surrounding this recommendation that will need to
be addressed carefully. The report also fails to address the staffing
issues, and we are concerned about the dangers inherent in losing
experienced staff in any attempt to simplify inspections across
what is a diverse and complex range of expertise.
68. The creation of an integrated rural
database raises issues in respect of Defra's IT Strategy and,
arguably, for the outsourcing contract. The inclusion of disparate
organisations, such as the environment agency, also raises issues
in respect of the capabilities their own IT systems and the ability
of existing but different systems to communication with each other.
Whatever, there are clearly significant cost implications for
all of this.
69. The recommendation also calls for "more
rapid uptake of internet usage by farmers and rural businesses".
Defra's attempts so far (and MAFF's before it) to achieve this
have not been a resounding success. This is as much down to the
lukewarm response from farmers as it is to the difficulties inherent
in providing workable and user-friendly electronic forms for example.
70. PCS believes that the recommendation
for a "farm advisory service" would appear to hark back
to the days of ADAS before it was split up and privatised over
a decade ago. This highlights the danger of making sweeping structural
changes to government departments on the basis of political fashion
rather than practicality and proven need.
Recommendation 28: In view of the
expanding environmental protection agenda, the Environment Agency
should agree with local authorities a supplementary role on regulation
and compliance. Local authorities should agree standards for delivery
with the Agency and call in its support where the extent of a
problem or the risks connected with it are beyond the authorities'
capacity to manage.
71. While we remain neutral on this recommendation,
we would reiterate the concerns already expressed about the use
of Local Authorities. It should perhaps be pointed out, though,
that the creation of the Environment Agency involved the significant
transfer of work (and staff) from Local Authorities. Again we
fear the prospect of once more going round in circles for no good
reason.
Recommendation 29: Local authorities
should take the lead local role in co-ordinating general regulation
and compliance advice on farm premises.
72. We once again reiterate our concerns
about the role of Local Authorities, especially in respect of
delivering policy advice and applying regulations that require
national consistency and co-ordination.
Recommendation 30: Defra should rationalise
its inspection functions, integrating them wherever possible with
existing regulatory authorities to achieve administrative savings
and avoid duplication of skills.
73. This could be said to be linked with
the whole farm approach, but it should be pointed out that the
various inspection regimes referred to cover a diverse range of
specialised areas. We are far from convinced that there is scope
for significant rationalisation, even allowing for any partial
overlap. Again, it may be that better co-ordination is required,
but that could be achieved effectively in-house. Better funding
would also be required, and we challenge the assumption in the
report that rationalising inspection functions would necessarily
produce administrative savings. There is nothing in the report
that backs up that assertion. Whilst collaboration might reduce
the number of inspections overall, the mechanisms and processes
required for co-ordinating such collaboration might even see the
need for more administrative resources.
Recommendation 31: Defra should review
all rural funding streams and schemes, to achieve a more rational,
transparent and comprehensible approach to the administration
of financial incentives and to ensure that all new initiatives
are consistent with Defra's delivery strategy, add real value
and do not duplicate.
74. PCS could probably accept a review as
recommended, providing that the necessary resources are allocated
to Defra to carry out such a review on top of all the other things
that are currently being reviewed and/or changed in the department,
which are considerable.
Recommendation 32: Defra should review
and simplify the current procedural rules connected with grants
to rural businesses and communities in order to provide greater
discretion in the execution and targeting of grants in a user-friendly
way, consistent with state aid rules.
75. Again, we could accept a review as recommended,
providing that the necessary resources are allocated to Defra
to carry it out.
THE IMPLEMENTATION
OF THE
RECOMMENDATIONS
76. We have made the point several times
that implementation of Haskins is only feasible if sufficient
additional money is made available by the Treasury to fund it.
Haskins himself makes the point, in paragraph 9.2, that partial
funding of the recommendations will not be acceptable. He rejects
the "sticking plaster" approach and so do we. If changes
are going to be made then they must be:
— Made in full consultation with the
trade unions; and
77. We have not yet seen Lord Haskins' business
case, but we have formally requested it from Defra. Judging by
the report, there are reasons to doubt its robustness and its
accuracy. Not least in this is the ease with which Lord Haskins'
believes that savings can be realised through giving up accommodation
within the government estate. This seems not to take proper account
of, amongst other things:
— The exit costs involved;
— The extent to which accommodation
is currently shared with others, and/or not owned by Defra per
se, so not fully disposable; and
— The implications in terms of redundancy
and/or relocation costs associated with the wholesale closure
of offices.
CONCLUSION
78. Lord Haskins acknowledges the many disparate
factors affecting the costs and practicalities of his recommendations
but, it would seem, either without fully grasping their true significance
or without paying these things much heed (regarding it as being
Defra's problem and not his). That is not a luxury that the unions
enjoy. We have a responsibility to look beyond the vision to the
reality. That is what this response to the Rural Delivery Review
is intended to do. We trust that Defra's own response, when it
comes, will do the same.
Public and Commercial Services Union (PCS)
January 2004
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