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[1].
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[2]
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.
I. The balance and integration of environmental
and socio-economic interests.
II. The importance of independent policy advice.
III. The concept of separating policy and delivery.
IV. Overemphasis on arrangements that will benefit
farmers.
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.
VII. Inadequate proposals for the Rural Affairs
Forum for England.
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 (e.g. 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"[3]
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.
December 2003
1 HMT (2003) Green Book: Appraisal and Evaluation in
Central Government Back
2
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
3
HMT (2003) Green Book Back
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