Select Committee on Environmental Audit Third Report


Background

4. Our predecessor Committee's report of April 2005 described the sorry history of environmental assessment over the last decade. Following a failure to ensure departments carried out their own separate environmental appraisals, and a move towards Integrated Policy Appraisal (IPA) which was both ill-conceived and poorly supported, environmental appraisal was finally subsumed into the Regulatory Impact Assessment in April 2004. The RIA process became the sole mechanism for assessing and comparing environmental impacts alongside social and economic considerations, and therefore represented a critical opportunity for the effective implementation of sustainable development principles.

5. The 2005 EAC report examined several key aspects of the RIA process, notably the adequacy of the guidance provided and the accuracy of the environmental costs and benefits included in RIAs. Several key factors were identified preventing the RIA process from adequately taking account of environmental impacts: a lack of emphasis on environmental concerns; guidance which was ill-suited to the complexities of balancing environmental factors with economic and social impacts; and a fundamental conflict arising from the origins of the process in seeking to minimise the impact of regulation.

6. The report made several recommendations for how the RIA process could be improved, including:

  • the restructuring of the RIA system by inserting a higher strategic tier, which would be named the Strategic Impact Assessment (SIA), separately identifying economic, environmental and social impacts, and setting these out on a single page summary;
  • shifting the emphasis for categorising impacts away from monetisation, using instead a plus/minus 7 point scale to present environmental impacts;
  • ensuring that the policy's impact on greenhouse gas emissions is clearly highlighted and prioritised, and
  • reassessing the appraisal process so that it takes greater account of strategic objectives and targets on environmental issues, including recognising the need to encourage the development of environmental industries.

7. The report also recommended that the NAO carry out an analysis of sustainable development in RIAs on the Committee's behalf. The NAO published its briefing document on the topic on 22 May 2006. The review was based on an analysis of 10 RIAs relating to policies with likely important social and environmental impacts, and reached the following main conclusions:

  • RIAs do have a number of potential strengths for informing and influencing policy, in particular the fact that it is now a well-established process, with high levels of departmental compliance.
  • The process suffers from a number of limitations: some RIAs do not consider all aspects of a policy, and often RIAs are used to justify policy rather than inform a decision.
  • In its review of particular RIAs, the NAO found that coverage of environmental impacts was frequently limited both in terms of scope and in terms of the depth of analysis: assessment of how successfully sustainable development issues had been considered was also complicated by variable presentation of RIAs.
  • The briefing document recommended certain aspects which could lead to improved consideration of sustainable development in RIAs, namely better guidance and training, a strengthened scrutiny process, and a more consistent style and standard of presentation.

8. On the same day as we launched our inquiry, the BRE also launched its consultation into revising the RIA process.[4] In the consultation document the BRE agreed with a number of the NAO's conclusions, in particular that the current guidance was inadequate, and that RIAs are often completed too late in the policy-making process to inform key decisions. The consultation document proposed a number of changes intended to address these issues and others, such as transparency. However, environmental issues received only minimal and ambiguous coverage, something commented on by several of the memoranda submitted to us, notably that of Friends of the Earth.[5] The consultation closed on 16 October 2006.

9. It is against this background that we have conducted this short inquiry. The NAO briefing document produced for us has been invaluable in highlighting crucial issues in this area, and has confirmed many of the concerns expressed in the report of our predecessor Committee. The very fact that a consultation has been carried out by the BRE demonstrates that the Cabinet Office is also aware that the RIA process suffers from a number of limitations, yet the lack of any sustained focus on environmental concerns within that process is disheartening and the consultation consequently fails to address many of the issues raised in the 2005 report.



4   Better Regulation Executive, The Tools to Deliver Better Regulation - A Consultation Document, The document can be found at http://www.cabinetoffice.gov.uk/regulation/documents/ria/pdf/consultation.pdf  Back

5   The memorandum from Friends of the Earth is printed at Ev 27-30. Back


 
previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2007
Prepared 5 March 2007