Guidance
68. The main tool assisting officials to complete
RIAs effectively is the guidance produced by the BRE and available
online.[73] We believe
that the current RIA guidance needs to be improved upon, firstly
in order to correct the "general lack of consistency in the
analysis undertaken and the presentation of results" as remarked
upon by the NAO in their annual review of RIAs for 2005-06,[74]
and secondly to improve the approach to environmental concerns
and sustainable development. The NAO's briefing for us found that
"more than half (nine out of 16) of BRUs we consulted agreed
that the BRE Guidance 'is of a reasonable quality but its usefulness
in assessing these [sustainable development] costs and benefits
is limited'."[75]
69. Guidance represents a valuable channel for ensuring
best practice and changes in the RIA process are cascaded down
to officials at the moment of compiling an RIA. It is also the
most valuable tool for successfully reinforcing the consideration
of environmental impacts in RIAs. A requirement to include such
impacts is worthless if officials do not possess the skills and
support adequately to identify and assess environmental concerns.
Unless guidance devotes considerable attention to these areas
any requirement risks being greeted as a 'tick-box' exercise whereby
analysis is carried out as a formality, rather than in a considered
and thoughtful manner. Guidance on this topic should acknowledge
the difficulties faced by policy-makers and facilitate this task
as far as is possible. It should also make clear to officials
the standards they are expected to reach in terms of scope, analysis
and presentation, and should provide the information and support
necessary to ensure these standards are reached.
70. We would like to see the
RIA guidance provided by the BRE strengthened in terms of how
it promotes and deals with sustainable development. We are concerned
that sustainable development and environmental issues are rarely
addressed directly or dealt with particularly prominently either
in existing guidance or in that proposed by the recent BRE Consultation.
We recommend that RIA guidance places strong emphasis on sustainable
development issues, referring directly to the current sustainable
development strategy and key principles. In
such a way the guidance should promote and reinforce understanding
amongst officials that a policy or regulation should seek to achieve
benefits across all sectors; economic, social and environmental,
and that these three areas should be viewed in an integrated manner
rather than as distinct, opposed domains.
71. The analysis and quantification of environmental
impacts is one area where clear, consistent guidance is considerably
lacking. Current guidance provides some general indications of
how this should be achieved, and also links to the relevant section
in the Treasury Green Book,[76]
but there is no consolidated, RIA-specific resource covering this
difficult area. Given the difficulties faced by officials when
assessing environmental impacts we are concerned that this rather
diffuse approach creates confusion and uncertainty, and we believe
a firmer guiding hand is required.
72. The BRE consultation document proposed an RIA
Toolkit, which was intended to provide "detailed guidance
on more technical issues—for example information on how
to establish competition effects—which is likely to be of
particular interest to economists and other analysts working as
part of the policy team."[77]
Given that this Toolkit was still being developed, it was unfortunately
not available to view with the consultation document. We encourage
and support the development of a single, consolidated RIA Toolkit,
as this would provide officials across government with an authoritative
and consistent resource for assessing impacts. It would also reduce
uncertainty and inconsistencies in the assessment of environmental
impacts. However, there are several factors which we hope
to see included in the Toolkit:
- In addition to assistance on
the quantification and monetisation of impacts, the Toolkit should
also advise officials on methods for assessing impacts through
qualitative analysis and descriptions, as well as the preferred
presentation and format for this. The Toolkit should acknowledge
and promote the need for different forms of analysis, and help
officials to decide what form(s) of assessment would be suitable
for each impact. This should help to ensure that environmental
impacts are dealt with in the appropriate manner.
- The figures and methods agreed in the Toolkit
should be applied cross-departmentally to ensure consistency and
prevent officials from selecting the techniques which may suit
their particular agenda. In its memorandum the Sustainable Development
Commission called for DEFRA and the BRE to work together on the
RIA guidance and Toolkit, and for all departments to "sign
up to agreed valuations, methodologies and discount rates".[78]
We support this recommendation, as we believe that greater consistency
across departments would improve the standard of environmental
assessment and would overall increase the profile of environmental
concerns in RIAs. This would also aid officials by presenting
them with a clear strategy for evaluating environmental impacts.
- We believe that the Toolkit should provide thorough
worked examples, in order to clearly demonstrate to officials
how particularly difficult areas of assessment should be tackled.
- Given the constant research into assessment,
we would like to see the Toolkit evaluated and updated regularly,
taking into account new developments in the field of impact assessment
and identifying appropriate new assessment models.
73. More generally, there are several key recommendations
we have made earlier in this report, regarding RIA guidance, which
it is appropriate to reiterate here:
- Guidance should communicate
to policy-makers the benefits of a thriving environmental industries
and services sector, and ensure that this factor receives adequate
consideration.
- Guidance should promote the consistent presentation
of RIAs within a single template, in order to maintain a clear
structure and improve the accessibility of RIAs.
- Guidance should emphasise the importance of extending
the consultation process to consult equally on environmental impacts
and with those parties particularly involved in and affected by
the environmental consequences of the implementation of the policy.
- Guidance should reiterate to officials a requirement
of including a "do-nothing" option, and provide the
information necessary for this part of the assessment to be understood
and adequately completed.
- Guidance should also reiterate a requirement
to include a "null response" for environmental impacts,
if there are deemed to be no such consequences of the policy.
This is crucial in order to demonstrate that environmental impacts
have been considered.
- Guidance should underline the importance of considering
the full range of environmental impacts, advising officials that
carbon, whilst remaining a crucial issue, is only one aspect of
a wide spectrum of environmental concerns.
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