Memorandum submitted by the University
of Manchester, Impact Assessment Research Centre, Institute for
Development Policy and Management
The Institute for Development Policy and Management
(IDPM) is a multidisciplinary centre in the School of Environment
and Development at the University of Manchester, specialising
in research, postgraduate education and consultancy work in the
field of development policy. The Institute, which was established
in 1958, currently hosts two major Research Centres for the UK
Department for International Development, in Regulation and Competition
and in Chronic Poverty, and an Impact Assessment Research Centre
(IARC), working on the impacts on sustainable development of national,
regional and international policies.
IDPM has played a leading role in the European
Commission's programme for Sustainability Impact Assessment (SIA)
of trade negotiations and agreements, has worked for both DFID
and OECD on the evaluation of National Sustainable Development
Strategies, and has been engaged in a series of intiatives for
the development and strengthening RIA systems in the UK, the EU,
and developing and transitional countries.
INQUIRY ISSUES
1. Should RIAs continue to be seen as the
key vehicle for appraising policies against sustainable development
principles, given the serious weaknesses that the National Audit
Office review highlights? Is there a better way to ensure environmental,
social and economic impacts are incorporated into policy-making?
We agree with the NAO that the RIA system should
be strengthened rather than attempting to incorporate SD issues
in some other way. If a viable alternative were developed, which
has been suggested as a possibility by the EAC, it should replace
the RIA system rather than complement it. There are two main reasons
for this. First, sustainable development has to integrate decisions
on economic, social and environmental issues. If a separate system
were introduced, it would serve to separate the issues rather
than integrate them. Second, one of the main difficulties of environmental
appraisal of policy is linking it directly to decision-making.
The RIA system already has a defined place in decision-making,
and environmental issues need to be evaluated at the same point.
2. If RIAs are seen as the best solution,
what steps are being taken to address these weaknesses, including:
— the weak link between the structure
of RIAs (and accompanying guidance) and the principles and priorities
set out in the UK's Sustainable Development Strategy;
— the difficulty of ensuring that
environmental and social impacts which are difficult to quantify
in monetary terms are fully taken into account;
— the variable quality of presentation
of RIAs, which can inhibit their ability to allow trade-offs between
environmental, social and economic impacts to be readily assessed;
and
— poor co-ordination with other
policy appraisal processes, such as European Impact Assessments
and Strategic Environmental Assessments.
In each case, will the steps taken be enough
to resolve the problem?
We are not involved in current actions to solve
the problem, beyond our contribution to the NAO work. We would
however comment on the above points.
— The weak link between RIA and SD
strategy is a key issue. If the strategy is to be implemented,
means are needed for evaluating its implementation in policy,
precisely as can be provided through the RIA process. To be effective
in this respect, RIA needs to include formal requirements for
evaluating impact on each aspect of the strategy.
— Typically, integrated assessment
draws a clear distinction between those environmental and social
impacts which have a direct economic impact, and those which do
not. The economic component of the first should always be assessed
in economic terms, while all other impacts should be summarised
separately. Multi-criteria approaches can sometimes be used for
evaluating relative importance, but more commonly the key need
is for sound analysis and transparency, so that all stakeholders
can make well informed contributions to the debate, each based
on their own (economic and non-economic) values.
— During the introduction of EIA, a
quality review process was introduced using a set of defined criteria,
enabling decision-making bodies to request revisions to the submission.
A similar approach could be used for RIA.
— Clearly, an RIA will not be valid
if it fails to take account of a relevant EU IA, and an SEA will
not be valid if it ignores a relevant RIA. Also, RIA can often
make use of information available in relevant SEAs. Better guidance
on these aspects would improve the process. It is worth noting,
however, that the European Commission's approach to Impact Assessment
exhibits the same problems of providing for an integrated and
balanced assessment of economic and environmental (and social)
impacts.
3. Does the formal role of Better Regulation
Units within departments take adequate account of sustainable
development objectives? How can training and guidance to officials
be improved?
We believe that the Cabinet Office RIA unit
can play an important role here. The unit already performs a quality
control function. This could be strengthened to ensure the Departmental
BRUs take adequate account of sustainable development objectives.
The key need is to have a review process that requires re-submission
if RIAs are inadequate. This would create the incentive to follow
the guidance and make use of training. Without a review process
and some form of sanction, training and guidance may have no lasting
effect.
4. How can the Better Regulation Executive
improve its scrutiny of RIAs to ensure that sustainable development
issues are adequately incorporated into each appraisal?
Develop a review process with agreed criteria,
as discussed above.
5. What evidence is there that RIAs make
a difference to policy outcomes? Can departments document examples
where the appraisal process has resulted in a change in the preferred
policy option to one which is more sustainable?
A fundamental weakness in the current procedures
is the absence a monitoring and evaluation stage in the RIA process.
If this were part of the process it would generate the information
needed to answer this question, and also contribute to quality
improvements over time. We have seen some evidence of this, and
would be interested in details of Departments' own examples.
6. Is the application of the RIA process
sufficiently comprehensive? Should it be extended to cover areas
such as the Pre-Budget Report and the Comprehensive Spending Review?
If not, what other processes are there to ensure that there is
transparency and accountability over the consideration of sustainable
development issues at the very earliest stages of decision making.
Are these processes adequate?
We believe that the integration that is needed
for SD cannot be fully achieved without extension to both these
areas. OECD and UN guidance on the implementation of national
sustainable development strategies calls specifically for integration
of the strategy into the budget process.
7. More generally, are there sufficient mechanisms
across government for ensuring that sustainable development is
fully incorporated into policy making in order to deliver the
Sustainable Development Strategy?
Research has shown the UK to be quite strong
on this compared with many other OECD countries. There are however
significant gaps, as revealed by the EAC and NAO reviews of RIAs.
August 2006
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