Memorandum submitted by Dr Duncan Russel
and Dr Andrew Jordan, Centre for Social and Economic Research
on the Global Environment (CSERGE), School of Environmental Sciences,
University of East Anglia, Norwich, United Kingdom
We welcome the Committee's enquiry on the structure
and operation of government in relation to the critical issue
of climate change. Given the IPCC's findings that there may be
little time left to rise to the challenge of decarbonisation,
it is vital that the United Kingdom (UK) government system is
better geared towards integrating the consideration of climate
impacts into its policy making.
CSERGE at the University of East Anglia has
been at the forefront of economic, social and political research
on sustainable development. This memorandum is based on our ongoing
research on policy coordination for sustainable development. This
work has been generously funded by the UK Social and Economic
Research Council (PTA-026-27-1094 and the Programme on Environmental
The main point we wish to make in this memorandum
is that creating a separate coordination process for climate change
would unnecessarily add to the already burgeoning list of cross-cutting
issues that busy policy makers are required to engage with. Instead
we would argue that energy would be better spent on improving
the performance of the existing cross-governmental coordination
strategy for sustainable development, which perforce should account
for climate change. In the remainder of this memorandum, we not
only seek to address the issues the Committee wishes to examine,
but we also suggest ways in which the Government's cross-cutting
sustainable development process might be improved.
What cross-departmental strategies exist, and
to what extent are they effective?
Since the publication of the Labour Government's
Modernising Government White Paper (Cabinet Office 1999) there
has been an explosion of strategies to manage different cross-cutting
issues (eg better regulation, social exclusion, women and families
and sustainable development). Our research has predominantly focused
on the UK's efforts to coordinate policy making in relation to
sustainable developmenta cross-cutting issue par excellence,
which includes climate change is a key element. Our research demonstrates
that the UK has been an international frontrunner in the pursuit
of more sustainable policy making. Indeed, the UK has a long history
of trying to achieve greater environmental coordination, and has
latterly shifted its focus more towards sustainable development.
In doing so, it has developed a number of different mechanisms
(eg an Environment Cabinet Committee, Sustainable Development
Ministers, and a Sustainable Development Unit) and tools (eg policy
appraisal systems such as regulatory impact assessment) to better
factor sustainable development considerations into departmental
policy making. It is not, therefore, surprising that the Organisation
for Economic Cooperation and Development (2001; 2002) has recently
applauded the UK for its innovative approach to pursuit of sustainable
Despite these apparent strengths, our findings
suggest that the implementation of the UKs various mechanisms
and tools to integrate sustainable development into UK policy
making has, on the whole, been inconsistent and weak. Indeed,
some of the elements (eg policy appraisal and the Environment
Cabinet Committee) have been spectacularly ineffective. Moreover,
many of them have been developed and established in a rather incremental
and incoherent manner through successive waves of initiatives
(Russel 2007). As such, there has been a general lack of clarity
as to how the different mechanisms, processes and tools are meant
to feed into each other and pull together to deliver sustainable
development. As a result we find that efforts to manage cross-cutting
sustainable development have been highly departmentalized.
Our evidence suggests that the
government's attempts to facilitate cross-governmental action
on sustainable development have been weak. As a result crucial
issues such as climate change have not been systematically or
effectively integrated into the policy making activities of departments.
Where is there a need for new or revised cross-departmental
strategies, and how these could be implemented?
According to the Organisation for Economic Cooperation
and Development, the traditional response of creating new institutions
and processes to deal with emerging issues might not always be
appropriate, as administrations may lack the capacity to respond
to the challenges involved (OECD 2002, p 2). Thus, the addition
of new cross-cutting strategies runs the risk of overloading the
policy making system. For instance, our research demonstrates
that when civil servants have too many considerations to factor
into their policy making, they may lack the skills and resources
to deal with them all effectively. As such there is a possibility
that they pick and mix between competing issues to suit their
own departmental interests. Thus, by placing a separate emphasis
on climate change, there is a danger that other important sustainability
issues (eg biodiversity loss) might be crowded out and thus sidetracked.
We therefore feel it is more important for the Government put
its energy into improving the operation of existing cross-cutting
initiatives, rather than risk over-loading the system by adding
new ones. For instance, if operating properly, the government's
existing strategy to coordinate on sustainability development
should pick up on climate change issues, which should arguably
render the need for a new, separate cross-cutting process redundant.
How effectively can such strategies can be managed?
There are many approaches that can be used to
manage cross-cutting initiatives. These can be broadly grouped
under the categories of centralised or diffuse approaches. Often
they are presented as either rival or complementary approaches
(OECD 1996). Very simply put, centralised approaches are intended
to minimise the discretion departmental policy makers, to ensure
a consistent cross-government line is followed. However, these
centralised approaches run the risk of overloading the heart of
government and overriding departmental expertise. By contrast,
more diffuse approaches are aimed at encouraging departmental
policy makers to engagement with cross-cutting issues, with central
actors becoming involved where there are differences of opinion
between departments that are irreconcilable. This approach allows
for greater local flexibility and makes use of departmental expertise.
Conversely, the lack of strong central steering may potentially
lead to a situation whereby departments follow their own separate
lines of action to deal with cross-cutting prioritiesa
situation often referred to as departmentalism.
Peters (1997) offers an exhaustive list of more
centralised mechanisms, tools and processes to manage cross-cutting
Leadership by the Prime Minister
through his or her personal office.
Assigning responsibility for
joined-up initiatives to central departments (eg the Cabinet Office's
management of social exclusion).
Using the Cabinet and cabinet
committees to manage cross-cutting objectives (eg the Cabinet
Sub-Committee on Policy for Children).
Adding cross-cutting issues
to ministerial briefs (eg The Secretary of State for Communities
and Local Government Ruth Kelly was also given the Minister for
Creating super ministries which
incorporate a range of responsibilities (eg the Department of
the Environment, Food and Rural Affairs).
Founding integration units within
(central) departments as centres of excellence (eg the Better
Regulation Executive Unit in the Cabinet Office).
committees (eg the Committee of the Ministers for Sustainable
More diffuse mechanisms, process and tools are
often based around the need to create an institutional culture
that embraces joined-up policy making on cross-cutting issues,
Building up capacity to join-up
within departments by helping participants in the policy process
exchange information (eg using tools such as policy appraisal);
identifying areas were coordination is required (as the government
has done with several cross-cutting issues including sustainable
development); and arbitrating where conflicts between participants
are not resolved informally (eg through more centralised means
such as inter-ministerial committees) (Jordan and Schout 2006).
Incentivising officials to unlearn
habits and practices that might hinder joined-up working.
Providing bureaucrats with the
right tools (6, et al. 2002, p 109) to identify cross-cutting
issues that need joining-up, and to generate and exchange information
on possible policy spillovers into and out of particular sectors
(eg policy appraisal).
Our research findings on sustainable development
suggest that cross-cutting issues are best tackled using a two-pronged
approach incorporating a mix of centralised and more diffuse meansa
view shared by the Organisation for Economic Cooperation and Development
(OECD 1996). Of course, having a blend of such approaches is not
in itself sufficient; the various component parts have to work
individually and in combination. Crucially we have found that
an effective supply of information on potential policy spillovers
is very important. Without such information it is difficult to
see how conflicts of interest can be systematically uncovered
to provide the initial spark for coordinated cross-governmental
action. Moreover, when there is a paucity of data on potential
policy spillovers, there is little for more centralised bodies
such as cabinet committees to work with, thus leading to the break
down of coordination. To this end, procedures such as policy appraisal
are essential. However, our research shows that poor implementation
of policy appraisal, which has been well documented by Environmental
Audit Committee (eg HC 353, Session 2006-07) and elsewhere (National
Audit Office, 2005, 2006; Russel and Jordan 2007), has significantly
hampered the UK's attempts to tackle cross-cutting sustainable
development (which is an issue we return to below).
That said, the problem is more complex than
simply ensuring that information on policy spillovers is made
readily available. There is a need for the more centralised processes
to create demand for such information and to manage information
exchange between departments (OECD 1996, p 15). Our research suggests
that where there is a lack of sustained high-level leadership,
cross-cutting initiatives may fail to make significant headway,
especially if they are managed by departments low in the Whitehall
hierarchy as is the case with DEFRA and sustainable development.
To this end, the efforts of the Prime Minister are essential.
However, the Prime Minister cannot be championing a specific cross-cutting
issue such as climate change all of the time, as other high-profile
issues will inevitably compete for his or her attention. Therefore,
it is vital that more centralised bodies (eg the Cabinet Office)
are used to better orchestrate cross-governmental action. That
said, even where a central presence exists, there may still be
difficulties. For example, while the Cabinet Office's Regulatory
Impact Assessment regime has high compliance levels, there are
well documented procedural problems with the process, meaning
that many assessments have little impact on policy outcomes (National
Audit Office 2005; Russel and Jordan 2007).
This brings us to the issue of having adequate
diffuse approaches to ensure that there is sufficient administrative
capacity within departments to tackle cross-cutting issues. In
this respect, our work demonstrates the importance of giving policy
makers appropriate tools to join-up (6, et al. 2002, p
109). Our research demonstrates that regulatory impact assessmenta
key diffuse tool for uncovering potential policy spillovers in
UK policy makingis, in its current guise, unsuited to the
needs of policy makers. Indeed, regulatory impact assessment as
currently advocated, assumes a rather rational and linear view
of the policy-making system. However, our interviewees suggest
that in reality they have to deal with pre-defined agendas, manifesto
commitments, tradeoffs with other departments, pressure from outside
groups, etc, all of which make ex-ante regulatory impact
assessment, as currently prescribed, difficult to apply. Moreover,
despite guidance (eg Cabinet Office 2003) being strongly in favour
of quantification, there seems to be a reluctance to quantify
impacts, especially in areas where uncertainty exists such as
climate change. Crucially, we find that tools such as regulatory
impact assessment need to be backed-up by programmes of sustained
learning (eg rolling training schemes and centres of expertise).
This goes well beyond the issue of short-term training, to include
the need for appropriate incentives (eg budgeting, career development
paths) to encourage departmental staff to positively embrace cross-cutting
issues in the long-term.
To conclude, we suggest that the Government
should concentrate on improving the performance of its existing
strategy to integrate sustainable development into policy making,
rather than embarking on a separate process for climate change.
To this end:
Central bodies (ie the Cabinet
Office and Prime Minister) should take on a stronger leadership
role to pursue cross-governmental compliance with sustainable
development goals. For example, more effort could be placed on
ensuring that regulatory impact assessments pick up and provide
robust analysis on potential climate (and other sustainable development)
impacts. In this regard, the Panel for Regulatory Accountability,
chaired by the Prime Minister, could broaden its scope so that
it scrutinizes regulatory impact assessments for there consideration
of sustainable development impacts alongside business ones.
More training and incentives
for staff should be provided to encourage them develop the skills
sets (eg the ability to conduct a regulatory impact assessment)
needed to deal cross-cutting issues. This could be done, for example,
by integrating climate change goals into job descriptions and
making involvement in cross-cutting initiatives a favourable condition
for career development.
The role of the Office of Climate Change in its
inter-departmental activity, and its interaction with existing
The Government could clearly learn lessons for
its Office of Climate Change from the Sustainable Development
Unit, which has frequently been criticised because of its lowly
role, status and position in Whitehall (HC 426-I, session 1998-99;
Jordan 2002a: 48) due to it being housed in DEFRA. Thus if the
Office of Climate Change is going to have any bite, it should
ideally be situated at the heart of government (ie Cabinet Office)
to give it the authority to pursue the climate change agenda across
That said, we have already voiced our concerns
over the proliferation of cross-cutting initiatives, which may
overcrowd the policy-making arena. Moreover, it is unclear how
the Office of Climate Change will interact and avoid replication
of the work of key parts of the Government's sustainable development
machinery, especially the Sustainable Development Unit.
Therefore, to conclude:
It might be better for the government
to put its efforts into making its existing strategy to deliver
cross-cutting sustainable development work more effectively (as
we state above), by, for example relocating the Sustainable Development
Unit to the Cabinet Office). By doing so, it would avoid adding
another layer of bureaucracy to policy making, and allow climate
change to be considered along-side other critical and sometimes
interrelated issues (eg biodiversity).
The setting of targets and Public Service Agreements
Our research shows that the application of sustainable
development-related targets to policy making and delivery has
been weak. We feel that Public Service Agreements could be a potentially
powerful way of setting targets to tackle critical issues such
as climate change. However, as this Committee has itself previously
reported, Public Service Agreements, to date, have not been comprehensively
aligned to goals in the United Kingdom's Sustainable Development
Strategy (HC 961, Session 2002-03, para 34). Nevertheless, the
government indicates that it views the use of Public Service Agreements
as an important mechanism to help implement its sustainable development
strategy (HMG, 2005: 154), including targets relating to climate
change. It is unclear exactly how it intends to do this. Moreover,
our research on the Government's efforts to integrate sustainable
development into the Spending Reviewthe process through
which Public Service Agreements are sethave been rather
ineffective. This was the even the case in the 2002 Spending review
in which departments were required to produce a stand-alone sustainable
development report to support their bids for funds. Our interviews
with officials who were involved in the production of these reports
reveal that the process was not very systematic with many reports
being of poor quality and not used to inform their respective
department's bids. Many were thus little more than cursory after-the-event
justifications. Despite these deficiencies, departments still
had their bids approved by the Treasury. Moreover, given the poor
quality of the reports, it is difficult to see how appropriately
targeted Public Service Agreements could have been set. In the
2004 Spending Review, the experiment with stand-alone sustainable
development reporting was dropped. It is thus unclear how sustainable
development issues, including climate change, are to be consistently
and coherently integrated into the spending plans of departments
and Public Service Agreement targets.
To conclude we would argue that:
Compulsory sustainable development
reports should be reintroduced to the Spending Review processes
to help set appropriate Public Service Agreements targets on key
issues such as climate change. However, the Treasury must ensure
that where department's reports are substandard or Public Service
Agreements are not met, there are appropriate incentives (eg the
allocation of special funds for cross-cutting projects) and penalties
(eg the freezing of funding) to ensure compliance.
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