Select Committee on Environmental Audit Minutes of Evidence

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[1]


  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 Decision Making).

  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 development—a 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 development.

  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.

  To conclude:

    —    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 priorities—a situation often referred to as departmentalism.

  Peters (1997) offers an exhaustive list of more centralised mechanisms, tools and processes to manage cross-cutting initiatives, including:

    —    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 Women brief).

    —    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).

    —    Establishing inter-ministerial committees (eg the Committee of the Ministers for Sustainable Development).

  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, through:

    —    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 means—a 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 assessment—a key diffuse tool for uncovering potential policy spillovers in UK policy making—is, 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 cross-departmental strategies

  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 Whitehall.

  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 Review—the process through which Public Service Agreements are set—have 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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(2006) Regulatory Impact Assessments and Sustainable Development. London: NAO.

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May 2007

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