Written evidencesubmitted by Dr John Turnpenny,
Professor Andrew Jordan, and Dr Tim Rayner, University of East
Anglia; and Dr Duncan Russel, University of Exeter |
We welcome the Committee's investigation into how
well sustainable development is embedded across government and
the prospects for the future. The inquiry comes at a particularly
important time following the government's decision to withdraw
funding from the Sustainable Development Commission (SDC) and
scrap the Royal Commission on Environmental Pollution (RCEP),
while proclaiming itself still committed to evidence-policy-making
and sustainable development. It is important that the Committee
fully investigates the barriers to embedding sustainable development
across government, how mechanisms to achieve such embedding have
performed, and draws lessons from this when proposing new mechanisms
in response to the recent government decisions.
This memorandum sets out our perspectives on these
issues. The University of East Anglia has a strong research tradition
in the field of sustainable development, hosting the Centre for
Social and Economic Research on the Global Environment (CSERGE)
and the Tyndall Centre for Climate Change Research. It has led
pioneering work on environmental policy integration (EPI), and
on mechanisms such as policy appraisal, expert advisory bodies
and parliamentary committees. The University of Exeter's Climate
Change and Sustainable Futures research strategy brings together
leading experts from different disciplines across the University
to understand the many factors that contribute to climate change,
and to develop solutions. Its Department of Politics has core
expertise in regulatory governance and impact assessment.
The evidence we provide is based on ongoing research
on EPI in UK central government and a number of other jurisdictions,
and on recent research funded by the Nuffield Foundation (Social
Science Small Grant SGS/37317) on the Environmental Audit Committee
We have divided our response into two parts. The
first addresses three of the inquiry's questions by examining
the integration of environment and sustainable development into
policy-making generally. The second part of our submission focuses
on the relationship between the SDC and the EAC. We make corresponding
sets of recommendations.
Q1. How can mechanisms to ensure the sustainability
of Government operations, procurement and policy-making be improved
and further embedded and mainstreamed across Government departments?
Q2. How can governance arrangements for sustainable
development in Government be improved, and how can sustainability
reporting by Government departments be made more transparent and
Q4. In formulating a future architecture for
sustainable development in Government, how can it take on board
wider developments and initiatives (e.g. to develop "sustainability
reporting" in departments' accounts) and the contributions
that other bodies might make (e.g. Centre of Expertise in Sustainable
- What is "integration"?
Ever since the United Nations-sponsored World Commission
on Environment and Development (aka "Brundtland Report")
called for more sustainable forms of development (WCED, 1987),
governments worldwide have sought to adjust their governance systems
to embed sustainability. A popular approach in many OECD countries
- including the UK - is that of "environmental policy integration"
(or EPI). The aim of EPI is to systematically integrate environmental
factors into all stages of government policy making regardless
of sector (WCED 1987: 314). While EPI does not in itself constitute
sustainable development (the two are arguably rather different
- see below) it is a vitally important part of the concept, as
it gives environmental issues greater prominence alongside traditionally
more dominant social and economic issues. In a comprehensive review
of the theory and practice of EPI, it was described as a "first
order principle to guide the transition to sustainability"
(Jordan and Lenschow 2010: 147)
EPI has been mainly conceived as a coordination challenge
for public administrations - hence "greening government".
As a result, governments right across the OECD have responded
by adapting their tried and tested means of policy coordination,
such as: establishing environment cabinet committees to resolve
interdepartmental conflicts; creating networks of green ministers
to exchange information and ideas; locating integration units
in all departments to monitor progress, provide expertise, produce
guidance and share best practice; incorporating environmental
assessment into central budgetary procedures; and using policy
appraisal or impact assessment (IA) to uncover the potential environmental
impact of new policies. Some have also utilised "softer"
governance approaches such as altering their constitutions to
highlight EPI, inaugurating reporting processes through which
every department produces an integration strategy, and establishing
bodies to offer guidance. Finally, others have established longer-term
integration targets for different departments to aim at.
- How well have these efforts fared?
Recent research on the implementation of these instruments
and procedures has shown that they have had rather mixed results
(Jordan and Lenschow, 2008). A comprehensive review of integration
practices in 30 OECD states demonstrated that governments have
tended to select different combinations of instruments and procedures
(Jacob et al. 2008). In general, the softer, so-called
"communicative" instruments (changing constitutions,
initiating reporting exercises, establishing new committees etc.)
have been far more commonly adopted than the harder "organizational"
or "procedural" ones (appraisal, green budgeting, long-term
target setting etc.).
Moreover, while many governments have extended their
existing repertoires of coordinating instruments, many have done
so in a rather piecemeal fashion. Curiously, many of the EPI instruments
that were supposed to deliver more integration have themselves
been poorly coordinated with one another (Schout and Jordan, 2008).
While it is important to have an array of different and innovative
instruments to support and drive EPI, variety alone is not sufficient.
They have to fit with and support one another. In summary, EPI-type
exercises in the OECD countries have largely failed to systematically
mainstream sustainable development in the manner advocated by
Brundtland. Instead states have tended to adopt a "pick and
mix" approach. Invariably, this pattern of deployment has
left some of the most environmentally vital areas of state activity
mostly unaffected. Indeed, across the OECD the core policy planning
activities in "driving force" sectors such as industry,
transport and agriculture have mostly remained immune to scrutiny
from policy appraisal and reporting activities (Jordan and Lenschow
That said, some states have undoubtedly tried harder
than others. The UK, Sweden and Norway are among the front-running
states in the comprehensiveness of their national frameworks -
i.e. a new constitutional provision in Norway, integrated policy
appraisal in the UK, and the specification of long-term integration
targets in Sweden (Jordan and Lenschow 2008). The UK has undoubtedly
been one of the most active adopters of EPI instruments in the
OECD (Jacob et al. 2008), having made use of a Cabinet
Committee on Environment and Energy, a network of Green Ministers
from across Whitehall departments meeting as a Cabinet Sub-Committee,
a Sustainable Development Strategy, the Sustainable Development
Unit in Defra, Environment-focused Public Service Agreements linked
to public spending, and a system of IA.
As a result of our work, more is now known about
the deployment of different EPI instruments, yet surprisingly
little is known about their long-term effectiveness, i.e. their
impact on sustainability "on the ground". Jacob et
al. (2008) discovered that most OECD states possess an "external
and independent review of environmental performance". But
many of them have very general mandates, are too poorly resourced
and politically weak to open up sectoral policy making to critical
scrutiny. The majority simply do not have the time or the resources
to dig into the everyday grind of policy making (Jordan and Lenschow,
2008). Even the more environmentally progressive jurisdictions,
namely Norway and Sweden, lack strong, independent and focused
scrutiny bodies (Lafferty et al., 2008; Nilsson and Persson,
2008). When our research was completed in 2007, the UK had the
most sophisticated evaluation machinery - including the work of
the SDC - amongst the 30 OECD states analysed (Russel and Jordan,
2008; Russel and Jordan, 2009).
- Why have sustainable development mechanisms
yielded little progress?
The UK's efforts at governing for sustainable development
appear to break down for a least three reasons, many of which
are common across the OECD (see above). First, there is the rather
ad hoc manner in which the instruments have been established;
too little attention has been devoted to ensuring that they interact
positively with one another. In many respects, the UK's Environment
and Energy Cabinet Committees were effectively redundant because
many potentially environmentally damaging policies were not picked
up early enough to be influenced. Improving the evidence-base
- through the use of IA - is crucial to ensure that information
is collected and shared amongst departments at a sufficiently
early stage in the policy process. Strategies for improving the
quality of IA have already been extensively covered in previous
enquiries (e.g. HC 740, session 2006-2007). Similarly, more could
have been done to link IA with the long-term departmental strategies
and targeting exercises such as the PSAs or departmental carbon
Second, the implementation of EPI has suffered from
a lack of sustained high-level support particularly from ministers
in "non" environmental ministries, central departments
(e.g. HMT and the Cabinet Office), and senior civil servants.
The inclusion of sustainability objectives in performance appraisals
was a really innovative way to hold permanent secretaries to account,
but too little is known about how seriously these were taken.
Thus it has been left to Defra to push forward the sustainable
development agenda within Whitehall, but without the power to
compel other departments to appraise policy for potential environmental
impacts (Russel and Jordan 2008). The lack of political support
is reflected by the lack of resources dedicated to EPI across
departments as previously documented by this Committee (HC 961,
Third, there is generally a lack of ex-post evaluation
work done to learn lessons and assess the effectiveness of individual
instruments. It is clear that "integration" as a whole
is not delivering as much as was originally promised, but we still
remain remarkably ignorant about precisely which instruments are
working and which are not. The UK is not alone in this respect
(see above). But at least with independent bodies such as the
Sustainable Development Commission, the Royal Commission on Environmental
Pollution, and the Environmental Audit Committee it was widely
regarded as being in a more advanced position than almost all
other OECD states.
- Our Recommendations
We conclude that:
- Until now the UK has always had a relatively
sophisticated evaluation system compared to other OECD states.
The SDC and the RCEP have played a vital role in holding the Government
to account. Without them, the UK's reputation for leadership in
this particular aspect of EPI could be in jeopardy. Unless the
Government is prepared to do a lot more to critically evaluate
its own performance - which hitherto it has been reluctant to
do - a lot more responsibility will fall on the EAC. We explore
the implications of this in more detail in the second part of
- In formulating a future architecture for sustainable
development, the new Government should look afresh at the linkages
and performance of existing instruments as many are simply not
supporting one another to mainstream sustainable development.
There is a crucial need for a system of IA that routinely accounts
for environmental and other sustainability-relevant impacts. As
currently practiced, IA tends to ignore them. There is plenty
of relevant guidance (such as that recommended by the Government
Economic Service's Review of the Economics of Sustainable Development),
but no effective system to ensure that it is followed by civil
servants beyond Defra. This thinking will need to inform the UK's
position in the run up to the Rio + 20 environmental summit to
be held in 2012.
- It is not sufficient for the Secretary of State
for Environment to provide leadership on sustainable development.
Sustained political support and resources also need to be provided
by the Prime Minister, the Cabinet and senior civil servants.
- The UK should use its influence in Brussels to
do more to connect national sustainability and EPI initiatives
to those at EU level. The UK has a great deal of positive experience
to share with other Member States. After all, sustainability and
EPI are multi-level challenges (Lenschow & Jordan,
2000). This point also needs to be taken up by whomever or whatever
takes up the SDC's and the RCEP's functions, as both have developed
effective networks with their opposite numbers in other Member
- Finally, in its forthcoming environmental White
Paper the new government should issue a clear statement explaining
how it thinks about, and wishes to advance, the relationship between
EPI and sustainability. In the academic literature these are generally
regarded as being rather different concepts with rather different
implications for the conduct of government. EPI is arguably concerned
with giving a clear and principled priority to environmental considerations,
whereas sustainability is more about finding a more even balance
between environmental, social and economic factors.
Q3. Was the SDC successful in fulfilling its
remit? Which aspects of its work have reached a natural end, or
are otherwise of less importance, and which remain of particular
Q5. How, without the assistance of the SDC,
will the Government be able to demonstrate that it is "the
greenest government ever"?
It is clear from the preceding paragraphs that a
strong, well-resourced, independent body which can hold government
to account is a vital pre-requisite for progress towards sustainable
development. In the following paragraphs we analyse the prospects
for both putting government policy onto a more sustainable path,
and evaluating government progress, in the light of the recent
decisions on the RCEP and the SDC.
5. How will policy be made more sustainable?
It is striking that in her explanation of the decision
to abolish the SDC, the Secretary of State suggested that an approach
consisting of personal leadership from her, as Secretary of State
at Defra, together with her counterpart at Energy and Climate
Change, will be capable of strengthen[ing] the Government's
performance ... and put[ting] processes in place to join up activity
across Government much more effectively than has been the
case. It suggests that such a model could actually be superior
to delegating this function to external agencies. This would seem
to imply giving more work to the Sustainable Development Unit
within Defra or sharing it out amongst a much wider array of actors.
However, there are at least four reasons why this
approach is somewhat questionable. First, powerful departments
such as the Treasury have tended to be sceptical of horizontal
environmental integration/sustainable development efforts (Russel
and Jordan 2009). As a relatively weak department, Defra needs
persuasive advocates for sustainable development that are seen
to be independent of any one departmental view. Given the enormous
effort required to bring the rest of government more into line
with sustainable development principles, it is surprising that
the Secretary of State wishes to dispense so easily with such
a valuable and world-leading asset as the SDC. Second, while the
EAC can press the case and confront departments with respect to
specific policies, its remit and limited resources prevent it
from offering the kind of detailed service that the SDC has provided.
Thirdly, international experience suggests that when a dispersed
set of actors are responsible for a complex and cross cutting
issue like EPI or sustainable development, "in practice no-one
is" (Jordan and Schout 2006: xi). This is precisely why most
OECD states have created evaluation units and agencies (see above).
Finally, both the SDC and RCEP have provided important
venues in which novel ideas could be proposed, analysed and discussed
without fear of being "politically unacceptable". While
the EAC hears evidence from many different perspectives, there
appears to be a "damping" of evidence which is deemed
to be too far from the mainstream, and thus unlikely to be even
included in the Committee report (Turnpenny et al, in preparation).
Unless changes are made, new and potentially challenging ideas
will have less "safe space" in which to develop.
- How will policy performance be evaluated?
The value of the SDC, particularly given a high profile
Chair, was that evaluation and advice was seen to be independent;
the Chair could report to the Prime Minister without fear or favour.
Although Select Committees such as the EAC are also able to scrutinise,
the SDC has often been able to probe in more detail. The danger
is that a unit within Defra would be less able to probe for relevant
evidence across Whitehall, and more likely to be caught up in
- We strongly suggest that an external scrutiny
and advisory role needs to be maintained. In the absence of the
SDC, this role could fall to a strengthened EAC, in conjunction
with a better resourced National Audit Office. Indeed, the original
model envisaged for the EAC - that its audit function should be
delivered by an enhanced and expanded NAO acting as an environmental
auditor of government with rights of access and resources for
analysis - could now be usefully revisited. In this way, the government's
performance in terms of the "greenest ever" commitment
could be monitored and evaluated with authority and transparency.
- We encourage the EAC to revitalise its cross-cutting
role as well as focusing on particular departments and/or sectoral
issues. A cross-cutting perspective can provide a distinctive
take on problems, or help challenge established "world views"
of departmental select Committees. Crucially, this type of synoptic
sustainability-related work, which has been undertaken by the
SDC and the RCEP, will be hard to replace.
- EAC must take on the advocacy role and the in-depth
study role which is left vacant by the abolition of the RCEP.
It is also important to have an advocate of SD across government
which is legitimate and credible, independent of government, and
able to advocate creative ideas.
- The EAC needs to maintain the credibility, salience
and legitimacy of the evidence it presents. We believe it should
focus on drawing in the latest evidence, rather than on hearing
the perspectives of familiar actors. The EAC must continue to
avoid any perception that it is a mouthpiece for any kind of special
- The EAC also needs to be significantly better-resourced,
specifically its secretariat and specialists, so it can in turn
support its elected members. It is unlikely that MPs will have
time to sit in more inquiries, but support for more in-depth analysis
for each inquiry (for example, help with assistants such as MEPs
have) would be welcome. Overall, a model rather similar to the
German Enquete Commissions may allow EAC to both challenge substantive
issues with in-depth analysis while retaining democratic legitimacy.
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13 October 2010