Embedding sustainable development across Government, after the Secretary of State's announcement on the future of the Sustainable Development Commission - Environmental Audit Committee Contents

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 itself.


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 accountable?

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 Procurement)?

  1. 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.

  1. 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 2010).

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).

  1. 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 reduction targets.

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, session 2002-2003).

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.

  1. Our Recommendations

We conclude that:

  1. 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 our submission.
  2. 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.
  3. 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.
  4. 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 States.
  5. 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 continuing importance?

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.

  1. 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 inter-departmental politics.

  1. Recommendations
    1. 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.
    2. 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.
    3. 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.
    4. 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 interest group.
    5. 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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Jordan A. Lenschow A. 2008. Integrating the environment for sustainable development: an introduction. In Innovation in Environmental Policy? - Integrating the Environment for Sustainability Jordan A. Lenschow A. (eds.) Edward Elgar, Cheltenham, 3-23.

Jordan, A.J. Lenschow A. 2010. Environmental Policy Integration: A State of the Art Review. Environmental Policy and Governance, 20, 3, 147-158.

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Schout, A. Jordan A.J. 2008 Administrative Instruments, In Innovation in Environmental Policy? - Integrating the Environment for Sustainability Jordan A. Lenschow A. (eds.) Edward Elgar, Cheltenham, pp 49-69.

Turnpenny J.R. Russel D.J. Rayner T.J. (in preparation) Institutionalising evidence-based policy-making? The UK Parliamentary Environmental Audit Committee and the Drawing of Boundaries. In preparation for the Transactions of the Institute of British Geographers.

WCED (World Commission on Environment and Development) 1987. Our Common Future. Oxford University Press: Oxford.

13 October 2010

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