Environmental Audit CommitteeSupplementary written evidence submitted by the Department for Environment, Food and Rural Affairs

Responses to the Committee’s questions following the session with Caroline Spelman MP and Oliver Letwin MP on 11 July.

(Q.1) The NAO brief on Appraisal for the Committee noted that guidance on the Impact Assessment process was substantially revised in August 2011, and that as a result it no longer includes the requirement for ten specific “tests” on wider impacts (equality, small businesses, competition, justice, health and wellbeing, human rights, rural proofing, greenhouse gas emissions, wider environmental impacts, and sustainable development). To what extent are each of these matters now explicitly required to be addressed in impact assessments?

The Impact Assessment process was amended in August 2011. As part of this exercise, the IA Toolkit and Guidance were substantially revised with the objective of more fully integrating into the assessment process sustainable development and the other associated matters that were previously subject to the specific “tests”. The Toolkit identifies a requirement to consider impacts in each of these areas and guidance is provided on how to do so. Further guidance on how to assess these types of impact is given in the Green Book, which provides the methodological framework for appraisal and evaluation across government. Additional guidance remains available from the lead department for each subject matter.

(Q.2) How have lessons learnt from the SOGE regime, and performance outturn against SOGE targets, been used to formulate the Greening Government Commitments regime and specific GGC targets?

The key lessons learned from the SOGE regime which were used to formulate the Greening Government Commitments and targets were essentially:

The importance on focusing on high level outcomes, and leaving departments some flexibility as to how to meet them. SOGE included a range of “mandated mechanisms”. There was no clear evidence that compliance with mechanisms improved performance and sometimes departments which were performing well against target outcomes were marked down in the Sustainable Development Commission’s league table for failing to comply with mandated mechanisms, which did not help drive performance improvement. The GGC are therefore focused on outcomes rather than processes.

Clear commitments are useful in driving performance and ensuring support for operational managers tasked with achieving them.

Strong leadership and clear governance is required to drive performance so the Government has established a cabinet sub committee to oversee performance against the GGC.

Departments need advice and support on best practice but not necessarily micro management. Clarity of responsibility and ownership is also important. Hence, the arrangements for the GGC make it clear that each department is responsible for meeting each commitment.

Experience of the SOGE regime also informed consideration of the specific GGC measures that were adopted. For example, the SOGE target required a 25% reduction in water consumption by 2020 but this appeared to have been met by key large departments reducing their non-office water use. While this reduction was welcome it did not provide any transparency on whether there had been an improvement in office water efficiency. In addition, some departments have already invested in water efficient sanitation systems, so a large percentage target would have been difficult for them to meet. Consequently, it was decided to use of an FTE indicator for office water consumption only, combined with a broad target to reduce water use. This will enable more like for like comparison of performance in office water consumption which should enable identification and spread of best practice.

In respect of carbon, the success of government under the SOGE regime and the 10% target led to the conclusion that it is possible to make greater carbon reductions in the public sector. Hence, the scope of the target was widened to cover Arms Length Bodies, extending the impact of these targets.

(Q.3) During the Committee’s session with Greg Barker in July 2011 on the 10% emissions reduction target for Government departments, it discussed the case for having “relative targets” — eg. reductions per person or per square-metre. The provisional Greening Government Commitments data provided to the Committee on 11 July 2012 includes a water usage target linked to benchmarks expressed in terms of consumption per full-time equivalent. What consideration has been given to setting the other GGC targets also in “relative” terms?

This has been considered in particular in relation to carbon, but as advised by William Jordan of Cabinet Office at the Committee’s session with Greg Barker in July 2011, setting targets around carbon per FTE or carbon per square metre can have unintended consequences. So for example a carbon per square metre target discourages downsizing of the estate and rationalising use of space, as carbon use per square meter goes up with hot desking and higher occupancy rates. Adopting targets per FTE means that absolute reductions through downsizing the estate are not captured.

In view of this it was decided it is better for departments to have a simple target rather than complex targets which create other incentives and have unintended consequences.

(Q.4) How will Greening Government Commitments performance data be validated, and by whom?

The Better Regulation Executive has been commissioned to quality assure the data provided by Departments. This involves validating the accuracy of the data and exploring with Departments the reasons for major outcomes that are unanticipated or not readily explicable.

15 October 2012