3 Policy making
11. Under the Government's plans for embedding sustainable
development in policy-making, it has sought to utilise the new
business planning system for setting objectives and monitoring
progress. The Government's February 2011 Vision document
described the use of that system for reviewing departments' adherence
to sustainable development principles. Defra would provide analysis
of the Plans for the Minister for Government Policy and the Chief
Secretary of the Treasury, who would then hold departments to
account through quarterly review meetings with the relevant departmental
ministers.[29]
12. The first set of business plans was completed
in November 2010, and have been 'refreshed' annually to reflect
evolving Government priorities. Each is required to cover the
vision of the department, planned actions and deadlines, departmental
expenditure data and information on the department's actions to
increase transparency.[30]
An annex to each Plan covers the department's overall goal on
sustainable development; its plans to assess and manage environmental,
social and economic impacts; how the department will implement
its Greening Government Commitment targets and its headline Sustainable
Development Indicators.[31]
13. In our June 2013 report we concluded:
The Business Plan review process has a significant
weakness in that it does not seek to address potential policy
gaps, where new initiatives could tackle unsustainable development.
The reviews examine the policies that are added to the Plans after
being negotiated within Government, rather than policies that
should be generated as a result of applying sustainable development
thinking from the outset. For the policies that the process does
review, the system remains opaque to external scrutiny, but presents
an important opportunity for the Cabinet Office, with Defra support,
to focus departments' attention on the sustainability of their
policies.[32]
For policies that do come forward and are examined,
we concluded that the key test of the system's effectiveness would
be the extent to which policies were adjusted and improved while
in development.[33]
14. Making policy-making sustainable also requires
effective policy appraisal and officials having the skills and
training to apply those disciplines. We noted in June 2013 that
guidance for departments on policy appraisal and impact assessments
had been improved to reflect the need to address sustainable development,
and civil servants' skills requirements were being strengthened
in these disciplines. Defra, we concluded, needed to use the results
of an audit of impact assessments to develop the guidance further,
and Defra and the Cabinet Office must challenge departments' non-compliance
as part of the Business Plan reviews.[34]
Since our report, the Government has begun to examine the results
of the audit and the need for any improvement in the policy appraisal
guidance or in "capability building".[35]
15. Against that background of Government-wide developments,
the NAO examined the position in BIS. The NAO's briefing included
an analysis of the potential impacts of BIS policies and examples
of the range of initiatives within the Department which are intended
to promote its principal aim of facilitating sustainable economic
growth.[36] The NAO concluded
that BIS could do more to assess the range of impacts associated
with its activities on a systematic basis, identify priority areas
for embedding sustainability, and consider the potential for mitigating
potential negative impacts.[37]
The NAO noted that while it was carrying out its audit, on our
behalf, BIS had started to undertake an assessment of its objectives
and policies to identify priorities for embedding sustainable
development, and areas where potentially unsustainable impacts
in might be mitigated.[38]
All departments should examine the NAO's analysis of policies
in BIS, to produce a similar analysis in their own departments
in order to identify potentially unsustainable policies and to
provide a baseline for reviewing and adjusting those policies.
16. The lesson for BIS is that increased economic
growth (an aim underpinning much of its policies) can have both
potentially good (eg. increased employment or social cohesion)
and bad (e.g. emissions) sustainability consequences, and that
policy-making needs explicitly to recognise and address those
tensions. The NAO examined such issues in the policy appraisal
of three case examplesthe Regional Growth Fund, higher
education funding reform (including student fees changes), and
the Government's Industrial Strategywhich we discuss below.
Regional Growth Fund
17. In its June 2010 Budget, the Government announced
plans for a Regional Growth Fund "to support increases in
business employment and growth".[39]
It was part of a package of measures which also involved the abolition
of the Regional Development Agencies and the creation of Local
Enterprise Partnerships.[40]
The Regional Growth Fund is open to businesses seeking to create
jobs in areas vulnerable to public sector job losses. The Fund's
specific objectives are
"to encourage private
sector enterprise by providing support for projects with significant
potential for economic growth and create additional sustainable
private sector employment; and to support in particular those
areas and communities that are currently dependent on the public
sector make the transition to sustainable private sector led growth
and prosperity".[41]
An NAO report on the Regional Growth Fund in 2011 found that applications
for grants were scored according to the relative vulnerability
of the location to public sector job losses by measuring local
unemployment, the local share of public sector employment, the
extent of private sector jobs growth and the number of active
enterprises.[42]
18. There have now been four rounds of bidding for
Regional Growth Fund grants (fourth round winners were announced
in August 2013), and a fifth round was announced in October 2013.[43]
The NAO assessed the first two rounds in May 2012 and calculated
that the scheme at that point had secured 41,000 jobs at a cost
of £33,000 eachbroadly similar, the NAO found, to
previous regional development policies.[44]
The impact assessment for the scheme identified a quantifiable
gross benefit of £5.7 billion,[45]
or £4.3 billion net of the costs of the Regional Growth Fund
outlays.[46] (The overall
package of measures, including the abolition of the Regional
Development Agencies and the creation of Local Enterprise Partnerships,
had a net cost.[47])
19. The NAO's recent briefing concluded, however,
that other than the 'social' benefit derived from greater employment
levels, only the economic pillar of sustainable development was
considered in the policy impact assessment. No assessment was
made of the impact of the scheme in terms of furthering a green
economya major policy priority in the BIS Business Plan.[48]
BIS told us that when the Regional Growth Fund policy was first
developed there was "discussion across Government" to
set its objectives, and that sustainability was not "specifically
one of the criteria" but rather a "specific footnote"
that "economic growth should be underpinned by environmentally
sound principles".[49]
20. The Regional Growth Fund budget was originally
split between Defra, BIS and DCLG.[50]
We asked BIS, who now manage the budget, about the extent to which
the environmental or social pillars of sustainable development
were considered in awarding Regional Growth Fund grants. They
told us that they monetised such factors where that was possible
from the information provided in the grant application form, and
passed that assessment to the advisory panel deciding on the grants.[51]
However, the application form for the scheme includes a section
which asks about potential "social or economic benefits",
seeking information specifically on "benefits to the
environment, improvements to transport networks and journey times
[or] scientific advances" (our emphasis), rather than disbenefits.[52]
Another section asks about equality impacts in terms of sex, race,
disability, and sexual orientation, but not also for income or
wealth inequalities.[53]
BIS told us that "the application form is designed to be
light touch and is therefore deliberately concise".[54]
21. While Regional
Growth Fund processes seek to measure and assess environmental
or social benefits, BIS did little to establish or quantify whether
there are disbenefits that might understandably be absent from
completed application forms. BIS should revise its Regional
Growth Fund assessment process to incorporate potential environmental
and social costs and disbenefits, and weigh these fully in considering
applications for grants. Defra and the Cabinet Office should challenge
other government departments to ensure that on any similar grant
allocation policies they collect information on all pillars of
sustainable development and fully take it into account.
Higher education funding reform
22. The NAO also examined higher education funding
reform, involving the raising of student tuition fees to partially
offset a reduction in BIS grants to universities. We examined
the sustainable development aspects of this initiative in terms
of its inter-generational equity, including the extent to which
such factors were taken into account in developing the policy.
The NAO's briefing explained that BIS did assess the question
of inter-generational transfer of debt associated with the higher
tuition fees:
Departmental analysts considered this issue but came
to the conclusion that individuals should not be adversely affected
by the potential liabilities involved. This was based on the fact
that repayments are dependent on income, and on the Department's
view that such debts will not count towards credit ratings. The
latter was based on information from the Association of Mortgage
Lenders which indicated that student debt does not affect their
ability to get mortgages.[55]
23. However, the obligation to repay student loans
did reduce the size of any mortgage available.[56]
The impact assessment for the policy took account of the 'graduate
premium'the £100,000 additional lifetime income for
graduates[57]and
BIS highlighted that the fees were still less than the cost and
that overall the Department would not get back the 'full value'
of the loans made.[58]
BIS, nevertheless, are planning to reassess the sustainability
of the higher education funding reforms next year.[59]
Industrial Strategies
24. The Government has published 'Industrial Strategies'
for 11 sectors, including several with particular environmental
sensitivity: for offshore wind[60],
oil & gas[61], nuclear[62],
aerospace[63], automotive[64]
and construction.[65]
The NAO told us that the Government had not published a business
case or impact assessment setting out the potential benefits and
costs of the initiative overall, or for the individual sector
strategies, "nor is there any overarching commitment to ensure
that the industrial strategy promotes green growth".[66]
The Secretary of State set out the logic for having such Industrial
Strategies, however, in a speech in September 2012 where he said:
There are two basic propositions. The first is that
it necessary to plan for the long term. The second is that the
government can and must work together to deal with genuine market
failures, where the benefits of education or the costs of environmental
damage for example are underestimated by markets.
... [there will be] strategic deals with business
and a cast-iron commitment, right across Whitehall, to identifying
and dismantling the barriers to growth.[67]
25. BIS highlighted examples of how environmental
or social aspects featured in particular Industrial Strategies,
for example the need for more fuel efficient vehicles in the Automotive
Strategy, and jobs and affordable housing in the Construction
Strategy.[68] We note,
nevertheless, that each of the Strategies for nuclear, oil &
gas, and offshore wind focus on how those individual sectors might
be supported without addressing the optimal mix of energy types
for sustainable development. The various strategies envisage maximising
the output of UK industry in their particular sector, with for
example the Oil & Gas Strategy aiming to maximise output from
the North Sea,[69] and
the Aerospace Strategy maximising UK aircraft manufacturing. When
they are taken together as a whole, the approach of individual
Industrial Strategies, which simply seek to maximise industrial
output, has environmental consequences which are inadequately
considered. BIS
should review its Industrial Strategies to ensure that they represent
a sustainable development approach across the 11 sectors as a
whole. If necessary, it should redraft and reissue them to demonstrate
where and how the Government has made any trade-offs between economic
growth and climate change mitigation.
26. The NAO told us that the BIS Business Plan cited
no actions on the transition to a low-carbon economy apart from
the Green Investment Bank and the compensation scheme for the
energy costs of energy intensive industries.[70]
Similarly, BIS's August 2011 Enabling the Transition to a Green
Economy, which we discussed in our 2012 report on the Green
Economy,[71] contains
only one commitment for BIS, relating again to the establishment
of the Green Investment Bank.[72]
27. The Industrial
Strategies appear to be disconnected from the BIS Business Plan
process, weakening the main vehicle by which Defra and the Cabinet
Office challenge the sustainability-proofing of BIS policy-making.
BIS should review its
Business Plan, to identify and reflect action commitments contained
in the various Industrial Strategies.
29 Embedding Sustainable Development: An Update, HC 202, op cit Back
30
ibid Back
31
ibid Back
32
ibid Back
33
ibid Back
34
ibid Back
35
Fourth Special report, HC 633, op cit Back
36
Departmental Sustainability Overview: Business, Innovation and Skills , op cit, Figure 7 Back
37
ibid Back
38
Departmental Sustainability Overview: Business, Innovation and Skills , op cit, para 2.3 Back
39
HM Treasury, Budget 2010, HC 61, p3 Back
40
Departmental Sustainability Overview: Business, Innovation and Skills , op cit, para 2.7 Back
41
BIS, Consultation on the Regional Growth Fund (July 2010) Back
42
NAO, The Regional Growth Fund, Session 2012-13, HC 17, para 2.11 Back
43
HC Deb 14 October 2013, col 38WS Back
44
The Regional Growth Fund, HC 17, op cit Back
45
BIS, Abolition of the Regional Development Agency: Impact assessment (November 2011) Back
46
Departmental Sustainability Overview: Business, Innovation and Skills , op cit, Figure 8 Back
47
BIS, Abolition of the Regional Development Agency: Impact assessment (November 2011), pp 25-26 Back
48
Departmental Sustainability Overview: Business, Innovation and Skills , op cit, para 2.9 and Figure 8 Back
49
Q49 Back
50
The Regional Growth Fund, HC 17, op cit, Figure 3 Back
51
Qq47, Back
52
Qq51-67 Back
53
BIS (BIS 003) Back
54
ibid Back
55
Departmental Sustainability Overview: Business, Innovation and Skills , op cit, para 2.13 Back
56
Q74 Back
57
BIS, Impact assessment: Higher education: Students at the Heart of the system (June 2011) Back
58
Q72 Back
59
Q75 Back
60
Government, Offshore Wind Industrial Strategy (August 2013) Back
61
Government, UK Oil and Gas: Business and Government Action (March 2013) Back
62
Government, The UK’s Nuclear Future Back
63
Government, Lifting off: Implementing the Strategic Vision for UK Aerospace Back
64
Government, Driving success: A strategy for growth and sustainability in the UK automotive sector (July 2013) Back
65
Government, Construction 2025 (July 2013) Back
66
Departmental Sustainability Overview: Business, Innovation and Skills , op cit, para 2.15 Back
67
https://www.gov.uk/government/speeches/industrial-strategy-cable-outlines-vision-for-future-of-british-industry
Back
68
Q77 Back
69
UK Oil and Gas: Business and Government Action (March 2013), op cit, p 2 Back
70
Departmental Sustainability Overview: Business, Innovation and Skills , op cit, para 1.8 and Figure 4 Back
71
Environmental Audit Committee, Twelfth report of Session 2010–12, A Green Economy, HC 1025 Back
72
Departmental Sustainability Overview: Business, Innovation and Skills , op cit, para 1.9 Back
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