House of Commons - Sustainability in the Home Office

Sustainability in the Home Office - Environmental Audit Committee Contents

2 Policy

4. Our previous reports have highlighted the importance of departments applying guidance correctly and ensuring that civil servants have the required skills.[8] A recent report for Defra on the quality of environmental appraisal, which audited appraisals in different departments including the Home Office, concluded that there were no systematic differences in the quality of impact assessments between departments. It concluded that quality of appraisal was most affected by the complexity of the policy area, and that departments might not assess all impacts adequately in more complex cases.[9] We have also heard from Duncan Russel of Exeter University who told us that another review of impact assessments identified "institutional cultures and behaviours", including a lack of time or fragmented working across Government, as factors which limited the way environmental aspects were addressed in policy appraisal.[10]

5. The Home Office follows central guidance issued by the Treasury which requires Government departments to take account of sustainable development and environmental impacts in policy-making. This includes guidance on appraisal, evaluation and reporting and an impact assessment toolkit. The Home Office has also developed its own internal guidance on how to undertake policy consultations.[11] To illustrate this, the NAO cited a January 2014 impact assessment for a proposal to ban the below-cost sale of alcohol, which considered social impacts by looking at potential effects on health and well-being and on low income households.[12]

6. The Home Office undertakes policies and programmes with a range of social and environmental impacts, and directs staff to follow guidance on considering sustainability as part of policy appraisal and impact assessment. It should ensure that sufficient time and resources, including high quality internal challenge and review, are spent on more complex cases to ensure the full range of impacts are assessed and incorporated into the design of policies.

7. In order to explore in more detail how the Home Office addresses sustainable development impacts in policy-making we examined work on the cost of crime in policing, and how the Border Force implements the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)—areas that the NAO focused on in their briefing.

The costs of crime

8. The NAO told us that the Home Office had undertaken "some innovative initiatives to embed sustainability in policy-making, such as its work to 'design out' crime and assess the carbon cost of crime".[13] The Department is developing estimates of the carbon cost of crime to ensure that its business case for investment in crime prevention recognises environmental as well as social and economic consequences. It is supporting research by the University of Surrey to further develop analysis published in 2009 by the Association of Chief Police Officers' Secured by Design initiative. The NAO suggested that such information could be used "to prioritise 'hotspots'".[14] However, Mary Calam, Director General of the Home Office's Crime and Policing Group, told the Committee that the response to reported crime is an operational judgment for the police and that she would be "surprised" if the new research "will ever take us to a place where for specific crimes you could make judgments in relation to carbon cost".[15]

9. The Home Office is also looking at ways to 'design out' crime, such as working with mobile phone manufacturers and networks to reduce theft. The NAO told us that "the department did not have an overarching strategy for designing out crime, but instead sees it as part of the wider crime prevention effort."[16] We heard from Professor Ken Pease, an expert in crime science, who told us that housing design is an area with long term consequences and that it is important that new houses are built to "standards of security that have been shown to be effective in reducing local crime".[17] He stated that the security standards proposed in the Housing Standards Review "would lead to an increase in crime, especially domestic burglary in new developments", and urged that the Home Office work with DCLG to ensure higher standards were included. Mary Calam told us that Home Office officials had been working with DCLG officials on the review of building regulations.[18] Our own inquiry on the Code for Sustainable Homes and the Housing Standards Review found that removing the existing sustainability standards would lead to poorer quality housing being built with worse energy efficiency.[19] As we stated previously, we are concerned that the Government's current de-regulatory approach on housing standards will produce less sustainable outcomes in future years. It is important that the full environmental and social costs of such decisions are analysed in policy appraisal and minimised wherever possible.

Wildlife crime

10. The Home Office makes an important contribution to sustainability through enforcing CITES regulations. The Border Force is responsible for carrying out regulatory checks on goods listed under international regulations to support the legitimate trade in endangered flora and fauna species, and for detecting and taking appropriate enforcement action over breaches of the rules. It works with HM Revenue and Customs, the National Wildlife Crime Unit (part funded by the Home Office), the National Crime Agency and the Crown Prosecution Service. The Department for Environment, Food & Rural Affairs is the UK's management authority for CITES and is ultimately responsible for issuing permits for CITES-listed imports and exports.[20]

11. In our 2012 report on Wildlife Crime, we identified the scale of the illegal trade in wildlife. In our current inquiry WWF and TRAFFIC told us that the illegal trade in wildlife remains "one of the most profitable illicit transnational activities worldwide" with an estimated value of $7.8-10 billion a year".[21] The Border Force have increased seizures of CITES-listed goods since 2008-09. Ivory seizures have increased from 2.2kg in 2009-10 to 80.7kg in 2012-13. Whilst seizures of CITES-listed goods fell in 2013-14, the Border Force considered that this was because of recent changes to the listing, which now no longer included agarwood parts and derivatives, removing these from the figures.[22]

12. In our 2012 report on Wildlife Crime, we recommended that the Government exert "robust diplomatic pressure in favour of the development and enforcement of wildlife law".[23] In February 2014 the UK Government, supported by the Home Office, hosted an international conference in London on the Illegal Wildlife Trade. WWF and TRAFFIC welcomed the "strong Declaration" that was agreed at the conference.[24] Grant Miller of the Border Force told us that whilst he had not yet been able to discern a change in the market as a result of the Conference, it had led to important new initiatives, such as "a critical communication tool for wildlife enforcers and scientists tackling the illegal wildlife trade".[25] We are pleased by the leadership that the Government has shown to promote international action against the illegal trade in wildlife, including the recent London Conference. It is important that this momentum is maintained to ensure that strong words are translated into concrete and sustained action to tackle wildlife crime.

13. WWF and TRAFFIC highlighted the importance of long-term funding for the Wildlife Crime Unit. Sarah Goddard of WWF told us that whilst she welcomed the recent commitment for two year's funding for the National Wildlife Crime Unit, which was an improvement on the previous year-on-year funding, long-term certainty over funding was needed. She wanted to see the budget inflation-linked and to continue to provide funding for an internet investigation officer.[26] The Home Office told us that it was not possible to commit funding beyond 2015-16, as no Government spending had been allocated yet for that far ahead.[27] Long-term action is needed to tackle wildlife crime, and it is important that the Government sets out a vision for the Wildlife Crime Unit with long-term funding maintained and at least increased with inflation.

14. In our previous Wildlife Crime report, we recommended that the Government review its performance on prosecuting wildlife crimes in England.[28] The Government responded that it considered that the Crown Prosecution Service (CPS) to be effective in prosecuting wildlife crime.[29] However, in this inquiry WWF and TRAFFIC told us they "still do not feel that there are sufficient penalties being handed out in all cases. It is a bit hit and miss", and recommended that the CPS should consider using specialist prosecutors and that clear sentencing guidelines should be introduced for the judiciary.[30] A report by World Animal Protection in August 2014 made a similar point:

15. The Government should keep wildlife crime sentencing under review and be ready to facilitate clear guidance for the judiciary to ensure that wildlife crime is punished with appropriately strong penalties.

16. On 14 April, Home Office Minister Norman Baker wrote to us announcing that the Home Office was introducing a separate category code within the police's 'Counting Rules' for Wildlife Crime:

Mary Calam told us that "the current changes will brigade together a number of wildlife offences that appear already in the counting rules but are scattered around. This will make for a better and much clearer picture of recorded wildlife crime."[33] She also told us that the Government had asked the Law Commission to look into the scope for reform and consolidation of offences to make them easier to track.

17. WWF and TRAFFIC welcomed the proposed coding changes, but told us that data still "is probably not sufficiently detailed and comprehensive enough and we need detailed coding in order to be able to monitor what is going on with wildlife crime in detail."[34] They believed that "despite offences under COTES [Control of Trade in Endangered Species (Enforcement) Regulations 1997] and CEMA [Customs and Excise Management Act] being recordable, at present it is not possible to obtain information on prosecutions under COTES or CEMA".[35] World Animal Protection's Wildlife Crime in the UK report concludes that the lack of data means that "it is impossible for the Government and police to analyse trends and crime rates, and accurately estimate the true scale of wildlife crime across the UK."[36] The Border Force told us that it would be the responsibility of the National Crime Agency to populate such a database, as the Wildlife Crime Unit was an intelligence Unit and no longer carried out its own prosecutions.[37] Grant Miller from the Border Force told us that responding to different stakeholders requests for data represented "quite a substantial cost" to the organisation, and he supported any efforts to develop a "smart way to report them".[38] The Home Office confirmed, however, that at present the Government had no plans to introduce such a database.[39] It highlighted that wildlife crime priorities were based on strategic and tactical assessments, including intelligence from a number of organisations, and told us that "incident data alone is not the answer".[40]

18. We welcome the steps that the Government has taken around data coding to ensure wildlife crime is a separate statistic. However, a more detailed publicly available database would provide greater transparency. Once the Government has received the Law Commission's report on modernising wildlife law, it should work with stakeholders to design a clearer and more comprehensive system of recording and reporting.

8 Environmental Audit Committee, First report of Session 2010-12, Embedding sustainable development across Government, HC 504, para 14 Back

9 EFTEC for Defra Baseline evaluation of environmental appraisal and Sustainable Development guidance across Government (March 2014) Back

10 Dr Duncan Russel et al (ESC004) Back

11 National Audit Office, Departmental Sustainability Overview: Home Office, (March 2014), para 2.2 Back

12 National Audit Office, Departmental Sustainability Overview: Home Office, (March 2014), para 2.3 Back

13 National Audit Office, Departmental Sustainability Overview: Home Office, (March 2014), para 8 Back

14 National Audit Office, Departmental Sustainability Overview: Home Office, (March 2014), para 2.11 Back

15 Q40 Back

16 National Audit Office, Departmental Sustainability Overview: Home Office, (March 2014), para 2.12 Back

17 Q2 Back

18 Q44 Back

19 Environmental Audit Committee Eighth Report of Session 2012-13, Code for Sustainable Homes and the Housing Standards Review, HC 192 Back