24 July 2006 NEW INQUIRY
24 July 2006 NEW INQUIRY
Policy Appraisal and RIAs
The Environmental Audit Committee (EAC) is today launching a short inquiry into policy appraisal and Regulatory Impact Assessments (RIAs). In April 2004 RIAs subsumed a dedicated sustainability appraisal tool - Integrated Policy Appraisal - to become the principal appraisal process for embedding sustainable development in policy making.
However, in its report of March 2005, the EAC raised the concern that: "the fundamental structure of the RIA and the associated guidance is ill-suited to the overriding need for policy makers to be able to balance environmental impacts against social and economic impacts, and to assess the extent of any trade-offs which need to be made". EAC recommended that the National Audit Office (NAO) carry out an analysis of recent RIAs to assess the extent to which they now incorporate explicit consideration of environmental and social impacts.
The National Audit Office (NAO) published the results of this review in May 2006. The NAO found that most of the RIAs they analysed did not handle sustainable development concerns well. 'Few identified all social or environmental impacts they might have been expected to cover. Social and environmental impacts were often not analysed in sufficient depth. And the variable presentation of RIAs made it difficult to see if and how sustainable development issues had been considered.' The NAO concluded that...."RIAs have a number of potential strengths as a means to inform and influence policy making, and to facilitate the consideration of sustainable development concerns in new policy...." In the absence of a viable alternative to RIAs the NAO also made recommendations to improve the current system.
As part of their wider audit role, the NAO has also conducted since 2004 a regular annual review of RIAs. The latest report in this series found that RIAs were often not used in the right way, that their purpose was not always understood, and that there was a lack of clarity in the presentation of the analysis and persistent weaknesses in assessments. As a result, in many cases RIAs have not offered a robust challenge to proposals to regulate.
The Committee now intends to follow-up on this work done by the NAO on RIAs, and it invites organisations and members of the public to submit memoranda setting out their views on this inquiry. The specific issues on which the Committee would welcome comments are set out overleaf, though respondents are free to comment on any other issues which they consider relevant.
Written evidence should be sent to the Committee in
Word format by
29 September 2006, by e-mail to
[email protected] A brief guidance note on the preparation and submission of evidence is available on the Committee's web pages. Following the submission of evidence, the Committee intend to take oral evidence from a limited number of organisations in October and to publish a report by the end of the year. For further information on this inquiry, please telephone Oliver Bennett on 020-7219-4102.
1. Should RIAs continue to be seen as the key vehicle for appraising policies against sustainable development principles, given the serious weaknesses that the National Audit Office review highlights? Is there a better way to ensure environmental, social and economic impacts are incorporated into policy-making?
2. If RIAs are seen as the best solution, what steps are being taken to address these weaknesses, including:
the weak link between the structure of RIAs (and accompanying guidance) and the principles and priorities set out in the UK's Sustainable Development Strategy;
the difficulty of ensuring that environmental and social impacts which are difficult to quantify in monetary terms are fully taken into account;
the variable quality of presentation of RIAs, which can inhibit their ability to allow trade-offs between environmental, social and economic impacts to be readily assessed; and
poor co-ordination with other policy appraisal processes, such as European Impact Assessments and Strategic Environmental Assessments.
In each case, will the steps taken be enough to resolve the problem?
3. Does the formal role of Better Regulation Units within departments take adequate account of sustainable development objectives? How can training and guidance to officials be improved?
4. How can the Better Regulation Executive improve its scrutiny of RIAs to ensure that sustainable development issues are adequately incorporated into each appraisal?
5. What evidence is there that RIAs make a difference to policy outcomes? Can departments document examples where the appraisal process has resulted in a change in the preferred policy option to one which is more sustainable?
6. Is the application of the RIA process sufficiently comprehensive? Should it be extended to cover areas such as the Pre-Budget Report and the Comprehensive Spending Review? If not, what other processes are there to ensure that there is transparency and accountability over the consideration of sustainable development issues at the very earliest stages of decision making. Are these processes adequate?
7. More generally, are there sufficient mechanisms across government for ensuring that sustainable development is fully incorporated into policy making in order to deliver the Sustainable Development Strategy?
Notes for Editors
1. The EAC's seventh report of 2004-05, Pre Budget 2004 and Budget 2004: Tax, Appraisal and the Environment, HC 261 raised a number of concerns about the adequacy of current approaches to environmental appraisal. It is available, along with other Committee reports, from the EAC website:
2. The NAO briefing, Regulatory Impact Assessments and Sustainable Development, was published on 22 May 2006, and is available at
www.nao.org.uk/publications/nao_reports/05-06/ria_sustainable.pdf and on the EAC website given above.
The Environmental Audit Committee
Under the terms of the Standing Order No. 152A the Environmental Audit Committee is to Aconsider to what extent the policies and programmes of government departments and non-departmental public bodies contribute to environmental protection and sustainable development: to audit their performance against such targets as may be set for them by Her Majesty's Ministers; and to report thereon to the House. The Committee was set up on 14 July 2005.