Regulatory Impact Assessments and Sustainable Development

Transcription

1 Regulatory Impact Assessmets ad Sustaiable Developmet BRIEFING FOR THE ENVIRONMENTAL AUDIT COMMITTEE 22 MAY 2006

2 This review was udertake by: Elea Bafield, Sarah Billiald, Laura Helm, Katy Losse, Simo Reaso, Peter Walker ad Athoy Weaver uder the directio of Joe Cavaagh. This review ca be foud o the Natioal Audit Office web site at The Natioal Audit Office scrutiises public spedig o behalf of Parliamet. The Comptroller ad Auditor Geeral, Sir Joh Bour, is a Officer of the House of Commos. He is the head of the Natioal Audit Office, which employs some 800 staff. He, ad the Natioal Audit Office, are totally idepedet of Govermet. He certifies the accouts of all Govermet departmets ad a wide rage of other public sector bodies; ad he has statutory authority to report to Parliamet o the ecoomy, efficiecy ad effectiveess with which departmets ad other bodies have used their resources. Our work saves the taxpayer millios of pouds every year. At least 8 for every 1 spet ruig the Office. For further iformatio about the Natioal Audit Office please cotact: Natioal Audit Office Press Office Buckigham Palace Road Victoria Lodo SW1W 9SP Tel: [email protected] Natioal Audit Office 2006

3 Regulatory Impact Assessmets ad Sustaiable Developmet CONTENTS Summary 2 Mai Report: Sustaiable Developmet i Regulatory 4 Impact Assessmets Itroductio 4 RIAs have potetial stregths as a appraisal tool 4 RIAs also have limitatios 7 Sustaiable developmet was ot well hadled i most of the RIAs 8 we examied There are steps which could improve the way sustaiable 13 developmet is cosidered i RIAs Appedices 1 Regulatory Impact Assessmets i our sample 15 2 Survey of departmetal regulatio teams 18 Briefig for the Evirometal Audit Committee

4 summary 1 The House of Commos Evirometal Audit Committee (EAC) recommeded that the Natioal Audit Office (NAO) carry out a aalysis of recet Regulatory Impact Assessmets (RIAs) to assess the extet to which they reflect a ew requiremet to cosider evirometal ad social impacts. This briefig respods to the Committee s request. 2 Sice their itroductio i 1997, primarily as a tool for assessig ecoomic impacts o busiess, RIAs have developed to provide a framework for aalysig the likely impacts of a policy chage ad the rage of optios for implemetig it. They are required for ay form of regulatio, such as formal legislatio, codes of practice or iformatio campaigs, which has ay impact, whether it be social, evirometal or ecoomic, o busiess, the public sector or the volutary sector. 3 The UK Sustaiable Developmet Strategy highlights the role that RIAs ca play i appraisig policies agaist sustaiable developmet priciples. 1 Betwee April 2004 ad April 2005 some 200 RIAs were produced by govermet departmets; this review is based o a sample of 10 RIAs that related to policies with likely sigificat social ad evirometal impacts. 4 RIAs have some potetial stregths as a meas to iform ad ifluece policy makig, ad to facilitate the cosideratio of sustaiable developmet cocers i ew policy. The RIA process is ow well established i Whitehall ad is iteded to cover all major policy developmet; there is a etwork of specialists i the Cabiet Office ad departmets to support ad eforce good practice; departmetal compliace with requiremets is high; the process ca ifluece policy at all stages from iitial idea through to implemetatio; the process is trasparet, beig i the public domai at key stages; ad fially, good policy makig ad sustaiable developmet share some commo priciples. 5 But RIAs also suffer from some limitatios. Some RIAs deal oly with certai aspects of a policy, which ihibits their potetial to assess sustaiable developmet cocers. Ad too ofte RIAs are used to justify decisios already made rather tha a ex ate appraisal of policy impacts. If RIAs are to fulfil their role to iform ad challege policy-makig, they should be started early i the decisio-makig process, ad ivolve wide-ragig cosultatio with key stakeholders, icludig other govermet departmets where appropriate. 1 I this briefig we take our uderstadig of sustaiable developmet from the Govermet s 1999 ad 2005 Sustaiable Developmet Strategies i.e. to iclude ecoomic, evirometal ad social issues, as well as cross-cuttig priciples such as takig a log-term perspective. Briefig for the Evirometal Audit Committee

5 Regulatory Impact Assessmets ad Sustaiable Developmet 6 Our review of 10 recet RIAs foud that most did ot hadle sustaiable developmet cocers well. Few idetified all social or evirometal impacts that they might have bee expected to cover. Social ad evirometal impacts were ofte ot aalysed i sufficiet depth. Ad the variable presetatio of RIAs made it difficult to see if ad how sustaiable developmet issues had bee cosidered. There is a learig curve i ay process ad the NAO, i its broader work o RIAs 2, has foud that departmetal practice has improved over time. Our sample was draw from RIAs published i the year after the requiremet to explicitly cosider evirometal ad social impacts was itroduced, so for some it was early days. If departmets icrease their capacity ad expertise, we might expect the cosideratio of sustaiable developmet issues to improve. 7 A importat questio, however, is whether to persist with RIAs as the key vehicle for icorporatig sustaiable developmet ito policy makig. O the oe had, sustaiable developmet may be difficult to icorporate i a process domiated by ecoomic ad quatifiable impacts. O the other had, it is early days ad practice may improve, ad it has to be asked if there is a alterative or better way of itegratig the ecoomic, social ad evirometal impacts ito policy makig. I the absece of a viable alterative to RIAs, we have cocetrated o recommedatios to improve the curret system. 8 There is more that ca be doe to improve the way sustaiable developmet is dealt with i RIAs. Better guidace ad traiig would help. The Cabiet Office could stregthe its scrutiy of sustaiable developmet. A more cosistet style ad stadard of presetatio would also demostrate that sustaiable developmet issues have bee addressed ad take ito accout. 2 Evaluatio of Regulatory Impact Assessmets Compedium Report (HC 358) ad (HC 341). Briefig for the Evirometal Audit Committee

6 MAIN report Sustaiable Developmet i Regulatory Impact Assessmets Itroductio 1.1 The House of Commos Evirometal Audit Committee (EAC) has a logstadig iterest i how sustaiable developmet is icorporated ito the policy makig process. I April 2004 Regulatory Impact Assessmets (RIAs) subsumed a dedicated sustaiability appraisal tool Itegrated Policy Appraisal to become the pricipal appraisal process for sustaiable developmet i policy-makig. I its seveth report of 2005, however, the Committee expressed cocer that the fudametal structure of RIAs 3 ad associated guidace was ill suited to the overridig eed for policy makers to be able to balace evirometal impacts agaist social ad ecoomic impacts ad to assess the extet of ay trade offs which eed to be made. EAC recommeded that the Natioal Audit Office (NAO) carry out a aalysis of recet RIAs to assess how they have respoded to the chage i procedures requirig explicit cosideratio of evirometal ad social impacts. This briefig respods to the Committee s request. 1.2 Our review was based o a sample of 10 RIAs published sice the guidace chaged i April 2004, chose o the basis that they relate to policies with likely evirometal ad social impacts (see Figure 1). 4 We assessed this sample agaist Better Regulatio Executive guidace o RIA developmet. We ivited a expert pael to assess each RIA agaist the sustaiable developmet issues they would have expected to feature i them. We also surveyed the RIA team i each departmet producig RIAs, about the arragemets i place ad their views of the process. 1.3 This work o sustaiable developmet i RIAs complemets the NAO s mai programme of work o RIAs; i December 2002 the Cabiet Secretary ivited the Comptroller ad Auditor Geeral, the head of the NAO, to udertake a aual evaluatio of a sample of RIAs. 5 The first report was published i March 2004 ad this is ow a aual publicatio. 1.4 At the time of writig, the Better Regulatio Executive is reviewig the future of RIAs, ad cosiderig optios for improvig their usefuless i policy makig. The results of our aalysis, ad the Committee s cosideratio of it, should cotribute to that review. RIAs have potetial stregths as a appraisal tool They are well established i govermet 1.5 Sice their itroductio i 1997, primarily as a tool for assessig ecoomic impacts o busiess, RIAs have developed to provide a framework for aalysis of the likely impacts of a policy chage ad the rage of optios for implemetig it. I the process the scope of the RIA has expaded; it is ow desiged to evaluate the full rage of ecoomic, evirometal ad social costs ad beefits of a policy proposal. This icludes for example, a assessmet of the impacts o small busiesses ad competitio, as well as icorporatig tests such as Health Impact Assessmet ad Rural Proofig (see Figure 2 o page 6). RIAs are required for ay form of regulatio, such as formal legislatio, codes of practice or iformatio campaigs, which has ay impact, whether it be social, evirometal or ecoomic, o busiess, the public sector or the volutary sector. 3 EAC Seveth Report (13 April 2005) Pre-Budget 2004 ad Budget 2005: Tax, Appraisal, ad the Eviromet. 4 Our sample icludes RIAs from the followig departmets: Departmet of Eviromet, Food ad Rural Affairs (DEFRA); Departmet for Trasport (DfT); Departmet of Trade ad Idustry (DTI); Office of the Deputy Prime Miister; Departmet of Health. 5 Evaluatio of Regulatory Impact Assessmets Compedium Report (HC 358) ad (HC 341). Briefig for the Evirometal Audit Committee

7 Regulatory Impact Assessmets ad Sustaiable Developmet 1 RIAs covered by our examiatio Biofuels Labellig Departmet for Trasport (DfT) Busiess Improvemet Districts Office of the Deputy Prime Miister (ODPM) 1 Crossrail DfT The Electricity ad Gas Eergy Efficiecy Obligatios (EEO) Order 2004 Departmet for Eviromet Food ad Rural Affairs (DEFRA) Reewables Obligatio Order 2005 Departmet of Trade ad Idustry (DTI) Water Fluoridatio Departmet of Health Work ad Families DTI Evirometal Impact Assessmet DEFRA Food Idustry Sustaiability Strategy DEFRA Lorry Road User charge DfT, HM Treasury ad HM Reveue ad Customs This RIA addressed a policy to comply with a particular article of the Europea Directive o the labellig of biofuels This RIA accompaied a Statutory Istrumet which prescribes the detailed arragemets for settig up ad maitaiig a Busiess Improvemet District i a area. The RIA assesses the eed for primary legislatio to implemet Crossrail, a ew railway coectig existig track to the west ad east of Lodo. This RIA describes a proposal to set targets for electricity ad gas suppliers to icrease domestic eergy efficiecy i order to alleviate fuel poverty ad reduce carbo dioxide emissios. This RIA assesses the impact of proposed chages to the Reewables Obligatio Order, icludig measures to make it fuctio more effectively, allowig for tradability of certificates issued uder the Reewables Obligatio with those issued uder the Norther Irelad Reewables Obligatio, ad extedig the levels of the Reewables Obligatio beyod 2010 to This RIA accompaies a statutory istrumet to outlie the level of cosultatio required by a Strategic Health Authority before it compels a water supplier to add fluoride to the water supply, ad give idemities to water udertakers ad water suppliers. This RIA accompaies the Work ad Families Bill, which itroduces a package of measures desiged to give childre the best start i life. The measure we cosidered is to exted the period of statutory materity ad adoptio paymets from 26 to 39 weeks. This RIA accompaies a Statutory Istrumet trasposig two requiremets of the EU Evirometal Impact Assessmet Directive, ad was at partial RIA stage at the time of our review. This itroduces ew rules o restructurig of rural lad holdigs, ad a proposal is to itroduce thresholds before evirometal assessmets are ecessary. This partial RIA 2 assesses a proposal to itroduce a volutary sustaiability strategy for the whole of the food ad drik idustry. This would cover all aspects of food processig ad retail oce food leaves the farm o which it is grow. This partial RIA accompaies a proposal to itroduce charges to foreig lorry operators usig British roads. Source: Natioal Audit Office NOTE 1 I May 2006, the Departmet for Commuities ad Local Govermet (DCLG) replaced ODPM. 2 At the time of writig this review, DEFRA had ot published the fial RIA o this proposal. Briefig for the Evirometal Audit Committee

8 Regulatory Impact Assessmets ad Sustaiable Developmet 1.6 The RIA process is supported by a etwork of regulatio specialists withi govermet. 2 The Scope of RIAs BRE guidace suggests that a fial RIA should set out: the purpose ad iteded effect of the policy proposal; a rage of optios for achievig the policy objective (icludig a do-othig optio); idetify who is affected, icludig the busiess sectors ad groups o which there may be a disproportioate impact; compare the beefits ad costs for each optio cosidered i the partial RIA; cosider ad record separately the other costs ad beefits: ot just those to the public sector, firms, charities ad the volutary sector but also to cosumers/idividuals ad to the ecoomy at large, takig accout of the ecoomic, social ad evirometal effects; the results of cosultatio; the impact o small firms ad competitio; ad arragemets for: eforcemet, sactios ad moitorig of the policy; a implemetatio ad delivery pla; ad postimplemetatio review. Source: Better Regulatio Executive The Better Regulatio Executive (BRE), part of the Cabiet Office, is resposible for the RIA process across Whitehall. BRE provides guidace to departmets, moitors departmetal compliace with RIA requiremets, is available for cosultatio o matters of RIA practice, ad gets ivolved i ay RIAs judged to be sigificat i terms of established criteria. Withi each departmet, a Better Regulatio Uit (BRU) co-ordiates RIAs, provides guidace ad assistace to teams ivolved i regulatio, ad is resposible for liaiso with BRE. 1.7 Departmetal compliace with the requiremet to produce a RIA for all sigificat legislative chages is very high. BRE s regular exercises to establish departmetal compliace with RIA requiremets have foud that the rate of compliace is cosistetly over 90 per cet with 100 per cet compliace i November 2004 ad Jue RIAs should be prepared for most policy developmet 1.8 BRE guidace advises that RIAs should be produced for ay policy proposal that has a impact o busiess, charities or the volutary sector, ad that a iitial RIA should form part of ay policy proposal to Miisters. RIAs would ot ormally be expected to accompay high level, strategic papers which outlie the geeral directio ad itet of a policy, but would be expected if these proposals were supported or complemeted with proposed actios or measures that will lead to impacts o busiess, charities or the volutary sector. Virtually all White Paper policy statemets ad Gree Paper cosultatios fall ito this latter category. Therefore, despite their ame, RIAs are udertake for govermet itervetios beyod regulatio, such as ew fiscal measures ad legislative arragemets for market mechaisms. 1.9 RIAs are primarily cocered with domestic UK policy chages. Foreig policy ad aid decisios are ot usually subject to the RIA system; the Departmet for Iteratioal Developmet produces very few RIAs. RIAs are ot prepared for lower-level policy makig ad implemetatio. For example RIAs are ot required for local govermet plas ad programmes, which are more likely to be captured by Strategic Evirometal Assessmet. Direct expediture o idividual projects such as road buildig ad flood maagemet, are covered by Evirometal Impact Assessmet regulatios rather tha RIAs. RIAs ca ifluece at several stages i the policy-makig process 1.10 Figure 3 shows how the RIA process ivolves four stages, providig opportuities to both ifluece ad documet policy-makig at key poits i the policy developmet process. Thus, i theory, the RIA process provides a ideal way to esure that sustaiable developmet cosideratios are take ito accout i policy makig. The RIA process is also trasparet: the partial ad fial RIAs are i the public domai, for all to see, whilst the fial RIA also provides a meas to demostrate to Parliamet that proper procedures have bee followed. Briefig for the Evirometal Audit Committee

9 Regulatory Impact Assessmets ad Sustaiable Developmet The RIA process ad sustaiable developmet share some importat priciples 1.11 RIAs cosider ecoomic, evirometal ad social costs ad beefits, whereas other ex ate appraisal tools such as Strategic Evirometal Assessmet 6 ad Evirometal Impact Assessmet 7 ted to focus predomiatly o evirometal issues. RIAs therefore have the potetial to play a importat role i ecouragig itegrated decisio makig, which is a key feature of sustaiability If RIAs are carried out accordig to BRE s guidace to departmets, they will icorporate may of the priciples i the govermet s 2000 ad 2005 Sustaiable Developmet Strategies. For example, three importat priciples i both strategies have bee: 3 The four stages of RIAs Iitial RIA: This forms part of the submissios seekig Miisterial agreemet to a proposal. It should be udertake at the outset of a ew policy ad may ivolve iitial discussios with stakeholders though it is ot likely to have much detail. Partial RIA: This builds o the Iitial RIA through research ad discussios with affected stakeholders. It must accompay the formal public cosultatio for proposals. It should set out the alterative ways of meetig the policy objective, based o a cosideratio of optios. Full RIA: The Departmet draws o the results of the cosultatio process ad further research to produce the full RIA. It should iclude a departmet s estimates of the problem, beefits, costs ad ucertaities. It is submitted to the relevat Miister who is required to sig it to state that the beefits of the proposal(s) justify the costs. Fial RIA: The documet siged by the Miister is kow as the Fial RIA. This is submitted to Parliamet if it accompaies a Bill or Statutory Istrumet. The timetable for this process varies sigificatly from case to case; the Cabiet Office requires a miimum 12 week cosultatio period, but there is o upper limit. Source: Natioal Audit Office takig accout of all costs ad beefits; evidece based-policy makig; ad stakeholder cosultatio. RIAs also have limitatios Some RIAs are scoped i ways which preclude or ihibit discussio of sustaiable developmet cocers 1.13 Some of the RIAs i our sample had a arrow scope or defiitio, sometimes dealig with a techical detail rather tha the substace of a ew policy. As a result, there was little or o discussio or cross-referece to the wider evirometal ad social impacts of the ew policy. Examples are show i Figure 4 overleaf. While it is good practice for RIAs to be clear, cocise ad specific (ad hece we assessed RIAs i our sample oly o the basis of social ad evirometal issues relevat to their give scope), if each RIA oly deals with small aspects of a policy there is risk that the fudametal issues of a policy are ever fully addressed. If RIAs are to fulfil their role of providig trasparecy ad a full evidece base to the Miisters, RIAs with a limited scope should lik to, ad ideally summarise, ay broader impact assessmets to provide reassurace that the wider social ad evirometal impacts of the policy are appraised elsewhere. Oe way to achieve this is for a arrow RIA to refer to a framework RIA i which these wider matters are addressed. Full cosultatio with the public ad other govermet departmets ca also help to highlight where there are wider issues for cosideratio; there is also the potetial for other govermet departmets to play a role i scrutiisig RIAs o this basis. RIAs are too ofte used to justify rather tha appraise ad iform policy 1.14 Our previous reports 8 o RIAs across govermet have show a eed to improve the way RIAs are used to appraise the itroductio of regulatory proposals. We have highlighted that RIAs are ot always itegrated fully ito the policy-makig process ad so are uable to fulfil their potetial to iform ad challege policy makig. RIAs may be started late i the policy makig process ad therefore have oly limited relevace to the outcome of policy, though evertheless serve as a importat commuicatio tool. Others have o impact o policy makig ad are produced merely because there is a obligatio o departmets to do so. The BRE guidace makes it clear that a good RIA should icorporate these priciples. 6 Required by a EU directive for plas ad programmes, such as local trasport plas ad regioal waste strategies. 7 Required uder plaig legislatio for developmet or costructio projects with sigificat evirometal effects. 8 Evaluatio of Regulatory Impact Assessmets Compedium Report (HC 358) ad (HC 341). Briefig for the Evirometal Audit Committee

10 Regulatory Impact Assessmets ad Sustaiable Developmet 4 RIAs i which the scope ihibited discussio of social ad evirometal impacts departmets still eed a overall assessmet of the costs ad beefits ad a bechmark for follow-up i later years to moitor implemetatio ad progress For example we idetified three factors that limit the ifluece of RIAs o policy: Crossrail This RIA focuses o whether the best legal way to proceed with Crossrail would be a hybrid bill or through existig legislatio. The RIA does metio that the mai evirometal ad social impacts of Crossrail are covered i other impact assessmets (a Evirometal Impact Assessmet ad a review of the busiess case) though it would help if the RIA provided a summary of their fidigs. Water Fluoridatio This RIA has a cofused scope, settig arrow objectives cocerig some aspects of whether to idemify the water compaies which fluoridate water, but the RIA proceeds to examie (i part) the wider issue of detal health, which we might expect to fid i a framework RIA. Biofuels Labellig This RIA assesses a policy proposal to comply with a particular article of the Europea Directive o biofuels, which imposes a requiremet that biofuel bleds i excess of five per cet should be clearly labelled at the poit of sale. I doig so, this RIA focuses oly o iformig cosumers to esure they did ot void their vehicle s warraty. It does ot cross refer to a framework RIA o the Biofuels Directive. It does ot cosider wider social ad evirometal issues. Source: Natioal Audit Office some RIAs are produced after importat decisios have bee made; some RIAs deal with the implemetatio of Europea Uio Directives. I such cases, may of the measures have already bee decided ad the UK ad other Member States are obliged to implemet them; ad some RIAs are produced to update aspects of the existig policy, whilst leavig the rest of the policy uchaged. Nevertheless eve i these cases departmets ca derive beefit from producig RIAs. Regardless of their ifluece o policy, RIAs fulfil a vital commuicatio role. I the case of implemetatio of EU directives, for example, 1.16 A forthcomig NAO report evaluates the extet to which departmets are embeddig impact assessmet ito their processes ad culture. Sustaiable developmet was ot well hadled i most of the RIAs we examied 1.17 To test the degree to which sustaiable developmet featured i recet RIAs, we examied 10 RIAs published sice April We expected the RIAs i our sample to follow the BRE guidace o assessig social ad evirometal impacts. That guidace requires that RIAs should: idetify all impacts; provide aalysis o each impact that is proportioate to the likely impact, but rigorous eough to iform decisio makig; ad preset all costs ad beefits clearly We also assessed the RIAs i our sample agaist the key priciples of the govermet s 1999 ad 2005 Sustaiable Developmet Strategies. 10 Although BRE guidace does ot explicitly refer to the Sustaiable Developmet Strategy, this is a cross-govermet strategy which applies to all policy-makig. The 2005 Sustaiable Developmet Strategy highlights the importace of appraisig policies agaist the priciples of sustaiable developmet ad the role that RIAs ca play i doig so Figure 5 summarises the results of our examiatio agaist BRE guidace o idetifyig, aalysig ad presetig evirometal ad social costs ad beefits. We foud a very mixed picture. All of the RIAs had some positive features, but oly oe RIA (o the Electricity ad Gas (Eergy Efficiecy Obligatios) Order 2004) demostrated all aspects of good practice. A list of the RIAs i our sample is provided i Appedix 1, together with examples of how they treated relevat evirometal ad social issues. We discuss the mai results of our aalysis i the rest of this sectio. 9 Three of the RIAs i our sample (o the Evirometal Impact Assessmet Regulatios (Rural lad holdigs ad ucultivated lad for agriculture); the Food Idustry Sustaiability Strategy; ad the Lorry Road User Charge) are partial RIAs at the time of writig, ad are assessed accordigly; we took accout of the fact that a departmet s estimates of the problem, beefits, costs ad ucertaities are likely to be less developed tha i a fial RIA. 10 Give that our sample icludes RIAs produced before ad after the Govermet lauched a ew Sustaiable Developmet strategy i March 2005, we applied oly the priciples commo to the two strategies. The 2005 is ot a departure from the 1999 strategy but rather a simplificatio of it: the differeces are i emphasis ad presetatio. Briefig for the Evirometal Audit Committee

11 Regulatory Impact Assessmets ad Sustaiable Developmet 5 Performace of the RIAs i our sample, agaist BRE guidace o social ad evirometal costs ad beefits RIA code BL BID CR EEC ROO WF W&F EIA FISS 1 LRU Idetificatio Aalysis Presetatio Key: 2 Good practice 1 Some good poits but room for improvemet -1 Some weak elemets -2 Poor practice Criteria for assessmet: Idetificatio: does the RIA idetify the social ad evirometal costs ad beefits?; Aalysis: does the RIA provide aalysis o each impact that is proportioate to the likely impact, but rigorous eough to iform decisio makig?; ad Presetatio: does the RIA preset all costs ad beefits clearly? Key to RIA codes: Full RIAs: BL: Biofuels Labellig; BID: Busiess Improvemet Districts; CR: Crossrail; EEC: The Electricity ad Gas (Eergy Efficiecy Obligatios) Order 2004; ROO: Reewables Obligatio Order; WF: Water Fluoridatio; W&F: Work ad Families. Partial RIAs: EIA: Evirometal Impact Assessmet Regulatios (Rural lad holdigs ad ucultivated lad for agriculture); FISS: Food Idustry Sustaiability Strategy; LRU: Lorry Road-User Charge. Source: Natioal Audit Office NOTES 1 The fial RIA o the Food Idustry Sustaiability Strategy was ot published at the time of writig this review, but DEFRA told us that it addresses may of the weak presetatioal ad aalytical elemets i the partial RIA. 2 As oted previously, some of the RIAs i our sample had a arrow or cofused scope which ihibited or precluded discussio of social ad evirometal issues relevat to the wider policy. To aid the clarity of our aalysis, however, the marks i this table do ot pealise RIAs for doig so, but oly assess how the RIA treated evirometal ad social issues relevat to the give scope. 3 Similarly, to avoid criticisig a RIA twice for the same mistake, the marks for aalysis oly assess how the RIAs treated the evirometal ad social impacts they idetified. Few RIAs idetified all social or evirometal impacts 1.20 Most RIAs i our sample made some referece to either social or evirometal impacts. However, i may cases the RIAs did ot provide a full eough descriptio to make it clear the Departmet had cosidered all the potetial impacts. A example is show i Figure 6. Evirometal ad social impacts were ofte ot aalysed i sufficiet depth 1.21 A aalysis of the key costs ad beefits of a proposal is the cetral compoet of the RIA. The iformatio ad aalysis o the costs ad beefits i the RIA should be proportioate to the likely impact but be rigorous eough to iform decisio makig. The BRE guidace describes three stages i the robust aalysis of costs ad beefits: full descriptio; quatificatio; ad moetisatio. 6 RIA that did ot idetify a evirometal impact Biofuels Labellig This RIA does ot discuss the effect that differet types of labellig might have o take-up of biofuels ad thereby o the impact o carbo dioxide levels. For example, oe of the optios i the RIA is to label biofuels with a warig sig; the RIA does ot provide evidece that the Departmet cosidered that a label of this type might discourage take-up of biofuels, ad so limit their role i reducig carbo dioxide emissios from trasport. It does ot make clear whether the Departmet cosidered ways to mitigate this effect, for example, by icludig iformatio about the evirometal beefits of biofuels o these labels. Source: Natioal Audit Office Briefig for the Evirometal Audit Committee

12 Regulatory Impact Assessmets ad Sustaiable Developmet 1.22 The guidace advises departmets to show costs ad beefits as moetary values wherever possible, i order to facilitate the direct compariso of differet impacts. This is usually straightforward where prices for goods ad services are ivolved. It is more difficult for may evirometal ad social costs ad beefits. Some of the techiques the BRE guidace recommeds for doig so are: surveys that show people s willigess to pay (how much people would pay for a clea river, fresh air, or a atioal park) or their willigess to accept (how much people would be prepared to accept i compesatio for sufferig); for valuig life/health, departmets ca use estimates of the value of a statistical life, or the cost to the NHS of treatig the illess; ad for valuig time, departmets ca use wages multiplied by the hours saved The guidace also says that where moetisatio is ot appropriate, quatificatio ca give a good idicatio of scale. For example, departmets might iclude such quatified estimates as the percetage fewer toes of a pollutat beig emitted to the atmosphere, or the umber of lives saved. There is likely to be ucertaity with such estimates of the quatitative or moetary value of such estimates; where this is the case, departmets should make this clear ad spell out the assumptios used to arrive at the estimates. Departmets should also cosider presetig a rage of values for their estimates ad statig whether this represets extreme values or the most likely outcomes. Where either quatificatio or moetisatio is possible, impacts should be described qualitatively However, amogst experts, both academics ad practitioers i the field, there is disagreemet o whether evirometal ad social costs ad beefits ca be, or ideed should be, quatified ad moetised. Some items are iheretly difficult to evaluate ad the calculatios may cotai a high level of subjectivity ad ucertaity Our fidigs as show i Figure 5 suggest that departmets are fidig it difficult i practice to aalyse evirometal ad social impacts. Five of the 10 RIAs we examied gave poor quality aalysis of evirometal ad social impacts. Figure 7 gives examples where the quality of the aalysis could have bee improved, while Figure 8 provides a example of the oe RIA i our sample that demostrated best practice More tha half (ie out of 16) of BRUs we cosulted agreed that the BRE guidace is of a reasoable quality but its usefuless i assessig these costs ad beefits is limited. No departmet said the guidace was ot helpful. 7 RIAs i which there was scope to provide a fuller aalysis of social or evirometal impacts Water Fluoridatio This RIA idetifies that detal disease has a social cost because it causes childre to miss time off school, but it does ot quatify how may childre might be affected i this way, or give a estimate of the moetary cost this imposes o society, for example i terms of the cost to parets who might have to take time off work. The RIA idetifies that there is a cocer that there are risks to overall health from fluoridated water but does ot give a full explaatio of the scietific evidece. Work ad Families RIA This RIA accompaies the Work ad Families Bill, which itroduces a package of measures desiged to give childre the best start i life ad parets more choice about how to balace their work ad family resposibilities. We cosidered how the RIA assesses the measure to exted the period of statutory materity ad adoptio paymets from 26 to 39 weeks. This RIA idetifies a umber of social beefits with this measure, such as the potetial improvemets to the quality of life of the mother ad parter, ad loger term beefits to childre ad the rest of society. The RIA states that the evidece cofirms the value of cosistet oe-to-oe care i the first year of a child s life, but does ot give the detail to support this claim, or describe what the ature of these beefits might be. Source: Natioal Audit Office 10 Briefig for the Evirometal Audit Committee

13 Regulatory Impact Assessmets ad Sustaiable Developmet The presetatio of most RIAs made it difficult to see if ad how sustaiable developmet had bee cosidered 1.27 There are two aspects of good practice i RIA presetatio that are importat for social ad evirometal impacts: 8 RIA with strog aalysis of evirometal impacts The Electricity ad Gas (Eergy Efficiecy Obligatios) Order 2004 The eergy efficiecy obligatio (2004) sets targets for electricity ad gas suppliers to icrease domestic eergy efficiecy i order to alleviate fuel poverty ad reduce carbo dioxide emissios. The RIA gives a quatitative estimate for carbo dioxide emissios saved by the policy proposal (about 0.7 millio toes of carbo per year i 2010) ad explais how this value is calculated. Usig a figure for the social cost of carbo, it also traslates this carbo savig to a moetary value of aroud 24m 95m a year. This RIA also icludes the followig paragraph which gives a good qualitative explaatio of the importace of reducig carbo dioxide ad greehouse gases: Ma-made emissios of carbo dioxide ad other greehouse gases are accumulatig i the atmosphere ad startig to chage our climate. There is ow strog scietific evidece that climate chage is happeig ad that it is beig accelerated by huma activity otably carbo dioxide released by burig fossil fuels such as coal, oil ad gas. This is ow ackowledged to have a serious impact icludig severe floodig, droughts ad storms with high ecoomic, huma ad evirometal cost both atioally ad iteratioally, particularly i developig coutries. Source: Natioal Audit Office The first is the suggestio i BRE guidace that iformatio o costs ad beefits, ad sectors ad groups affected, is preseted i a summarised form. A good way to do so is i the form of a summary table that brigs together iformatio o evirometal, social ad ecoomic costs ad beefits, for clarity ad ease of compariso (see Figure 9 overleaf for a example). This is also importat because there is o other mechaism withi the RIA for presetig trade-offs or syergies. However, oly three of the 10 RIAs i our sample icluded a summary table. The secod, which is ot cotaied i the BRE guidace, is the provisio of a ull respose if there are o social or evirometal impacts. Although the RIA process should ot become a tick box exercise, the fial RIA documet is more trasparet if it icludes eough iformatio to explai whe a RIA has cosidered evirometal ad social impacts but ot icluded them because it cosidered them to be immaterial or irrelevat. Also, the disciplie of explicitly statig a ull respose ecourages departmets to thik about the completeess of their aalysis. Oly oe of the seve RIAs that did ot idetify ay evirometal impacts gave a explicit ull respose. Neither of the two RIAs that did ot metio social impacts gave a explicit ull respose. Some priciples of sustaiable developmet were less evidet or uder-treated i most RIAs 1.28 Takig full accout of social ad evirometal costs ad beefits, where appropriate, is a ecessary coditio for a RIA to reflect sustaiable developmet, but it is ot sufficiet; both the 1999 ad the 2005 sustaiable developmet strategies defie sustaiable developmet to also iclude some importat cross-cuttig priciples Oe such cross-cuttig priciple is evidece-based policymakig. Six RIAs i our sample showed a poor performace o this frot by ot settig clear objectives or by ot assessig appropriate optios icludig a do-othig optio, or both. However, aother importat aspect of evidece-based policy-makig, cosultatio, was strog i our sample, with eight RIAs meetig most or all aspects of good practice Noe of the RIAs referred to the UK sustaiable developmet strategy ad oe explicitly referred to cross-cuttig sustaiable developmet priciples such as the polluter pays priciple 11, the precautioary priciple 12, takig a log-term perspective, ad itegratig social, ecoomic ad evirometal beefits. Where a policy proposal implicitly took accout of these priciples, the RIAs i our sample did ot always make clear whether the departmet had fully ad systematically compared the optios o this basis. Figure 10 overleaf gives some examples. 11 The polluter pays priciple suggests that evirometal ad social costs should fall o those who impose them. It is a way of allocatig evirometal costs fairly ad of providig disicetives to pollutig or wasteful activities. 12 The precautioary priciple says that if the cosequeces of a actio are ukow, but are judged to have some potetial for major or irreversible egative cosequeces, the it is better to avoid that actio. Similarly, it advises agaist iactio if delay would have a similar egative result. Briefig for the Evirometal Audit Committee 11

14 Regulatory Impact Assessmets ad Sustaiable Developmet 9 Example of good use of a summary table The Work ad Families RIA cotais a table of the costs ad beefits of the proposal to exted materity leave, which allows the ecoomic ad social impacts to be compared easily: Source: Work ad Families RIA NOTES SMP: Statutory Materity Pay. MA: Materity Allowace. SAP: Statutory Adoptio Pay. 10 RIA ad cross-cuttig sustaiable developmet priciples Busiess Improvemet Districts The overall aim of Busiess Improvemet Districts (BIDs) is to provide local busiesses (ad local authorities) with a greater say i the improvemets udertake i their area ad give them the opportuity to work together to put i place these projects which busiesses fud through a levy. The Departmet told us that BIDs, by their ature, may lead to improvemets i the quality of the local eviromet, however, this RIA does ot evidece whether the Departmet has cosidered how it might itegrate evirometal, ecoomic ad social cosideratios i the arragemets for busiess improvemet districts. For example, the RIA could have icluded iformatio o whether the Departmet had cosidered ways to promote evirometally friedly projects through icetives i the ratig structures, tax relief, or eve through settig this as a criterio for local authority fudig. Lorry Road User Charge The objective of this Regulatio is to esure that all lorries usig UK roads, regardless of atioality, cotribute o a fair ad equal basis to the costs that they impose. This partial RIA icludes some qualitative aalysis of how the polluter pays priciple might apply; it recogises that a lorry road user charge might be tailored to reflect the differet evirometal costs imposed by differet types of vehicles/forms of trasport. However, the referece to social ad evirometal issues is ofte abstract. The RIA recogises that quatified costs ad beefits will eed to be developed over time; it would have bee helpful to iclude estimates at this stage. Source: Natioal Audit Office 12 Briefig for the Evirometal Audit Committee

15 Regulatory Impact Assessmets ad Sustaiable Developmet There are steps which could improve the way sustaiable developmet is cosidered i RIAs 1.31 Our aalysis above shows that most RIAs i our sample did ot succeed i reflectig relevat sustaiable developmet issues: either sustaiable developmet cocers were ot addressed or if they were addressed they did ot fid their way ito RIA documetatio. So there is room for improvemet if RIAs are to develop fully ito a satisfactory tool which icorporates ad demostrates sustaiable developmet thikig There is a learig curve i ay process ad the NAO, i its broader work o RIAs 13, has foud that departmetal practice has improved over time; for example cosultatio is ow better tha it was. It is oly sice April 2004 that RIAs have bee required to iclude sustaiable developmet issues ad our sample was draw from RIAs published i the followig year; so for may it is early days yet. If departmets icrease their capacity ad expertise, we might expect the cosideratio of sustaiable developmet issues to improve Some might argue that RIAs will ever be capable of bearig the weight that has bee applied to them: as we describe above, sustaiable developmet is just oe of several dimesios which have bee added to the RIA process sice their begiigs i 1997, ad RIAs may struggle to do justice to each of these dimesios. But it seems likely that RIAs i some shape or form will remai the prime vehicle for iformig ad presetig policy makig, at least i the field of regulatio. Eve if they were to be abadoed, a similar tool would eed to be re-iveted sice there would still be a eed for a tool to ecourage cosideratio of ecoomic, social ad evirometal costs ad beefits Our emphasis, therefore, is o improvig the RIA process. Below we highlight ways i which this might be doe. Guidace to officials could be improved 1.35 Better Regulatio Executive Guidace is a importat way to provide advice to departmets o sustaiability issues. However, the majority of departmets respoded to our questioaire by sayig the guidace is of a reasoable quality but its usefuless i assessig evirometal ad social costs ad beefits is limited The guidace could do more to draw attetio to sustaiable developmet issues. For example: o-lie ad writte guidace could lik or refer directly to the govermet s Sustaiable Developmet Strategy ad its key priciples; guidace could do more to emphasise the importace of achievig ecoomic, evirometal ad social impacts at the same time. A Stretchig the web tool developed by Departmet for Eviromet Food ad Rural Affairs (Defra) is a useful example of how to help policy-makers thik this through, though it does eed to be supported by a full uderlyig aalysis. (see Figure 11 overleaf); the guidace o social impacts could be more cocise, better co-ordiated ad more closely liked to RIAs 14 ; ad the guidace could provide more worked examples o how to assess evirometal ad social costs ad beefits, particularly givig examples of how to quatify ad moetise these impacts where appropriate. Officials ivolved i the productio of RIAs eed more traiig o sustaiable developmet 1.37 Traiig is aother way to improve officials uderstadig of how sustaiable developmet ca be icorporated ito policymakig ad, where possible, RIAs. The majority of departmetal BRUs told us that a lack of resources, such as staff or traiig, restricts their ability to esure RIAs fully cosider sustaiable developmet. 13 Evaluatio of Regulatory Impact Assessmets Compedium Report (HC 358) ad (HC 341). 14 The extat web-guidace o social impacts provides liks to a umber of differet websites maitaied by differet departmets. These are of varyig quality, are ot always kept up to date, ad do ot lik well to each other. Briefig for the Evirometal Audit Committee 13

16 Regulatory Impact Assessmets ad Sustaiable Developmet 11 Defra s stretchig the web tool The web is a simple graphic, based o the RIA, to help Defra policymakers itegrate sustaiable developmet cosideratios ito policymakig. Each questio i the costs ad beefits checklist of the BRE guidace becomes a spoke of the web. The joiig strads are created by joiig up the self-assessed score for each questio, from -2 (very egative impact) to +2 (very positive impact). Q21 Q20 Q19 Q18 Q17 Q16 Q22 Q1 Q2 Q3 Q4 Q5 Q6 Q7 Q8 The RIA is iteded to help policy-makers to thik of sustaiable developmet as stretchig the web mitigatig egative impacts, ad icreasig positive impact s rather tha as a trade-off or balace betwee ecoomic, evirometal ad social impacts. COLOUR KEY Ecoomic impacts Social impacts Evirometal impacts Q15 Q14j Q14i Q14h Q13 Q14g Q14a Q14f Q14e Q14b Q14d Q14c Q12 Q11 Q10 Q9 Source: Departmet for Eviromet Food ad Rural Affairs Thik sustaiable web pages 1.38 Oly three departmetal BRUs respoded to our questioaire to say they provide traiig o sustaiable developmet to officials ivolved with the productio of RIAs, though a further 11 ited to do so. The BRE does ot curretly offer traiig o sustaiable developmet to the BRUs The Natioal School of Govermet, which is also part of the Cabiet Office, offers traiig courses o the priciples of sustaiable developmet; these could be expaded to relate directly to RIAs. The Better Regulatio Executive could improve its scrutiy of RIAs 1.40 BRE is resposible for esurig that departmets comply with the RIA process. For may RIAs, the BRE iput is limited to published guidace ad offerig ad hoc advice to departmetal BRUs ad directly to policy makers if requested. However, the criteria for triggerig BRE s direct ivolvemet i a RIA are based primarily o ecoomic cosideratios rather tha sustaiable developmet. The BRE gets ivolved directly with a particular RIA if the policy cotais sigificat measures defied as costig more tha 20 millio; if the issue has high media topicality or sesitivity; if there is a Better Regulatio Commissio report or iterest i the policy area; or if there is likely to be a disproportioate impact o a particular group. These criteria esure that BRE gets directly ivolved with RIAs o policies with sigificat ecoomic issues, but it does ot give social ad evirometal issues the same weight Each departmet has a omiated cotact withi the BRE ad it is this cotact s resposibility to provide a challege fuctio withi the RIA process. The BRE will poit out errors ad weakesses i the RIA but they will ot assess it for completeess, or do BRE officials have specialist sustaiable developmet expertise, ad thus ay omissios or errors relatig to sustaiable developmet will ot ecessarily be picked up. 14 Briefig for the Evirometal Audit Committee

17 appendix 1 Regulatory Impact Assessmets ad Sustaiable Developmet regulatory impact assessmets IN OUR SAMPLE Biofuels Labellig Departmet for Trasport A policy proposal to comply with a particular article of the Europea Directive o biofuels, which imposes a requiremet that biofuel bleds i excess of five per cet should be clearly labelled at the poit of sale. This is to protect cosumers from ukowigly fillig their vehicles with fuel that may be usuitable for their vehicle ad that could ivalidate their warraty. The overarchig objective of the Biofuels Directive is to reduce carbo dioxide emissios ad reduce reliace o exteral eergy sources. Busiess Improvemet Districts Office of the Deputy Prime Miister The overall aim of Busiess Improvemet Districts (BIDs) is to provide local busiesses (ad local authorities) with a greater say i the improvemets udertake i their area ad give them the opportuity to work together to put i place these projects which busiesses fud through a levy. The Local Govermet Act (2003) established the statutory framework for BIDs; this RIA accompaies the Statutory Istrumet which prescribes the detailed arragemets for settig up ad maitaiig a BID i a area. Crossrail Departmet for Trasport The RIA assesses the eed for primary legislatio to implemet Crossrail, a ew railway coectig existig track to the west ad east of Lodo via a tuel through cetral Lodo. It cosiders whether it would be better to use existig legislatio, or to itroduce a hybrid bill. The Electricity ad Gas Eergy Efficiecy Obligatios (EEO) Order 2004 Departmet for Eviromet, Food ad Rural Affairs The eergy efficiecy obligatio (2004) sets targets for electricity ad gas suppliers to icrease domestic eergy efficiecy i order to alleviate fuel poverty ad reduce carbo dioxide emissios. Suppliers would meet their targets by ecouragig ad assistig domestic cosumers to take up eergy savig measures. The obligatios proposed i this RIA are a successor to the eergy efficiecy obligatios established i Reewables Obligatio Order 2005 Departmet of Trade ad Idustry The Reewables Obligatio requires licesed electricity suppliers to source specified percetages of the electricity they supply from reewable sources. For each MegaWatt hour of reewable electricity they geerate, they receive a Reewable Obligatio Certificate (ROC). If suppliers do ot preset the required umber of certificates by the ed of a period, they pay a buy-out fee; this fud of buy-out paymets is the re-distributed to the Certificate holders. The objective of this RIA is to assess the impact of proposed chages to the Reewables Obligatio Order, icludig the measures to make it fuctio more effectively, allowig for tradability of certificates issued uder the Reewables Obligatio with those issued uder the Norther Irelad Reewables Obligatio i the preset scheme, ad extedig the level of the Reewables Obligatio beyod 2010 to Briefig for the Evirometal Audit Committee 15

18 Regulatory Impact Assessmets ad Sustaiable Developmet Water Fluoridatio Departmet of Health This RIA accompaies a statutory istrumet which ameds the Water Idustry Act to outlie the level of cosultatio required by a Strategic Health Authority (SHA) before it compels a water supplier to add fluoride to the water supply, ad give idemities to water udertakers ad water suppliers. Work ad Families Departmet of Trade ad Idustry This RIA accompaies the Work ad Families Bill, which itroduces a package of measures desiged to give childre the best start i life ad parets more choice about how to balace their work ad family resposibilities. The measure we cosidered is to exted the period of statutory materity ad adoptio paymets from 26 to 39 weeks. Evirometal Impact Assessmet (Partial RIA) Food Idustry Sustaiability Strategy (Partial RIA) Departmet for Eviromet, Food ad Rural Affairs This is a partial RIA o a proposal to itroduce a volutary sustaiability strategy for the whole of the food ad drik idustry. This would cover all aspects of food processig ad retail oce food leaves the farm o which it is grow. Lorry Road User charge (Partial RIA) Departmet for Trasport, HM Treasury ad HM Reveue ad Customs This partial RIA accompaies a proposal to itroduce charges to foreig lorry operators usig British roads. The objective is to esure that all lorries usig UK roads, regardless of atioality, cotribute o a fair ad equal basis to the costs that they impose. It aims to address the potetial for lorries registered overseas to avoid completely ay charge for usig British roads, while British lorries ted to do so by payig vehicle excise ad fuel duty. Departmet for Eviromet, Food ad Rural Affairs This is a partial RIA which accompaies a Statutory Istrumet (SI) trasposig two requiremets of the EU Evirometal Impact Assessmet (EIA) Directive 85/337/EEC. The SI itroduces ew rules o restructurig of rural lad holdigs, so that lad maagers of certai large-scale projects will eed permissio from the regulator (Natural Eglad) before they ca proceed. The SI will also replace existig rules o evirometal assessmets projects which use ucultivated lad ad semi-atural areas for itesive agricultural purposes; the proposal is to itroduce thresholds before evirometal assessmets are ecessary. 16 Briefig for the Evirometal Audit Committee

19 Regulatory Impact Assessmets ad Sustaiable Developmet Treatmet of evirometal ad social costs ad beefits RIA Evirometal ad social Withi scope Idetified Explaatio of sigificace issues viewed as relevat 1 of the RIA 2 Described Quatified Moetised Busiess Opportuity to cotribute to urba regeeratio Improvemet Effect o local democracy 4 8 Districts Potetial for evirometal beefit? 8 Crossrail Biodiversity ad heritage impacts 8 employmet opportuities 8 costs for ladowers public participatio Electricity Gas Greehouse gas emissios (EEO) 2004 Impacts o icome groups Labellig Displacemet of food productio? 8 Biofuels Redevelopmet of rural areas? 8 greehouse gas emissios Reewables Greehouse gas emissios Obligatio Impacts o icome groups Order Water Detal health beefits? Fluoridatio Impacts o icome groups? Health risks? 8 Work ad Quality of life beefit to paret/carer Families Health beefit to child potetial to icrease tesio i the workplace EIA Impact o availability of gree space 4 8 regulatios 3 Biodiversity impacts Impact o rural commuities Food Idustry Greehouse gas emissios Sustaiability Waste Strategy Health ad Safety of workers Lorry Road Cogestio User Charge Air quality greehouse gas emissios Key: Yes 4 Partially 4 No 8 Idirectly/ope to questio? NOTES 1 As idetified by our expert pael. 2 This colum demostrates how i our sample had a arrow or cofused scope which ihibited or precluded discussio of social ad evirometal issues relevat to the wider policy. To aid the clarity of our aalysis, however, our assessmet of each RIA does ot pealise RIAs for doig so, but oly assesses how the RIA treated evirometal ad social issues relevat to the give scope. 3 (Rural lad holdigs ad ucultivated lad for agriculture). Briefig for the Evirometal Audit Committee 17

20 Appedix 2 Regulatory Impact Assessmets ad Sustaiable Developmet Survey of departmetal regulatio teams Questio Yes partly No Other Q1 The Board Level champio for regulatio effectively ecourages sustaiable developmet (SD) i policymakig Q2 There is a visible team or idividual, with sufficiet resources, who is clearly resposible for SD i policymakig ad RIAs Q3 The departmet provides traiig o SD to officials ivolved with RIAs Q4 Appropriate officials have a clear uderstadig of how to icorporate SD i policymakig Q5 BRE web-based guidace is of a high quality ad useful for evirometal ad social costs ad beefits Q6 The departmet meets the requiremet to fully assess evirometal costs ad beefits where appropriate Q7 The departmet meets the requiremet to fully assess social costs ad beefits where appropriate Q8 The departmet attempts to quatify or score evirometal or social costs ad beefits Q9 The departmet makes appropriate use of expert iput i assessig evirometal ad social costs ad beefits NOTE We set our survey to the better regulatio uit, or better regulatio cotact i all Whitehall departmets for whom the Cabiet Office has a better regulatio cotact, amely: Departmet for Costitutioal Affairs, Departmet for Educatio ad Skills, Departmet for Eviromet Food ad Rural Affairs, Departmet for Trasport, Departmet for Work ad Pesios, Departmet for Culture Media ad Sport, Departmet of Health, Departmet of Trade ad Idustry, Foreig ad Commowealth Office, HM Reveue ad Customs, HM Treasury, Home Office, Miistry of Defece, Office of the Deputy Prime Miister, Food Stadards Agecy, Health ad Safety Executive. (For RIA purposes Cabiet Office treats HSE ad FSA as Whitehall departmets) We preseted our survey i the form of a set of McKisey style assertios; for each questio we asked the respodet to circle the most appropriate statemet. These statemets correspod to the questios ad aswers above. Other idicates a ull or ot applicable respose, or o oe occasio, where a respodet circled more tha oe respose. 18 Briefig for the Evirometal Audit Committee

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