Select Committee on Environmental Audit Minutes of Evidence

Memorandum from Enviros Aspinwall

  Overall I believe the two main issues are those of:

    —  Transparency, in that any observer should be able to see that outcomes, actions and programmes are clearly linked and guided by a simple and accessible policy, and

    —  Assurance, in that any observer should be provided with suitable assurance that performance information and data meets agreed minimum standards of robustness and confidence.

  I wish to make contributions in the following four areas:

    (a)  Coherence and Consistency;

    (b)  Systems and Accountability;

    (c)  Audit, Appraisal and Assessment;

    (d)  Reporting.


  There is still need to secure greater coherency and consistency in what Sustainable Development and Sustainable Management means in terms of the working life of the government and individual departments. Any debate on these issues is still dogged by, or confounded by, immature or incomplete understanding of how in individual situations and contexts Sustainable Development manifests itself. In addition given that different departments and associate bodies have differing business foci it is natural that their "local" view of sustainability might also vary. This is both a strength and a potential weakness of the concept. It is likely to be only when all the contributions are drawn together in an overall government context that the totality could be assessed. There is therefore the need to promote, monitor and report at a number of levels. Each level would therefore also plan, manage and report, against its own local context and in terms of its contribution to the wider governmental context.

  If departments are allowed, or encouraged, to develop their own local methods and approaches, in isolation to the wider context, then it is highly likely that local practice could diverge. In addition the development of (incompatible) local methods and approaches will likely prevent the assimilation of government wide performance and progress.

  There is significant progress still to be made on the environmental (or sustainable) literacy of departments and staff, apart from those "specialist" staff with a particular role in these areas. Where staff with specialist knowledge are "centralised" there is considerable potential for a coherency gap to be created between policy and operational units within the same department.


  In general the Green Ministers Committee, and its supporting systems, does provide an adequate instrument to monitor and report on greening government. The Green Ministers Committee also has a clear role to play in setting cross government priorities and targets. The Committee could further assist the greening of government by establishing greater consistency and standardisation in the use of performance metrics and monitoring, and reporting methodologies.

  There is no doubt that a balancing act has to be struck between prescription and facilitation. However, there would be benefit in establishing a small number of clear metrics, defined in detail, upon which to collect performance data. These metrics would be applied consistently and without exception across all departments and ideally over a number of years. New metrics could be added but there should be no changes to how the existing ones are calculated. The metrics would all link to the sustainability goals that the government has set for the UK as a whole.

  A distinction may be drawn between Policy and Operations. In the case of the former the associated outputs, but not necessarily the outcomes, will be under the direct management of the relevant department. In the case of the latter both outputs and outcomes will be directly managed by the department or associated body. In the case of the former there is therefore some argument to suggest that systems and accountability for Policy outputs and outcomes could be distinct and separate.


  Audit in all its forms is well established and understood. For environmental issues there is considerable experience throughout many organisations on the process and procedures involved in environmental auditing. There are well-established classes or types of audits and there are standards for audits, auditors and auditor training.

  Audit is one of the most important "assurance" tools for management and other interested parties. In policy terms audits can provide assurance that policy is being implemented; that actions are being taken; and what the outputs or outcomes of those actions are. Audits are also essential to establish where corrective action is required. Audits may also concentrate on output performance, in any event there should be audit of performance, and audits should follow established protocols and procedures.

  Consequently those carrying out the audit should be competent auditors depending on the scope and purpose of the audit. In terms of strict audit process and in this context, it is possible for audits to be carried out by departments themselves, other government bodies, and independent third parties. All of these have their role to play. For instance self-auditing enables local management to be assured that practises and policy are being adhered to on a routine and day to day basis. In a given situation the appropriate auditors are likely to be determined by the level of scrutiny to which the audit findings will be subjected and the level of assurance required. In general third party independent auditing will be required where the audit findings are likely to be open to wider scrutiny.

  Appraisal, and to a lesser extent Assessment, are much less well understood, and there is much less consistency in the use of the terminology. There is considerable uncertainty as to what constitutes a policy appraisal or assessment, or what constitutes the appraisals or assessment process. Whilst examples of appraisals and assessment are helpful what is lacking is a visible underlying framework to policy appraisal and assessment. Various models already exist, for instance the concept of strategic environmental assessment, which can be of help. In addition most of the models have a few common underlying themes which therefore could form the basis from which to develop an approach suitable for use in departments and associate bodies.


  Reporting practices across departments and associate bodies varies greatly. There can be little doubt that several years' experience of the reporting cycle is required before organisation can report openly and confidently. This is driven, typically, by a number of issues. There may be concerns about establishing a stable reporting base line, or there may be concerns regarding the robustness of performance data and collection systems. Without doubt there is still an element of don't report unless you have to.

  There are examples of departmental and associate body environmental reporting that is the equal of that to be seen in the private sector, however apart from the obvious exceptions, the breadth and depth of government environmental reporting must be considered limited. Mandatory reporting, whether from an environmental or sustainability standpoint, is not the answer on its own. Reporting has to be linked to wider issues such as corporate responsibility and governance. The material being produced through the activities of the participants in schemes such the Global Reporting Initiative will be relevant and of assistance. However this will require modification for the needs and specific context of public sector bodies and particularly government.

  Should government decide to require mandatory environmental reporting from industry in any shape or form then it is inevitable that departments should be expected to produce similar reports.


    —  Greater clarity, consistency, and simplicity when describing policy;

    —  Improve the environmental literacy of staff;

    —  Standardise performance metrics;

    —  Guidance on when, what and who to audit;

    —  Develop standardisation in appraisal framework and methods;

    —  Improve breadth and depth of reporting across all departments.

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Prepared 9 January 2001