Select Committee on Culture, Media and Sport Appendices to the Minutes of Evidence


Memorandum submitted by The Chartered Institution of Water and Environmental Management



  The Chartered Institution of Water and Environmental Management (CIWEM) is the independent pre-eminent body for professionals engaged in the stewardship of environmental assets and sustainability. CIWEM's Royal Charter remit includes recreational aspects of the environment and many of our members are involved in the cultural industries. Most recently we have been supporting projects and programmes which bring together artists and environmental issues—mostly at a local level—to develop some innovative community arts initiatives in order to raise the profile of environmental affairs.

  I write in response to the Arts Council of England's (ACE) consultation document, "Working Together for the Arts", in which it presents proposals to disband the 10 Regional Arts Boards (RABs) and replace them with a new single national body which will assume the current functions of ACE and the RABs. I welcome the opportunity to alert the Culture, Media and Sport Committee of the House of Commons to the views of CIWEM, and others, on this important matter and hope that they will be taken in to account. This written evidence is based on CIWEM's response to the Arts Council's document "Working Together for the Arts".

  I comment on the Arts Council's restructuring plans in my capacity as Executive Director of this Institution (CIWEM), as an Adviser to Southern Arts (but not for Southern Arts) and as Chair of ILAM South East, the regional arm of the institute of Leisure and Amenity Management (ILAM), representing cultural services in the South East of England. I have consulted widely with colleagues and stakeholders of each organisation and this response reflects many strongly held views.

  I read the Arts Council's proposals with great interest and welcome the fact that more time was given to the consultation process. Two themes stand out from the text of the consultation document. Firstly, the stated commitment to subsidiarity. (This is mentioned several times in the document). Secondly, the document refers to the difficulty of harmonising the views of ACE with those of the RABs because of the latter's independent status. I would like to deal with each of these in detail then follow with some general comments which I have been asked to make you aware of and which I support entirely:


  Although the proposals reinforce a continued commitment to the principles of subsidiarity, as a key feature of the need for change, there is in fact very little evidence of this in the document. Proposals for the organisational structure, governance, appointment of senior staff and appointment of members of the proposed new Regional Councils of the national body all indicate a strong desire for central control with an ability to take away those roles and responsibilities the new national body proposes to delegate. As the consultation document states—the governing council of the national body "will retain the right to revoke any delegated decisions". This makes a mockery of the stated commitment. The independent status of the 10 RABs represents subsidiarity in action and is an outward and visible sign of local determination by committed representatives of local communities. A real test of subsidiarity is the extent to which real independence and self determination, in response to local circumstances, exists. What is being proposed does not meet this test.

  Presentation is important and this document has failed to hide ACE's frustration with arts funding and administration in the Regions. Neither does it disguise the "London knows best" attitude which prevails. I suggest that the tone of the document will anger those consultees ACE presumably wishes to win over. This, together with recent previous discredited attempts to sell proposals for change to the arts funding system, says a great deal about the culture of ACE and colleagues have drawn their own largely negative conclusions in this regard. Which is a pity given the important role of ACE and the public support and confidence it needs.

  Art in the Regions will only be truly vibrant and successful if it is funded and supported by an independent and locally managed system. I see no real or sustainable alternative to the RABs. What does bear examination though is how the RABs can best contribute to ACE and its remit based on a "bottom up" approach.

  If ACE has real problems working with the RABs who is to say that the fault does not lie with ACE? In my varied management experience successful working relationships are achieved despite organisational arrangements and not because of them. So, why change what works well for local communities? In my opinion it is for local people and the arts community, locally, to determine the need for change and to take the lead.


  I can well understand the frustration of ACE in trying to harmonise the national strategic view with those of the RABs. However, I regard it as something akin to arrogance for ACE to assume, by implication, that the fault, if any, lies with the RABs. Notwithstanding my earlier comments, if there are real difficulties this could be resolved by creating a national body which comprises stronger representation of the RABs. I have long doubted the balance of the current composition of ACE and it is disappointing that other options for a more effective arts funding system have not been objectively debated in the public domain. If we are to have a review then I believe that this must be managed and undertaken independently of those most likely to be affected. I do not regard ACE as independent in this context.


    (a)  The proposals are based on many assertions which are untested. No new organisation can guarantee to "respond more quickly and effectively to new developments across the country". Where is the evidence for this? To base proposals for major reorganisation on such thin and subjective assumptions is naïve, in my opinion, and should be discounted for this reason alone.

    Proposals for change, from whatever source, must, like a business plan, be well researched, be sustainable, be properly costed, be supported by evidence, have wide ownership and inspire confidence. The proposals must also be based on a clear vision. In this case I see no vision just a rather dubious attempt by ACE to extend its sphere of control.

    (b)  The proposals say that the new body will work with local authorities to promote the arts to other agencies. The RABs already do this very effectively. The proposals do not evidence the new arrangements or show how they would improve on what is being achieved already.

    (c)  If financial and other sorts of accountability are an issue then I am sure that the RABs would be happy enough to let the National Audit Office examine the way they utilise public money and appear before Parliament. My view though is that there are already sufficient safeguards and tests in place to negate such a move.

    (d)  The consultation document is neither a detailed plan or a blueprint. It contains very little financial data and hardly anything in the way of outcomes or outputs supported by evidence or performance indicators. As I have pointed out earlier, in (1) above, the proposals meet none of the established criteria for making a business or strategic case for change.

    (e)  Despite the claim to support the subsidarity principle this is a proposal based on centralist control which flies in the face of this Government's devolution agenda. I also doubt that what is being proposed is sustainable. How can a single national body be as effective as the RABs in working with the merging regional structures? If these are adopted I believe that further re-structuring would be necessary in a few years time. A point well made by Southern Arts and one which I reiterate.


  Reasons why the Arts Council's proposals for restructuring of the Arts funding system should be rejected:

    —  Research shows that the majority of artists and arts organisations do not believe that the proposals for change will benefit them or their stakeholders;

    —  A business case has not been made and the proposals are based on many assumptions. A clear programme of improvements to the existing structure would be more effective than the creation of a single organisation;

    —  Any proposals for change must be independently investigated and customer driven. The Arts Council cannot be regarded as independent in this context. It has a vest interest.

    —  The proposals run counter to the Government's policy of regional self determination and should be dismissed on that count alone.

    —  The suggested cost saving benefits of the proposals have not been proven. A single organisation is likely to be costly and more bureaucratic than the present structure.

  I hope these comments are helpful to the Culture, Media and Sport Committee. If you would like clarification of any point please do not hesitate to contact me.

7 January 2002

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