Memorandum submitted by the Royal Society for the Protection of Birds (RSPB) (G 21)
1. EXECUTIVE SUMMARY
The RSPB believes the creation of the Department for Environment, Food and Rural Affairs (DEFRA) brings positive opportunities for the environment, particularly in terms of integrating environmental considerations more closely into rural policy than was the case under the previous departmental arrangements. It is difficult to judge DEFRA's performance on the evidence of its first year, as this has been dominated by the aftermath of the foot and mouth outbreak and by the internal personnel and organisational issues created by the amalgamation of parts of the former DETR with the former Ministry of Agriculture, Fisheries and Food (MAFF). However, on balance, we are encouraged by both DEFRA's emphasis on consultation with external stakeholders and much of the rhetoric from the ministerial team and Management Board on its new policy priorities. We remain concerned that some of the cultural issues that characterised the worst aspects of MAFF still predominate and that there is a huge amount of work to convert fine words into real action. However, we acknowledge that this is against the backdrop of a year in which there has been a huge amount of upheaval following the merger and that much consultation was necessary to establish a new direction and ownership within DEFRA.
2. DEPARTMENTAL VISION
2.1 The RSPB endorses the vision set out by the Secretary of State, particularly the emphasis it places up-front on international action to tackle climate change and environmental degradation.
2.2 We contributed to the consultation on the Department's new aims and objectives and expressed concern that the original draft was weighted too heavily in favour of the rural agenda. The final set of aims and objectives was more balanced and represents a reasonable summary of what we believe the Department should be seeking to achieve.
2.3 The Departmental Prospectus The Essentials of Life set out some laudable principles for the Department to follow but was disappointing in terms of its policy content. As an overarching statement of intent, it was rather backward-looking and missed opportunities to set out exciting new approaches to tackling issues such as flood defence, rural policy and marine conservation. It could be argued that it was a mistake to publish this document ahead of Spending Round 2002, which will ultimately determine DEFRA's ability to act on a range of key issues.
2.4 To date, there has been little tangible progress towards meeting the ministerial vision. In its first year, DEFRA has clearly been pre-occupied with, in the first instance, managing the aftermath of foot and mouth and latterly, developing an identity and approach distinct from that of its predecessor department. It also appears that the personnel issues raised by the merging of staff from the former department of the Environment, Transport and the Regions (DETR) with the former MAFF have created additional time constraints. There is substantial good will towards DEFRA from many of its key stakeholders but it will need to start showing innovation and urgency on a range of policies to maintain this beyond its first year. After nine months of stakeholder engagement, we are not approaching the time for DEFRA to stop consulting and start acting.
2.5 The area where DEFRA has been most active is agriculture reform, primarily in the UK. Progress on this agenda was delayed by the work of the Policy Commission on the Future of Farming and Food. The RSPB welcomed DEFRA's endorsement of the Commission's overall directionwe see the biggest opportunity of DEFRA's creation as being a more progressive approach to policy on the countryside. However, we were concerned that DEFRA seemed surprisingly ill-equipped and slow to respond to the Commission's report. It is vital that DEFRA start to show leadership on this issue once it has published its Strategy this autumn and that it is not subject to further consultation. Its willingness to champion the whole Curry packageincluding an increased rate of modulation to 10 per centwill be seen by the environmental community as the acid test of how far it has moved away from acting as a champion of big producer interests and towards a broader view of rural policy. This bringing together of policy on the countryside with environmental policy presents the Department with real opportunities for making change work.
3. BALANCE BETWEEN FARMING, FOOD AND ENVIRONMENTAL ISSUES
3.1 Given the political context for its creation, DEFRA has had to work hard to dispel the perception within the sustainable development community that it is simply a rural department. The RSPB welcomes the high levels of consultation and stakeholder dialogue that the Department has carried out during its first year. We have been involved at many levels with formal and informal consultations on Aims and Objectives, Sustainable Development Strategy and Departmental Prospectus, as well as its horizon-scanning programme for its research and development programme. This is an extremely welcome departure from the approach of its predecessor department, which appeared to see environmental organisations as, at best, alien to its view of rural policy as being about mass food production at lowest cost, and, at worst, a threat.
3.2 We have seen no evidence that farming, food and environmental concerns are not given proper weight by the Department, although agriculture reform appears to be its political priority. However, we are concerned that the environment portfolio has been marginalised within government by the new departmental arrangements. In particular, we are not convinced that DEFRA has the political muscle of the former DETR to champion sustainable development across government. Looking at the performance of departments that should be DEFRA's closest partners suggests that there is a long way to go on joined-up government. In addition, there is still a perception within Whitehall that DEFRA is solely a rural department. Most of DEFRA's initial focus on sustainable development has gone into what the Department can achieve within its own remit. To this end, developing a departmental Sustainable Development Strategy was a welcome exercise in refocusing DEFRA's own priorities and getting ownership behind this new direction across the Department. However, working on sustainable development across government will require close working with all government departments, especially with departments such as the Department of Trade and Industry, the newly created Department of Transport, and HM Treasury on issues such as energy, planning, transport and environmental taxation. DEFRA should be seeking joint Public Service Agreements with these departments to help reach consensus across government on how such cross-cutting areas of policy should be taken forward.
3.3 Despite the progressive rhetoric of the ministerial team and Management Boardand the substance given to this by the Aims and Objectives and Ministerial Visionthere is worrying evidence that the inertia and narrow world view towards agriculture shown by the former MAFF are still pervasive at lower levels within the Department. For example, DEFRA has failed to take the initiative on implementing the report of the Policy Commission on the Future of Farming and Food, particularly on championing the benefits of the broad and shallow scheme, at a time when it is crucial that it wins the money to match-fund any increase in modulation under the Comprehensive Spending Review. Another example would be the flood defence agenda, where DEFRA appears to remain wedded to an unnecessarily narrow view of the range of possible solutions.
5. RURAL AGENDA
5.1 DEFRA should be in a position to ensure coordination of policy across the rural sector within its scope of activities and across Whitehall through influence on "rural proofing" other ministries' activities. Recent work by the Countryside Agency demonstrates that DEFRA still has a long way to go before rural matters are taken seriously across Government. Confusion still exists as to ministerial responsibility, which remains unclear even to seasoned observers of ministerial roles. Greater clarity on responsibility should be provided. The setting up of the Rural Affairs Forum was an opportunity to develop stakeholder agreement for a range of government initiatives and as a sounding board for the quick rural policy and implementation wins that government seeks. However, early experience of the Forum fails to dispel the fears of those who feared another talking shop. To date there is little sign that this initiative will deliver real benefits and "on the ground changes". At a regional level however, there are positive signs that the Regional Rural Forums are working and getting to grips with real local problems and their solutions. This could prove to be a success story for the Department.
5.2 The RSPB hoped that the merger of the countryside protection functions of DETR with the Flood defence and agri-environment functions of MAFF would lead to significant improvements in the handling of flood defence issues within the Department as they affected both wildlife protection and enhancement. Early signs are not encouraging. As yet, there is little appearance of the joined up thinking approach that these sectors desperately need in order to fulfil both our national and international biodiversity obligations, within a more adventurous and holistic approach that the new DEFRA should be able to provide. The ability of the Department to develop a strategy for improving water quality which is sufficiently robust to meet new standards arising from the Water Framework Directive, and sufficiently sensitive to the current social and economic difficulties of farmers, will also provide an interesting test of the new arrangements.
6. FUTURE SPENDING PLANS
6.1 The outcome of ongoing management problems is not being felt in the regions and within the farming community. Our fear is that this will dent the farming community's confidence in the new Department to deliver the changes required. Instead of saving money to be spent elsewhere, the creation of DEFRA has cost more than originally planned and this has had knock on effects elsewhere. For example, we understand that, due to lack of staff, the Department is not able to spend all the monies released by the match funding for the original modulation package announced by Nick Brown as part of his New Direction for Agriculture in December 1999.
6.2 We are concerned that DEFRA has suffered in its first year from staff cutbacks and other financial problems caused by the merger. This cuts down its capacity as a fully-fledged environment department. Its capacity to act on a range of big issues, including resource productivity, planning and transport, has also been hampered by the new arrangements. Of the issues that fall outside its remit, the greatest gap is linking its responsibility for energy efficiency with the Department of Trade and Industry's role in championing the development of renewables.
6.3 We see the current Spending Round as critical to how successful DEFRA is in implementing its vision. In particular, it will be hamstrung from the start if the Treasury does not allocate the new money required to implement the vision for agriculture reform set out by the Curry Commission. It is essential that DEFRA gets the opportunity to make this first step-change towards fundamental reform of the farming industrythis could trigger success on other fronts.