Greening the quangos

Greening the Quangos:Environmental Reporting byNon-Departmental Public Bodies

Submission to the Environmental Audit Committee EnquiryGreening Government 1998-99

Summary 3

1. Why do NDPBs matter? 4

2. The study 5

3. The reports 6

3.1 Department for Culture, Media and Sport 6English Tourist BoardArts Council of EnglandEnglish HeritageNational Lottery Charities Board

3.2 Ministry of Agriculture, Fisheries and Food 7Meat and Livestock CommissionThe Sea Fish Industry AuthorityMAFF Consumer Panel

3.3 Welsh Office 8Wales Tourist BoardWelsh Development AgencyArts Council of Wales

3.4 Scottish Office 9Scottish Tourist BoardHIghlands and Islands EnterpriseScottish Community Education CouncilScottish HomesScottish Enterprise

3.5 Northern Ireland Office 11Northern Ireland Tourist BoardLocal Enterprise Development UnitLaganside Development CorporationAgricultural Research Institute of Northern IrelandFisheries Conservancy Board for Northern Ireland

3.6 Department of the Environment, Transport and the Regions 12The Housing CorporationEnglish PartnershipsRural Development Commission

3.7 Foreign and Commonwealth Office 13British Council

3.8 Home Office 14Community Development Foundation

3.9 Department of Trade and Industry 14Export Credits Guarantee Departmentand Export Guarantees Advisory GroupMonopolies and Mergers CommissionCoal Authority

3.10 Cross Comparisons 15

4. Conclusions 18

5. Ten steps for greener government bodies 20

SummaryNon-Departmental Public Bodies (NDPBs) spend £18.5 billion of government money each year, and are responsible for a huge variety of policy areas from promotion of the arts to support for the meat industry. Despite the Government's general commitment to integrating concern for the environment into decision-making, there is currently no statutory requirement for NDPBs to produce environmental policy strategies or report on them.

This report looks at 29 such bodies, reporting to nine government departments, in order to assess the level and quality of their environmental reporting. It examines those NDPBs whose policies have a significant environmental impact, but who do not have a specifically environmental remit. It concludes that environmental reporting varies considerably, with some organisations showing a commitment to environmental standards in all areas of work, and others not mentioning the issue once. This variation may be explained in part by the lack of guidance from host Departments.

The report ends with ten recommendations for greener government bodies. It calls for greater transparency and accountability in environmental reporting, the establishment of guidelines for environmental reporting by NDPBs, clear lines of responsibility for environmental strategy from Department through to NDPBs, and a re-thinking of terms of reference of these bodies to include the environment.

1. Why do NDPBs matter?The Government has a commitment to integrating environmental considerations into decision-making, at all levels, across the whole government.1 Although there has been considerable discussion about integrating environmental considerations into the work of all Government Departments, less has been said about the next 'tier' of national government: the government Agencies and Non-Departmental Public Bodies (NDPBs). NDPBs alone spend £18.5 billion of government money each year2. Their policies and functions, which range from advising the meat industry to providing grants for arts organisations, have a significant environmental impact. If integration of environment into all decision-making is to be achieved, then we must look at this tier closely.

Although the current trend is toward reducing the number of NDPBs, the amount of government money that they spend has increased dramatically over the past twenty years. Since 1979 the number of NDPBs has fallen from 2,167 to 1,073, and staff levels have dropped by half. However departmental spending in support of NDPBs over that period has increased from just over £3 billion to its current level of £18.5 billion.3 As well as their financial importance, NDPBs have an important role in standard-setting. If the Government is to expect the private sector to develop systems of environmental reporting, Government agencies need to be seen to do likewise.

The Government's 1998 initiative, 'Quangos: Opening the Doors', aims to improve the openness, accountability and effectiveness of NDPBs.4 This process will include reviews of their work every five years. The current shifts toward devolution and regionalisation of government functions, too, provide an opportunity to rethink the role and function of government bodies. Many NDPBs will soon report directly to the Welsh Assembly or Scottish Parliament. Several NDPBs such as English Partnerships and parts of the Rural Development Commission are being amalgamated into the new Regional Development Agencies (RDAs). The changing remit of these organisations provides an opportunity to review the effectiveness of their work, and suggest improvements for the future. New devolved tiers of government mean that NDPBs will be more accountable for the local environmental impact of their work.

1See, for example, 'The Government's Response to Environmental Audit Committee Report on the Greening Government Initiative', November 1998

2'Public Bodies 1998', Cabinet Office, page viii3'Public Bodies 1998', Cabinet Office, page viii4'Public Bodies 1998', Cabinet Office, page vii

2. The studyFor the purposes of this study, Green Alliance has used the Cabinet Office definition of an NDPB: "a body which has a role in the process of national government, but is not a government department, or part of one, and which operates accordingly to a greater or lesser extent at arm's length from Ministers." 5 NDPBs fall into 4 categories: Executive, Advisory, Tribunal, and Boards of Visitors.

This report looks at a number of executive and advisory NDPBs, described as follows:

Executives NDPBs: "These bodies carry out a variety of administrative, regulatory and commercial functions. They generally operate under statutory provisions, employ their own staff and have responsibility for their own budgets ... A number of executive NDPBs are classified as a public corporations for public expenditure control and national accounting purposes."

Advisory NDPBs: "These are generally set up administratively by Ministers to advise them and their departments on matters within their sphere of interest ... Advisory NDPBs are supported by staff from within the sponsor department, and do not incur expenditure on their own account." 6

The purpose of this study is to consider the extent to which NDPBs from all Departments consider the environment when reporting. For this reason, we chose bodies whose policy and functions have an environmental impact, but do not have specific responsibility for environmental policy. So whilst we do not look at the Environment Agency, whose primary responsiblity is for environmental legislation, we do include the Cardiff Bay Development Corporation, whose activities have significant environmental impact.

We chose a sample of 28 NDPBs, reporting to nine different Departments. We aimed for a cross-section, from small advisory bodies through to large executive NDPBs with considerable budgets. NDPBs are not obliged publish an annual report at any particular time of year. We looked at the latest available report, generally for 1997-8 or 1998.

5'Public Bodies 1998', Cabinet Office, page vi6'Public Bodies 1998', Cabinet Office, page vi

3. The reports3.1 Department for Culture, Media and Sport (DCMS)

The DCMS is a small Department with a large number of NDPBs - 36 in total. The DCMS acknowledges the need for consideration of the environment in the work of NDPBs:"Environmental considerations are taken into account during policy and operational reviews, by the Department, its Agencies and NDPBs, where the impact on the environment might be significant... environmental appraisal is likely to feature in the development of policy in the cultural heritage and tourism sectors, and perhaps to a lesser extent for sport and the arts." 7

English Tourist Board (1997-8 annual report)The English Tourist Board states as one of its key objectives "Support [for] sustainable development". Environmental considerations, in the form of action toward sustainable tourism, run throughout the report. They include initiatives such as the Green Audit kit, which encourages small hoteliers to reduce their environmental impact; the South East England Tourist Board's tourism development code offering guidelines and best practice for developers; a yearly Tourism and the Environment award; and special environmental projects to mark the millennium. In addition to these particular projects, discussion of the environment is integrated into all areas of the report.

Work to promote sustainable tourism has been encouraged, and actually required, at Departmental level, beginning with a 1991 task force on tourism and the environment, which outlined a role for the English Tourist Board. This resulted in a number of the initiatives outlined above. The process is ongoing - the Government has recently established a group to review progress, and published a consultation document, 'Tourism - Towards Sustainability'.

Arts Council of England (1998 annual report)The Arts Council report makes no mention of the environment in its report. The DCMS asserts that cultural and heritage organisations have more of an environmental impact than arts and sports NDPBs. However, there are still environmental factors that the Arts Council's report should consider, particularly in relation to its role as grant-giver. For example, it runs a significant capital grants programme, which could incorporate environmental objectives. Any capital spend on buildings or infrastructure should consider energy use, transport needs generated and related environmental costs. There are opportunities, too, to promote the environment through the arts, and this is something that the Arts Council could give attention to in its actions and report.

English Heritage (1997-8 annual report)

7'The Greening Government Initiative', Environmental Audit Committee. Volume 2, p333

Although English Heritage does not specifically mention the environment in its objectives and targets for the year, its report brings out the links between the natural and built environment. Environmental considerations are built into many of its projects, such as the improvements to the Stonehenge site, and its work on urban heritage. However, little mention is made of the environmental impact of its schemes and projects, such as the effects of visitor numbers on many historic monuments under their care. No environmental impact assessments are reported.

National Lottery Charities Board (1997-8 annual report)This NDPB spends money raised from the National Lottery rather than public funds. The environment does not figure in their stated aims and objectives. One of their main grants programmes, 'Improving peoples' living environment', includes grants for environmental issues in the community. However, environmental considerations are not built into the criteria for other grants programmes or the organisation as a whole. Whereas the Board has both a Medical research advisory panel and a Social research advisory panel, there is no equivalent for the environment. A notable exception to this pattern is the International grants programme, which integrates consideration of the environment and sustainable development into its reporting programme.

3.2 Ministry of Agriculture, Fisheries and Food (MAFF)

MAFF has 69 NDPBs in total. In its evidence to the Environmental Audit Committee's Greening Government Enquiry, MAFF suggested that NDPBs should contribute toward green housekeeping objectives, but did not mention the environmental impact of the NDPBs' policies.8

Meat and Livestock Commission (1997 annual report)Despite the considerable environmental impacts of the meat industry, and consumer demand for more 'environmentally friendly' food, the report makes no mention of the environment, or the environmental impacts of its field of work. The Commission runs 'Industry development' and 'Science and technology transfer' schemes which provide support and advice to the industry, and aim to improve competitiveness. These schemes could incorporate projects to promote sustainable agriculture, but do not appear to at present.

The Sea Fish Industry Authority (1997-98 annual report)The Authority's key targets and achievements for 1997-8 include some environmental considerations: primarily conservation, both of fish stocks and of other marine life, and waste management. These aims are well reflected in the body of the report. For example, The Technology Division aims at 'improving the sustainability of fish stocks and awareness of environmental issues'. However, whereas the Chief Executive's report mentions the role of the Authority in helping the industry to adapt to environmental regulation,


the report gives limited examples of this role in action, mentioning only the response to the EU Urban Waste Water Treatment Directive.

MAFF Consumer Panel (1997 annual report)This advisory NDPB is a panel of ten individuals representing the views of ordinary consumers. It aims to bring to the attention of Ministers food issues of concern to consumers. Its report included descriptions of studies undertaken about genetically modified maize, and several other consumer issues with environmental implications. However, as the Panel is led by its members rather than MAFF itself, it may be considered inappropriate to oblige the members to consider environmental implications.

3.3 Welsh Office

The Welsh Office has 51 NDPBs. They employ a total of 2,133 staff with a yearly budget of around £650 million. The Welsh Office acknowledges that individual NDPBs have responsibility for environmental policies:

"The model Code of Practice for Board Members of executive NDPBs in Wales include amongst the important responsibilities of board members a requirement to ensure 'that the board operates sound environmental policies and practices in accordance with the approach set out in the 1990 White Paper This Common Inheritance and other relevant guidance'."9

Responsibility for NDPBs will pass to the Welsh Assembly.

Wales Tourist Board (1997-8 annual report)The Wales Tourist Board does not mention environment in its aims and objectives, although mention is made later of a 'Green Guide' for the tourist industry, produced with the Countryside Council for Wales. A brief mention is also given to an environmental best practice award run by the Wales Tourist Board. Remaining environmental commentary is limited to successes in protection of the coastal environment.

In the section entitled 'Working with Partners' only a brief mention is given to working with National Parks, and this does not include specific reference to the environment.

Given the stated importance of the 'beautiful natural environment' in promoting the tourist industry in Wales, and the apparent effort involved in producing the 'Green Guide', it is surprising that the environmental reporting is so limited.

Cardiff Bay Development Corporation (1997-8 annual report)The Cardiff Bay report concentrates mainly on reporting large capital projects, job creation and levering of private money. No mention is made in the report of environmental concerns, environmental improvements as a


result of the redevelopment of Cardiff Bay, or the use of environmental appraisal in any area of the Corporation's work.

The report could have mentioned environmental benefits in a number of contexts. This could have included the re-use of derelict and possibly contaminated land and partnerships involving European funding from both ESF and ERDF, which may have attached environmental considerations to funding offers.

The report covers a period 10 years into the project, and some of the necessary environmental improvements may have been completed by this time. However, the lack of a holistic overview of the Corporation's work is disappointing considering the significant impacts of such a large infrastructure project on the local environment.

Welsh Development Agency (1997-8 annual report)The Welsh Development Agency includes sustainable development and some specific environmental issues in its aims and targets. There are also a number of brief case studies involving environmental improvement, particularly land reclamation, included in the report.

Although there is no specific chapter concerning environmental improvement, environmental considerations are well integrated. The one area of concern is the concentration on environmental clean-up, rather than fully including environmental considerations into the development process.

Arts Council of Wales (1997-8 annual report)The Arts Council for Wales does not have primary environmental objectives. The report includes two mentions of the role the arts can play in urban regeneration and improving the local environment.

3.4 Scottish Office

In its 1998 Departmental Annual Report the Scottish Office lists its overall aim as "improving the economic, social and environmental conditions in which the people of Scotland live and work." It sets out clearly what it expects of its NDPBs:

"Lord Sewel [Green Minister] has announced that he expects all Scottish NDPBs and executive agencies to adopt sustainable development objectives and targets. This will be done on a timetable and in a manner which accords with the public body's sustainable development impact. Several have already adopted such approaches without prompting".10

The Scottish Office is responsible for 36 executive NDPBs, employing 8,000 people, and 61 advisory bodies. Total spending and support by Government for Scottish Office NDPBs was around £1.65 billion in 1998. Scottish Natural Heritage and the Scottish Environmental Protection Agency both have statutory duties in regard to Sustainable Development.

Responsibility for these bodies will pass to the Scottish Parliament.

Scottish Tourist Board (1997-8 annual report)The Scottish Tourist Board does not mention environment in its aims and objectives, although it is mentioned in the Chairman's Statement, and sustainable tourism and environmental protection are covered elsewhere in the report.

Specific mention is made of the importance of enhancing and protecting the natural environment in order to attract visitors. The report includes an excellent section on partnership with other bodies, such as Scottish Natural Heritage and the National Trust for Scotland, in ensuring "the harmonious


coexistence of tourism development and environmental sustainability".11 An environmental accreditation scheme for tourism businesses has also been launched.

Given the proactive way environmental issues are being addressed by the Board, it is disappointing that it does not feature more prominently amongst its aims and objectives.

Highlands and Islands Enterprise (1997-8 annual report)Achieving environmental renewal is included in the tasks of the Highlands and Islands Network, although each of the 10 separate enterprise agencies include their own yearly list of priorities and targets. Environmental considerations are integrated into most topics covered by the main body of the report. Tourism is particularly well reported, though transport issues, of importance to the Highlands and Islands, are a disappointing omission. Of particular note is the inclusion of a paragraph on the availability to the public of environmental information on the HIE Network.

A page in the report is devoted to each member of the HIE Network. Environmental renewal is one of the four main areas covered in this section. Less impressive are the key priorities for 1998-99 that each body lists, where only three of the ten bodies include reference to the environment, in each case regeneration. Shetland Enterprise, however, makes specific mention of the need to plan for a post-oil economy and include "building community capacity to generate sustainable development" as a key priority.

Scottish Community Education Council (1997-8 annual report)Rather than listing aims and objectives, the Education Council reports under six themes. The importance of the environment to community education is included in sections on active citizenship and social exclusion. The role of community education in urban regeneration is emphasised by the presence of the Scottish Urban Regeneration Forum on the board of the Education Council.

Overall the report is impressive in its coverage of environmental themes, although given the importance afforded it in the rest of the report, reference to the role of the environment in the conclusions would not be out of place.

Scottish Homes (1997-8 annual report)Environmental considerations in the aims and objectives are limited to the inclusion of the word 'sustainable'. Bearing in mind the potential environmental impact of Scottish Homes' remit, the report includes relatively limited coverage. The terms of reference for the body include the effective provision of good quality housing and enhancing the quality of life of the people of Scotland. The role of energy efficiency, and environmental protection and enhancement in this is central, yet each is afforded only two passing mentions.

Scottish Enterprise (1997-8 annual report)11Scottish Tourist Board Annual Report 1997-8, page 20

Scottish Enterprise recognise the environment as an important resource, in the aims and objectives of the report. The term 'sustainable' is used frequently in the report although it is unclear how much the environment is a consideration in using this term. The report includes a section on combining improvements in physical infrastructure with environmental considerations, although this may indicate that the environment is still seen to some degree as a barrier to development.

3.5 Northern Ireland Office

The Northern Ireland Office is responsible for 35 executive NDPBs, employing 18,500 staff, and 25 advisory. They are funded and supported by government to a total of £800 million. The Northern Ireland Office describes its policy toward NDPBs and the environment as follows:

"Specific environmental policy appraisals by such bodies are not yet mandatory; nor is reporting on impacts. Some agencies ... have developed consistent and stringent appraisal and reporting techniques. However, Departments will, in considering application of the new guidelines, be examining the role of such bodies." 12

The Secretary of State for Northern Ireland's aims, as described in the 1998-99 Departmental Annual Report, include conserving and improving the quality of the natural and built environment.

Northern Ireland Tourist Board (1997-8 annual report)The Northern Ireland Tourist Board includes no mention of environmental considerations in its aims and objectives. With the exception of the promotion of cycling holidays, the Tourist Board does not mention the environment in the report, concentrating on the performance of the Board, and mechanisms to attract more visitors.

The lack of environmental information in the report is especially surprising as the Board produced a the document 'Tourism in Northern Ireland - A sustainable approach'13 as recently as 1993. The report described the natural beauty and historic landscape of Northern Ireland as its main attraction.

Local Enterprise Development Unit (1997-8 annual report)The Local Enterprise Development Unit's (LEDU)terms of reference are "To assist in the profitable growth of client businesses and to increase the number of business start-ups, with particular emphasis on those with export growth potential." 14

LEDU lists five main corporate objectives in its report, none of which mention the environment. All objectives could conceivably include an environmental


13Northern Ireland Tourist Board Annual Report 1997/8, page 314'Public Bodies 1998', Cabinet Office, page 96

element, although the omission is particularly disappointing from the sections on 'creating an environment conducive to the set-up of small businesses', and 'enhancing activity within those areas designated as disadvantaged.' The LEDU report also includes a detailed section on performance trends from which mention of the environment is also absent.

Laganside Development Corporation (1997-8 annual report)The Corporation include 'environmental improvement' in the Chief Executive's review, although this statement is not given a supporting context. The Chairman's report refers directly to urban regeneration responsibilities, and goes on to identify four major areas of benefit from the process. Environmental improvement does not feature.

A breakdown of spending on environmental improvement is featured in the expenditure analysis, and the importance of solving environmental problems is mentioned on a number of occasions throughout the report. Partnership with other bodies, including LEDU, is also mentioned.

Although environmental considerations have been integrated into the report, more in-depth analysis would have been beneficial. This could have included, for example, an environmental impact analysis of the new Lagan Weir.

Agricultural Research Institute of Northern IrelandThe Institute mentions environmental protection in its aims and objectives. The report is made up of an in-depth review of current research work. This includes environmental considerations wherever relevant to its work, particularly the need to balance them against other demands on farmed land. There are however, no obvious references to the need for sustainability in farming.

Fisheries Conservancy Board for Northern Ireland (1997 annual report)The report includes three sections not devoted to fishing and fish stocks. Although environment could be better integrated, the report includes a good section on pollution. The report also mentions work in partnership with the Environment and Heritage Service of Northern Ireland. Overall, the report would benefit from a consideration of wider environmental issues in the sections on conservation and protection of fish stocks.

3.5 Department of the Environment, Transport and the Regions

As the lead Department on greening government issues, the DETR has particular responsibility in overseeing the environmental performance of all Departments and NDPBs. They acknowledge this in saying that "Sponsors of NDPBs draw the Department's environmental policies to the attention of their bodies; we are reviewing whether this can be done more systematically." 15 Responsibility for their own NDPBs is described as follows:


"The Department expects its NDPBs to follow, as far is as practicable, its environmental strategy. For example, in 1997, larger NDPBs were asked to establish Green Transport Plans to ensure that there business travel arrangements were 'greener'."16

In 1998 the DETR had 34 executive and 24 advisory NDPBs. Total DETR expenditure in support of NDPBs in was just under £2 billion. Nineteen ninety-nine has seen significant changes in the structure of some DETR bodies, with English Partnerships and parts of the Rural Development Commission (RDC)being incorporated into the new Regional Development Agencies, and the creation of a new Countryside Agency through the merger of the rest of the RDC and the Countryside Commission.

The Housing Corporation (1997-8 annual report)The Housing Corporation regulates the provision of social housing. Although it makes much use of the term 'sustainable', environmental considerations are not explicitly included in this vision. For example, descriptions of its capital grants programme make no mention of funding of environmental improvements - "Our aim is to invest in schemes which meet local priority needs and are cost effective; and to ensure that dwellings are well maintained". 17 The section on innovation and good practice similarly makes no mention of environment. The most striking omission in the report is acknowledgement of the benefits of home energy efficiency, where investment pays social, economic and environmental dividends. The report does cover regeneration of brownfield sites, stating that DETR targets for building on brownfield sites had been exceeded, but without explanation of the environmental benefits of this.

English Partnerships (1997-8 annual report)The Chief Executive's yearly review includes mention of environmental best practice, regeneration, and reclamation of derelict land. Although environmental considerations are mentioned throughout the report, they are not fully integrated. Examples of sections which have an environmental bearing but do not include mention of environmental factors are coalfield regeneration initiatives, and the promotion of 'mixed' communities.

Rural Development Commission (1997-8 annual report)Environmental protection is absent from the aims and objectives of the RDC. Environment is mentioned as an issue throughout the report, particularly in work carried out in partnership with the Countryside Commission and English Nature. Overall the level of environmental reporting is not on a level with the RDC's impact. There is evidence in the case studies that this is a result of poor reporting rather than a lack of emphasis in RDC policy. It will be important for both the Regional Development Authorities, and the Countryside Agency, which take over the functions of the RDC, to consider their environmental performance and reporting in a more systematic way.


17The Housing Corporation Annual Review 1997/8, page 13

3.7 Foreign and Commonwealth Office

The FCO has a limited number of NDPBs - seven executive and three advisory. The British Council is by far the biggest, with a staff of over 6,000 and turnover of £415 million, of which half comes from Government. In its evidence to the Environmental Audit Committee's last Greening Government enquiry, the FCO does not mention a specific policy regarding its NDPB's environmental performance.

British Council (1997-8 Annual Report)The British Council aims to "reinforce the UK's positive role in the international community through cultural, scientific, technological and educational co-opearation." 18 There is no mention of the environment in its statement of purpose, and no general environmental commitments mentioned in the report. However, several British Council sponsored projects in the fields of science and development have an environmental focus - these include a seminar in Hong Kong on the theme of urban sustainable development, a university link on the subject of environment and energy consumption, and a university research project assessing the impact of logging on rainforests. Given the commitment to environmental issues demonstrated in particular projects, it is surprising that this is not reflected in the report as a whole, in the form of an overall environmental statement or commitment. Such a commitment does exist for equal opportunities within the British Council.

3.8 Home Office

The Home Office has just 12 executive NDPBs, and ten advisory. It has established detailed recommendations to NDPBs on environmental policy:

"The revised environmental strategy will be a two tier policy with the larger Agencies and NDPBs expected to develop their own strategy along similar lines to the Home Office model. Smaller Agencies and NDPBs will be given the option of either being incorporated in the Home Office strategy, or developing their own... NDPBs or Executive Agencies will be expected to consider the environmental impacts of any policy or programme for which it has responsibility and the advice circulated to Home Office policy makers will be copies to Agencies and NDPBs which have appropriate responsibilities... the arrangements for reporting performance on environmental issues for each Agency and NDPB will vary according to their size and environmental impact, but most will be expected to cover the issue in their Annual Report." 19

Community Development Foundation (1997-8 report)The Community Development Foundation aims to develop and promote informal activity in local communities. The environment does not figure in the Foundation's 'indicators of success' or mission statement, neither does it appear in descriptions of their work in economic regeneration in their

18British Council Annual Report 1997-8, page 119'The Greening Government Initiative', Environmental Audit

Committee. Volume 2, p349

description of 'working with communities'. However, the section on 'best practice' has a detailed description of co-operation with the environment movement on Local Agenda 21 issues to promote community involvement in LA21, including a report published by the Foundation, 'Environment for Everyone'. It cites this work as one of its main achievements for 1997-8. In addition, it includes a separate section to the report entitled 'Sustainability, the Environment and Community Development: Working with Communities', which again discusses the publication 'Environment for Everyone'.

3.9 Department of Trade and Industry

The Department of Trade and Industry has 26 executive and 24 advisory NDPBs. It states that "In terms of reproting on environmental impacts and performance, Executive Agencies and NDPBs are free to include this in their Annual publications",20 though the DTI does not require or suggest that they do so.

Export Credits Guarantee Department (ECGD) & Export Guarantees Advisory Council (EGAC)These bodies, which report to the DTI, aim to "help exporters of UK goods and services to win business, and UK firms to invest overseas, by providing guarantees, insurance and reinsurance against loss." 21 Despite providing assistance to UK companies involved in large-scale capital projects overseas, such as steel mills and road projects, there is very limited mention of the environmental impact of these projects or of the ECGD's work. The report on one project, the Jiangyin suspension bridge in China, mentions that funding for environmental and social studies was provided by the Department for International Development. The only other mention was a report on discussions in progress about how to encourage Export Credit Agencies "to consider the environmental impact of projects whilst respecting the rights of host countries to make decisions and enforce environmental standards in thier own jurisdiction".22

ECGD's lack of environmental standards in its annual report is in direct contrast to the report of the US Export Credit Agency, Ex-Im Bank. The US Agency sets out environmental procedures and guidelines for US exporters, with both qualitative and quantitative targets. If companies fail to meet these targets, the Agency's Charter authorises the withholding of financial support. It also works to support particular export sectors seen as environmentally beneficial.23

Monopolies and Mergers Commission (1997-8 annual report)The MMC has a highly complicated and broad remit, and environmental reporting may be limited to specific cases. However, it is disappointing the

20'The Greening Government Initiative', Environmental Audit Committee. Volume 2, page 143

21ECGD Annual Report and Trading Accounts 1997/9822ECGD Annual Report and Trading Accounts 1997/98, page 3223Ex-Im Bank, the US Export Credit Agency Website (www.exim.gov)

environmental considerations do not warrant a single mention in the report despite the presence of an environmental specialist on the board.

Coal Authority (1997-8 annual report)Environmental considerations are mentioned in the aims and objectives of the Coal Authority, though they are not given the same standing as efficiency, effectiveness and economy. Despite appearing as a secondary consideration, environmental issues are integrated into nearly all relevant sections of the report, as well as being the subject of a specific chapter. Partnership work with SEPA and the Environment Agency is also mentioned.

Specific absences in the report include the environmental impact of mining schemes, as opposed to environmental issues in the clean-up after mining has ceased. Environmental considerations are also absent from the section on the coalfield regeneration.

3.10 Cross-comparisons

This section compares the environmental reporting of different bodies responsible for similar policy areas. In many cases, similar organisations report to different Departments. For example, whereas the English Tourist Board reports to the DCMS, the Scottish, Welsh and Northern Irish Tourist Boards report to their regional Departments. This results in different approaches to reporting.

TourismThere are individual tourist boards for England, Scotland, Wales and Northern Ireland. The natural environment, and its protection, is clearly an important element in attracting visitors, and this is the primary objective of these organisations. However, the boards give vastly different importance to the reporting of environmental concerns.

The English Tourist Board reports environmental considerations, particularly sustainable tourism, in a proactive and informed manner. It reports the move toward sustainable tourism as something which much be continually strived for, rather than a process achievable in a year. This contrasts sharply with the Northern Ireland Tourist Board which produced its own guide to sustainable tourism in 1993, but included no reference to the environment and its protection in the 1997-98 report. The Scottish and Welsh reports both mention environmental considerations without fully integrating them.

If the UK is to improve levels of sustainability in tourism, then there is a need for shared environmental responsibilities and improved co-ordination between the tourist boards.

Development and regenerationRegeneration is an area of policy which has been largely given over to implementation by NDPBs. Although there are exceptions, this appears to have led to a view of environmental reporting as being mainly confined to countryside protection. There is little mention in any of the reports covering

this area (including Scottish Homes) of the importance of energy efficiency in buildings, the use of passive heating, or environmental appraisal of large projects.

Local: We looked at two local regeneration NDPBs: Cardiff Bay Development Corporation and Laganside Development Corporation in Northern Ireland. They report little or no recognition of environmental impact. This is particularly surprising given that some of their actions have been beneficial to the environment. An example of this would be the clean-up of derelict or contaminated land which seems likely to have taken place but is not mention in either report. These Corporations may be missing an environmental 'good news' story.

Regional: Regional regeneration bodies, such as Scottish Enterprise, generally include details of environmental concerns in their reports, but it is still a secondary consideration after jobs and the economy. This is surprising given the role of regeneration in shaping communities and their environment.

Environmental considerations have been included in the mandate of Regional Development Agencies, but this will fall short of objectives if environmental considerations do not feature in individual projects.

AgricultureThere is a clear relationship between agriculture and the environment which is not always reflected in NDPB reporting. The Meat and Livestock Commission does not report on the environment as part of its work, whereas the Macauley Land Use Research Institute (Scottish Office), which deals with both arable and pastoral farming includes in depth research on sustainable agriculture in its report. Elsewhere, most notably in the case of the Agricultural Research Institute of Northern Ireland, there is superficial recognition of the importance of environmental considerations in agriculture with little in the way of reporting to back them up.

CultureMany NDPBs with a cultural remit, such as the Arts Council and the British Council, do not consider environmental responsibilities as part of this remit. The Scottish Community Education Council is the only culturally-related body in this study which made a sustained attempt to mention the role of the environment in community activities. In contrast, English Heritage, which is responsible for cultural heritage, had a more developed sense of environmental responsibility. Parnerships between these organisations could help here.

PartnershipAs well as vertical information flow between Departments and NDPBs, information should also flow horizontally, between NDPBs. Successful examples of this include the joint production of a 'Green Guide' by the Welsh Tourist Board and Countryside Council for Wales, and the mention of work between the Coal Authority, the Scottish Environmental Protection Agency and the Environment Agency.

However, given the specialist nature of much of the work carried out by NDPBs, there is further scope for reporting where they have worked together. This could include work on an environmentally related projects or attempts to reduce environmental impacts. Much could also be done to share best practice on environmental policy and reporting.

4. ConclusionsOur analysis of 29 government bodies shows a very variable level of environmental reporting. Some organisations, such as the English Tourist Board, integrate the environment and considerations of sustainability into their report, both in their stated aims, and through examples. Other NDPBs whose activities have a significant impact on the environment - the Meat and Livestock Commission and the Cardiff Bay Development Corporation, to name two - do not mention it at all.

Reporting and practiceIt is important to distinguish between environmental reporting and actual practice. It may be that some NDPBs are exemplary in their consideration of the environment, and carry out detailed assessments, without publishing their findings in their annual report. If this is the case, they are missing an important opportunity for demonstrating their environmental commitment, and setting standards for industry and other government organisations to follow.

NDPBs reporting obligations are set out in Cabinet Office Guidance, 'Non-Departmental Public Bodies - a Guide for Departments', publishes guidelines for reporting, stating that 'Annual reports and accounts will provide the main means for disclosure for information about an NDPB's activities'24. However, specific obligations are restricted to financial information. Besides this, NDPBs do not have obligations to report in a particular way, or at a particular time. Whilst allowing NDPBs the flexibility and distance from Government that they need to carry out their functions, we feel that there is a need to lay down more detailed standards for reporting. This should include guidelines for environmental reporting, in order to allow transparency and accountability, and is particularly important given the massive spending powers of many NDPBs.

Accepting responsibility for the environmentNDPBs are specialised bodies, and focus on very specific policy areas. For this reason, many NDPBs without particular environmental remits, such as the Arts Council or those aiming to promote enterprise, may feel that the environment is beyond their field of responsibility. However, this is not the case. There is widespread acceptance that the environmental impacts of all sections of government, from agriculture to defence to export promotion, must be considered. This is the rationale behind the 'Green Minister' system, whereby a named Minister takes responsibility for his or her Department's impact on the environment, both in policy terms and in operations, or housekeeping issues. There is a need to explicitly include NDPBs in this drive toward integration of environmental considerations into all policy areas.

Guidance from host Departments

24'Non-Departmental Public Bodies: A Guide for Departments' Cabinet Office and HM Treasury, 1992, rev. 1996, chapter 8

Our study has shown difficulties in the relationship between host Departments and NDPBs. Responsibility at Departmental level for environmental performance of NDPBs sponsored by that Department is far from clear. The Green Minister has no clear responsibility for NDPBs. Some Departments do not consider that they have a responsibility to offer guidance on environmental practice - the Department of Health, for example, writes "The Department has not consulted with, or offered guidance on environmental strategies to, the numerous NDPBs it sponsors". 25 Others, like the Welsh Office, have set requirements in place, such as responsibility for environmental policies and practices being placed among the responsibilities of board members, as stated in the Code of Practice for Board Members.26

Given the specialist remit of many NDPBs and their staff, these bodies may not have the internal capacity to carry through proper environmental policy and practice. The host Department must offer them guidance and expertise to that they can understand how to consider, and report on, the environmental impacts of their activities.

Other agenciesAlthough this study was limited to NDPBs as defined by the Cabinet Office, these conclusions, and the recommendations below, may also apply to other Government bodies, such as Next Steps agencies, including the Highways Agency, the Benefits Agency and the Prison Service.

25The Greening Government Initiative', Environmental Audit Committee. Volume 2, p334

26The Greening Government Initiative', Environmental Audit Committee. Volume 2, p388

5. Ten steps for greener government bodiesThis report highlights a need to standardise and improve environmental reporting of Non-Departmental Public Bodies, in order to improve accountability and fully integrate consideration of the environment into all sectors of government. Green Alliance recommends the following steps:

1. In the interests of transparency and accountability, both executive and advisory NDPBs should publish environmental information in their annual reports, making this information available to the public.

2. The current initiative promoting openness and accountability in Government bodies27 should include recommendations for environmental performance and reporting. The Cabinet Office Guidance covering NDPBs28 should be revised accordingly. Accountability should be seen in its wider sense to encompass environmental as well as financial accountability.

3. These guidelines should ask NDPBs to report on how their policies and practice impact on the environment, and what measures are taken to lessen environmental impacts. The guidelines should be sector-specific where necessary.

4. Reporting should cover both policy and operations. It should include green 'housekeeping' measures, or greening operations, such as energy efficiency, staff transport use and recycling. Departments' obligations to promote green housekeeping should be extended to their NDPBs. It should also include environmental impacts of the organisation's policy and programmes.

5. The terms of reference of new NDPBs must include the pursuit of sustainable development, according to the Government definition29, and maintenance of environmental standards amongst primary aims. Ongoing reviews of the remit of existing NDPBs should include changes to their terms of reference to include this aim.

6. Each NDPB should nominate a senior employee to hold responsibility for the environmental performance of the organisation. Environmental issues should be overseen by a nominated board member.

7. Green Ministers should be given clear responsibility for ensuring that NDPBs reporting to their Department carry through their environmental obligations. NDPBs should also be asked to implement the guidance outlined in 'Policy Appraisal and the Environment'30 and subsequent guidance.

27'Quangos: Opening the Doors', 199828'Non-Departmental Public Bodies: A Guide for Departments' Cabinet

Office and HM Treasury, 1992, rev. 199629Using, for example, the definition of sustainable development in the

forthcoming Government Sustainable Development Strategy.30'Policy Appraisal and the Environment', Department of the

Environment, 1990

8. Central government should provide guidance and expertise for NDPBs to help them improve their environmental performance and reporting. This could come from the host Department; additionally the Sustainable Development Unit of the DETR could provide technical advice and support on greening operations and policies.

9. NDPBs operating in similar policy areas - such as regional tourist boards, or those responsible for economic development - should co-operate to promote best practice in environmental policy and reporting in their sector.

10. The environmental performance of all Government bodies, including NDPBs and Next Steps Agencies, should be the subject of continuing scrutiny by the Environmental Audit Committee.

Green Alliance, May 1999

Documents

Greening the quangos