Does government need a framework like the Better Regulation Principles to raise the quality of its policy decisions on low carbon? Environmental think-tank Sustainability First suggests it does, and has proposed 12 principles that could form the basis of a new framework.
The proposals got their first airing at a meeting in April when representatives from lobby groups, utilities, the finance community and Whitehall were asked to help develop and implement the framework for low carbon interventions.
John Bird, associate at Sustainability First, set the scene with his experience of implementing energy policy. He talked about his surprise at how little formal guidance government departments could call on to provide insight into the how new taxes or levies would affect different groups. That was also reflected later in the discussion when delegates asked whether institutional learning was captured, and is deep enough, in government departments when staff move on.
Most of the representatives at the meeting had experience of slow or incoherent policymaking, last minute changes at the implementation phase, and dramatic changes in policy later on, when the outcome was more or less successful than expected.
That meant Sustainability Firsts’ proposals had an appreciative hearing. But can they be effective? Some suggested that instead, policymakers at Decc needed concrete examples of how their policies had affected different industries.
What did come out strongly from the meeting was that the objectives of a policy should be clearly understood, and if possible quantified. Too often objectives changed during policy development, or were lost sight of during implementation or as they moved to another phase – insulation, P and onshore wind all had examples here. Government needs to understand that there are “other drivers than policy”, especially in the low carbon sector where there may be technology leaps.
In developing policy most people wanted to see better research at an early stage, more use of evidence and especially pilot projects, and more open discussion. But that should be the preliminaries: once policy was formulated it should be possible to move much faster to implementation.
The principles put forward by Sustainability first are:
- No retrospection
- Stability of policy, with well-defined and pre-determined break points
- Underpinned by well-understood cost curve predictability and development of supply chain
- Use economic modelling only where it adds value and explain the assumptions and methodology behind the projections
- Dialogue with Brussels to ensure long term consistency with State Aid regime
- Be clear on the impact on different user groups (eg fuel poor, all-electric households, intensive energy users)
- Contracts may be preferable to legislation
- Price-based intervention often preferable to quantitative targets
- Long term nature of investment requires a cross-party approach
- Learn from previous experience in UK and elsewhere and try to avoid conflicts with the single European energy market
- Progression from even-handed support for new technologies over a clear trajectory to a technology-neutral approach with a common price for carbon
- Keep number of interventions to a minimum and reduce complexity
The proposals did not always get an easy ride from the discussion group. Civil servants working on policy needed strong examples of the effects – intended or unintended – of their policies rather than a checklist, suggested one person, while another said that most civil servants might think that they already had these issues in mind and were unlikely to reach for a checklist when under pressure – not least from the industry – to publish.
Examples such as Better Regulation suggest that such guidelines can be useful once they are “baked in” from the start of the policy process, but clearly they have to have real weight among industry and policymakers.
That is why Sustainability First is looking for help from other groups to implement and publicise the framework. It also needs broad consensus to give it the necessary weight among policymakers and ensure it is does not become a ‘wish list’. Interested parties are invited to provide feedback on the need for a framework, on whether these are the right principles to comprise it, and on how to take it forward.
Download the proposals – titled “Let’s get it right” from Sustainability First’s website