Mainstreaming the environment through appraisal: Integrative governance or logics of disintegration?

IG and policy appraisal

While our focus on policy appraisal links to a very specific subset of IG concepts, it contributes to IG as an emerging concept in several ways. First, the main aim of the IG framework is: ‘explanatory analyses of the relationships and performance of groups of governance instruments’ (Visseren-Hamakers, 2018a). Jordan and Lenschow (2010) argue that one can observe how more integrated decision making works in practice in three different ways: (1) how the process of integration occurs, including how different administrative instruments operate and interact to facilitate coordination processes, (2) the outputs of policy integration in terms of policy produced, i.e. the extent to which the environment has been incorporated into the policy and (3) outcomes in relation to whether there are improvements in physical environment as a result of policy integration. Through examining how a specific set of related instruments operate in practice, we examine the challenges faced by appraisal as a long-established tool to promote more integrated policy making (Jordan and Lenschow, 2008) and the subsequent challenges faced by IG. Appraisal is a particularly helpful focus because much of the existing IG-related literature often concentrates on current policies: ‘While scholarly debates focus on analysing the fragmentation of current governance systems and trying to improve relationships between existing policies, the consequences of this fragmentation for the development of new policies receive relatively little attention’ (Visseren-Hamakers, 2015: 141). A focus on an instrument explicitly intended to operate with policies under development is helpful, especially since policy is rarely developed ‘from scratch’. Appraisal acts as a bridge between existing ideas and potential new ones, encouraging some and rejecting others, and therefore examining how it operates might be particularly fruitful for generating a better understanding integration between policies old and new.

Second, the paper departs from existing studies by examining different institutional ‘logics’ that operate between governance sectors, governance scales, appraisal systems and policy making professionals, and how these can hamper the integration of environmental knowledge into decision making (and ultimately policy outcomes) via appraisal, and hence the instrument’s ability to facilitate more IG. The concept of logics, which draws on new institutionalist ideas examining how formal and informal institutional logics affect behaviour (Visseren-Hamakers, 2018a), helps to provide explanations for some of the challenges faced by those promoting appraisal as a tool of IG.

Third, an important part of the IG research agenda is to examine relationships between different types of instruments from different governance systems and levels, and different policy sectors (Visseren-Hamakers, 2018a). While such analysis could quickly become intractable, focusing on the broad single instrument of appraisal allows consideration of several variants on that instrument, while maintaining a focused empirical remit. The paper examines appraisal in the EU, which has been a pioneer in its approaches to environmental policy integration, specifically through policy appraisal, in all levels of decision making (Jordan and Lenschow, 2008). Some type of appraisal is employed at every level of governance from the European Commission and member states through SEA and EIA in local planning policy and development projects. The paper also specifically examines appraisal in the UK, which has been at the vanguard of attempts to better integrate the environment in decision making (Russel and Jordan, 2009), and has been a leader in developing policy appraisal processes (De Francesco, 2016). The paper’s overarching examination of appraisal as an administrative process thus reveals empirically some of the dynamics and extent of both horizontal (between sectors) and vertical (between governance levels) integration.

Fourth, there is a still unresolved paradox about appraisal. Despite its reputation, studies have shown that in practice appraisal across all governance levels has not consistently operated in a way that promotes integration, either of environmental knowledge into appraisal, or of appraisal into policy, or of policies or sectors themselves (see, e.g. Eales and Sheate, 2011; Morgan, 2012; Turnpenny et al., 2009). We argue that this disparity between the positive reputation of the EU and UK and the more negative critiques of practice make an ideal case study for exploring the challenges faced by appraisal as an important tool for IG.

Finally, much of the IG-related literature is about ‘improving policy coordination’ and proximate causes of the lack of it: ‘IG literature remains rather ‘managerial’ in character, with authors expecting or hoping that enhanced coordination and learning will improve environmental governance performance’ (Visseren-Hamakers, 2015: 141). An important part of the IG research agenda is to look beyond such approaches into more political explanations for integration or lack thereof. By drawing explicitly on institutionalist ideas, and focusing on the operation of a politicized instrument in practice, this paper contributes to this call.

Policy appraisal research

Due to its important role in policy integration, appraisal has become a major area of research in both the public administration (e.g. Dunlop and Radaelli, 2016; Dunlop et al., 2012; Turnpenny et al., 2009) and the environmental social science literatures (e.g. Owens et al., 2004; Russel and Jordan, 2009; Bina, 2007; Bond, 2015). What these literatures have in common is that they explore the use of appraisal as a tool for integrating knowledge into decision making processes, i.e. how far appraisal is typically characterized as a rationalist process, whereby the appraisal generates knowledge about one or many integration priorities which is then used to make adjustments to policy to minimize negative or maximize positive outcomes. The public administration literature has focused more on how appraisal has been used to influence regulatory processes, through factors such as political control, attempts to rationalize the policy processes and minimizing regulatory effects (e.g. Radaelli, 2005; Dunlop et al., 2012). The environmental social science literature has been more concerned with appraisal as a tool for integrating specifically environmental considerations across different policy sectors at different levels of government from the local to the supra-national (Hertin et al., 2008; Russel and Jordan, 2009; Turnpenny et al., 2014). In this literature, appraisal is explored in the wider context of policy integration strategies with a focus on both how far appraisal leads to more integrated decision making processes across policy sectors, and on the interaction of appraisal with other policy integration venues such as inter-ministerial and cabinet committees. The rationale is that ex ante appraisal at the earliest stages of the decision making processes can alert policy makers to potential policy spillovers into cognate sectors and governance systems thus providing the necessary knowledge to facilitate the integration processes. According to Schout and Jordan (2005: 215), policy appraisal is the ‘lubricant’ of policy integration without which there is little or no information for other parts of the policy integration machinery to use in their coordination efforts.

The body of literature on policy appraisal largely shows that while there are clear cases of technical rational instrumental uses of policy appraisal to drive the integration of relevant knowledge into policy making (see Dunlop et al., 2012), many appraisals are used rather symbolically – for example to justify pre-determined policy choices, and/or demonstrate that policy goals have been consulted on – rather than driving policy development in a more integrative direction (Dunlop et al., 2012; Nilsson et al., 2008; Runhaar, 2016). Indeed, policy-level appraisal practice has often had a distinctly mixed impact in facilitating IG, exhibiting well-documented problems with handling environmental impacts (see Adelle et al., 2012 for a review). Similar concerns have also been expressed with programme-level (SEA) (Jenkins et al., 2003; Lee and Kirkpatrick, 2000; Pope et al., 2004) and project-level (EIA) appraisal (e.g. Cashmore et al., 2004; Elling, 2009; Rozema et al., 2012; Wood and Jones, 1997). However, environmental assessments such as EIA and SEA do show a more complex and mixed picture of integrating environment in decision making (e.g. Arts et al., 2012; Runhaar, 2016) than does policy-level appraisal. The importance of politics as a factor affecting the integration process is also clear at these levels (Cashmore et al., 2009; Cashmore and Richardson, 2013; Runhaar et al., 2010).

The wider research programme from which this paper was written sampled 75 policy-level appraisals, 50 SEA documents and 50 EIA documents and found that while appraisal is widely practiced in government from the EU level right down to the lowest level of decision making, practice often fell short of high-level appraisal ambitions. Specifically, appraisals were found be inconsistently used to integrate environmental knowledge into decision making and to ultimately having little impact on final policy decisions (Russel et al, 2014; Turnpenny et al, 2014). These findings are consistent with the patterns in the aforementioned appraisal literature, which has examined appraisal practice since the early 1990s (e.g. see Russel and Jordan, 2007) showing a long established pattern. A key question is why has appraisal often fallen short of expectations as a tool for more integrated decision making?

Appraisal, institutions and logics of integration

To understand the role played by policy appraisal in IG, this paper draws on insights from institutionalism (Peters, 2005). For this purpose, we define an institution as an established or ad hoc configuration of formal and informal ‘systems of rules, norms and cultural systems of meaning that shape the courses of action’ (Scharpf, 1997: 38). In a broader sense, institutions are social constructs. They are also dynamic social entities that over time attain a relatively high degree of resilience (Scott, 2001: 51) and which coordinate behaviour across policy through harmonized perceptions and scripts for action (DiMaggio, 1997; Aspinwall and Schneider, 2000) – thus, they can have strong integrative characteristics and normative cores. Within this definition, we can include appraisal systems and processes as institutions as well as the different sector and governance environments in which they operate.

Crucial to the institutional literature is the idea that different institutional ‘logics’ create the rules around which behaviour and decision making occur. These logics, among other things, help facilitate simultaneous activities, avoid excessive conflict and reduce unpredictability (March and Olsen, 1989: 24), and thus, reduce ‘the time and energy otherwise used on thousands of decisions about how to perceive and evaluate an otherwise unintelligible stream of information’ (March and Olsen, 1994: 253). While over time, the rules and routines associated with the logics of different institutions can change (such as following an acute crisis), they tend to have a ‘surprising durability’ (March and Olsen, 1994: 262), which can give the impression of inertia.

In the literature, important distinctions exist in terms of the underlying rationale of the different logics (Hall and Taylor, 1996), which can range from a more rationally inspired ‘logic of consequence’ that seeks to reduce the transaction costs of actions (Peters, 2005) to a more sociologically inspired ‘logic of appropriateness’ that evolves as social processes, images, symbols and rituals combine to form rules of behaviour which lead to the development of shared meanings (Morgan, 1997: 132). While these logics can in some cases help with the internal coordination of action within institutions, they can in other cases be detrimental to more integrative working between institutions if there is a mismatch between logics. These might be termed ‘logics of disintegration’. Drawing on our empirical work below, and the existing literature, we suggest there are at least four institutional logics of integration which may have hindered IG through all levels of appraisal.

The first logic (I) applies to the policy appraisal instruments themselves, which can have markedly different foci, institutional arrangements and procedural rules depending on the level of governance in which they are operating (Russel et al., 2014). We contend that different logics of integration are at play within appraisals operating at different governance levels, which can limit their capacity to integrate environmental considerations into decision making. The second logic (II) concerns governance differences between sectors with regard to both how appraisal works and how environmental considerations are integrated therein. This logic is based on the premise that different sectors – or governance systems – have their own priorities (which may be different or even antithetical to environmental goals), their own procedures for conducting appraisals, and their own definitions of the problem at hand (e.g. see Jordan and Lenschow, 2008; Peters, 2005). We contend that these differing sectoral logics can impede the horizontal integration of environmental considerations into the decisions made across policy sectors via policy appraisal. The third logic (III) concerns a disconnect between the institutional logic of appraisal, often framed as a rational technocratic process, and that of decision making processes in practice, which tend to operate on a much less linear logic (see Owens et al., 2004). We contend that conducting an appraisal according to technical rational guidelines is a complex procedure given the actual setting in which policy is made and may hamper IG. The fourth logic (IV) relates to differing professional logics. It concerns how the logic of policy appraisal and its application to environmental decision making can mean different things to different people from different professions and governance settings. Drawing on Radaelli (2005) and Runhaar et al. (2013), we can suppose that the logic of an appraisal may vary depending on a person’s professional relationship to the policy process. For example, for an economist, the main logic of an appraisal may be the efficiency of natural resource use. For a civil servant, it may be conforming to formal and informal policy making rules, which may or may not prioritize integration of environment. For a politician, it may be navigating conflicting pressures from conservationists and other important lobby groups, the ‘median voter’ and international commitments. For a business actor, it may be profit maximization, and the extent to which the preservation or destruction of environments affects the bottom line. For a member of the public, it may be more about ensuring decision making protects them against environmental risk. We contend that where these different professional logics are not aligned, they can shape the way actors interact with appraisal, and thus impede how it integrates environmental considerations into decision making.

Logic (I) contrasting integration logics at different governance levels

A clear illustration of the contrasting integration logics at different governance levels can be seen by comparing appraisal in the European Commission and in the UK government. Both of these systems have an integrated approach, which seeks to appraise for many impacts in one process. Thus, the scope for analysis is wide, which can create ambiguities when considering conflicts and trade-offs (e.g. long-term protection of natural environment versus short-term financial concerns). However, European-level decision making has a more strategic and flexible orientation, setting framework targets for member states (e.g. the Water Framework Directive) but not stipulating how these targets should be delivered. In this context, appraisal is arguably more likely to focus on the physical environment and broader macro-economic impacts of the directive. By contrast, member states often have to produce more precise policies to implement both EU and domestic initiatives. In such cases an appraisal has to consider a different range of policy options to implement, meaning that the appraisal not only has to incorporate analysis of how different policy options deliver broader framework objectives (e.g. cleaner air or increased internet broad band coverage) but also the wider impacts of these delivery mechanisms on different societal groups, sectors in the economy and cognate sectors. Thus, there are different decision making logics at these different levels of government, requiring very different appraisal analysis. This means that the impact of appraisal on policy making for example at the national level could well be limited as the broader policy direction of the policy has already been set at the EU level under more macro-level appraisal dynamics. ¹ If appraisal analysis at the national level reveals environmental impacts not seen at the EU level, the actual impact of this analysis on UK decision making is limited as the EU policy direction is already set and the UK is required to implement it (see Russel and Jordan, 2007: 14).

In a similar vein, programme and project-level appraisal (SEA and EIA) in the sub-regions of EU Member States tend to come later in the decision making process:

with something like SEA, it is designed to come out late in the process, making integration of assessments difficult… in practice. [interview A2]

Unlike policy-level appraisal in the EU and UK, which is governed by administrative protocol, SEA and EIA must meet specific legal requirements as enshrined in EU Directives (2001/42/EC and 85/337/EEC). Thus, there is less flexibility in terms of methods and processes used to produce the appraisal, and what impacts can and cannot be covered:

So going above and beyond [legally stipulated process] can be considered [a] risk. There is a fear of EU law compliance; if you are not well versed you can get caught out, and this gets publicised. [A5]

Logic (II) conflicting sectoral policy making logics

Conflicting sectoral policy making logics were particularly observed in UK-level policy making, although similar issues have been observed in relation to IG and policy appraisal in the EU (see Jordan et al., 2008). These differing sectoral logics reinforce the fragmented nature of policy making at the expense of IG. As an interviewee remarked:

Different departments interpret the importance [of integrating the environment into their decision making] in different ways. The [policy appraisal] guidance does look at the level playing field, but there is a different prioritisation of effort in different departments. [A1]

This problem is perhaps exacerbated by the fact that all UK policy-level Impact Assessments must pass through the UK Government’s Regulatory Policy Committee, which has a focus on reducing the regulatory burden of policy on business and can block a policy proposal if this is seen to be disproportionate to the benefits. This, according to some interviewees, ² can create the incentive for efforts to be placed on assessing economic costs and benefits at the expense of the assessment of environmental impacts in appraisals. Similar processes exist in the EU, where the Commission-led Regulatory Fitness and Performance agenda is seeking ‘to reduce regulatory and administrative burden without endangering the achievement of the objectives of the legislation’ (COM, 2015b: 3).

Sectoral logics and resulting institutional fragmentation of decision making is not just an issue that impacts upon policy-level appraisal but is also seen with EIA and SEA. For example, the configuration of the UK planning system is geared towards development, ³ despite the fact that EIA and SEA have an environmental focus. In such a policy making context, development goals can get prioritized over environmental ones meaning that the impact of SEA and EIA on planning processes can be marginalized and often conducted as an add-on to the decision making processes. ⁴ Moreover, planning policy in the UK, which is the responsibility of the Department for Communities and Local Government and delivered by local authorities, is a separate policy domain to, for example, agriculture and forestry, which is the responsibility of the Department of the Environment, Food and Rural Affairs. Hence, the planning system does not address agriculture and forestry. According to an interviewee, this means that:

… local authorities don’t have a say on agriculture or forestry and they are thus talked about in isolation…so local authorities have no need to engage in agricultural policy [in their SEAs and EIAs]. [C1]

Logic (III) appraisal logics of rationality versus the messy reality of policy making

Differences between the logics of policy making and the logics of appraisal were observed in our research. According to one interviewee, rather than a technical rational logic of embedded analysis, appraisals tend to be conducted around existing policy making logics and processes:

If someone has done the appraisal and someone says ‘did you think about x, will you go back and do it again?’ the answer likely be ‘no’ as you may miss your parliamentary slot. [A2]

As a consequence, an appraisal can simply be a tidying up exercise that occurs late in the decision making process, ⁵ which acts as a ‘snapshot’ [D4] of the process rather than a ‘dynamic’ [D4] aid to the integration of environmental knowledge into decision making via appraisal.

The political aspects of appraisal were noted by many interviewees. One interviewee observed:

What is the incentive for the Secretary of State to pay attention to the [policy appraisal]? He is under immense pressure from the Cabinet to not let environmental regulation get in the way of infrastructure development and housing. [B4]

Logic (IV) different professional logics of appraisal and environment

While we were unable to systematically map all different professional logics around appraisal due to the sample size and the diversity of professional backgrounds of interviewees, we did find (in conjunction with Radaelli, 2005; Runhaar et al., 2013) that conflicting professional appraisal logics can create fragmentation of the necessary skills needed for a comprehensive analysis. ¹¹ As one respondent put it:

Projects are being led by specialists. If you want a cross cutting team you have to identify and pay for the time of experts. This creates inbuilt silos. [D2]

Concern was expressed by some interviewees ¹² about the dominance of economics in the appraisal process and the related push for enhanced monetary valuation of environmental impacts at all levels of appraisal, because of the idea that values are not objective but ‘cultural constructs’ [A10]. Thus, while monetary valuations may provide a veneer of scientific fact there are well-documented ethical dilemmas surrounding the quantification of environmental impacts and assessing their costs and benefits (e.g. Pearce, 1998; Russel and Jordan, 2007). Hence, a perceived logic of quantification of the natural environment can mean that appraisal is met with resistance by sceptical decision makers as a matter of professional principle or overlooked because of the limits of professional competence. ¹³

The problem of differing professional interpretations is perhaps enhanced by the different logics of the academic professionals who focus on defining and measuring impacts of decisions on the environment, often from different disciplinary perspectives, and policy making professionals who have to apply environmental knowledge to real-world decision making contexts. As a result, as one interviewee remarked, ‘Those that are not fully involved find it very jargonistic’ [B4]. In the words of another interviewee: ‘There are different terminologies from rival academic camps’ [C1]. For some, the underpinning logic is about following a more analytical approach to environmental decision making, for others it is about promoting agendas and persuading different actors. Thus, appraisal as an integration tool is shaped by these different disciplinary logics, which can impact upon the influence it has to better integrate the environment in decision making processes, again contributing to a logic of disintegration.