Department for Environment, Food & Rural Affairs

Financial Management and Policy Review of the
Royal Commission on Environmental Pollution

2. Purpose and Role of the Commission

2.1 Background information on the origins of the Royal Commission is contained in a research paper by Dr Susan Owens and Mr Tim Rayner entitled "The Role and Influence of the Royal Commission on Environmental Pollution2". The Commission was set up by Harold Wilson in 1970 in response to growing public and political concern about environmental issues. At the time, there was a perception at senior levels within and outside of Government that the fragmentation of responsibilities for environmental issues across Whitehall Departments was working to the detriment of environmental protection. The creation of the Commission was part of a package of measures designed to overcome this lack of a cohesive approach.

Remit as set out in the Royal Warrant
2.2 The Commission's overall purpose was set out in broad terms in the Royal Warrant. This was:

'To advise on matters, both national and international, concerning the pollution of the environment; on the adequacy of research in this field; and the future possibilities of danger to the environment.'

Commissioners were further authorised

'to inquire into any such matters referred to you by one of our Secretaries of State or by one of our Ministers, or any other such matters on which you yourselves shall deem it expedient to advise'.

2.3 The government of the time did not attempt to define purpose more closely, to clarify the scope of the Commission's audience, or to set specific objectives or working methods for the newly created body. This left the Commission substantially free to create its own role, identify its own audience and to interpret environmental "pollution" widely. Subsequent governments have not tried to curtail this freedom.

Current perceptions of purpose
2.4 Within this loose framework, it was possible that perceptions of the Commission's purpose might vary, depending on the standpoints of observers. There was also a likelihood that perceptions had changed over time as the scope and focus of environmental concerns and policies, as well as the institutional and regulatory frameworks had evolved and matured.

2.5 We therefore set out to establish whether there was a common view of current "purpose" across different sectors of the policy community and within the Commission itself; whether people believed that purpose had changed over recent years; and whether there was a perceived need for the purpose to adapt to meet changing circumstances.

2.6 We found there was widespread consensus among different groups about a number of core features of the Royal Commission's purpose. Most interviewees cited the following four elements as encompassing the primary purpose:

to apply a multi-disciplinary approach to multi-disciplinary environmental problems, providing an integrated consideration of the scientific, technical, economic, social and moral implications of environmental issues;

to provide authoritative, in depth analysis of complex environmental problems, framing or reframing available knowledge in novel ways, and providing innovative solutions;

to take a long term perspective of environmental issues;

to provide independent, fearless, and non-partisan advice.

2.7 Other facets cited by many interviewees were:

to bring into political focus, environmental issues that might otherwise be ignored, or which might not readily be identified from within government;

to encompass a broader perspective than any individual Department, delivering a 'joined up' and sometimes mould-breaking overview of complex inter-Departmental issues;

to stimulate policy debate and provide a basis for action at national and international levels, challenging conventional orthodoxies and contributing to changing belief systems of policy makers.

2.8 Additional facets identified by a small number of interviewees, and about which there was some disagreement were:

to draw attention to uncertainties in current knowledge and identify areas where further research is required;

to educate a wide range of people, by raising awareness of environmental issues;

to initiate, promote and steer public debate, testing and developing informed public opinion.

2.9 These findings fit reasonably well with other research on the issue. Susan Owens' work established that the Commission has adopted a variety of different roles over time. The majority of these reflect the purposes outlined above3. Similarly, the Royal Commission's own customer survey carried out in 1997/8 as part of its review of working methods, bears out the main purposes above4. This review showed that the Commission's reports were valued for being in-depth inquiries based on factual evidence, and for contributing to longer-term policy development, providing an authoritative basis for policy-making and debate, and setting new policy agendas or priorities. Both of the above also fit with the Commission's own formal definition of its role as set out in the booklet "The Commission and its work". This states that "the primary role of the Commission is to contribute to policy development in the longer term by providing a factual basis for policy making and debate, and setting new policy agendas and priorities. This requires consideration of the economic, ethical and social aspects of an issue as well as the scientific and technological aspects5".

2.10 The purposes identified to us clearly go much wider than the three elements contained in the Royal Warrant; and of these three, the requirement to comment on the adequacy of research was not seen as significant by the majority of interviewees. We consider in Chapter 7 whether there would be merit in changing the Royal Warrant to reflect these findings or in encapsulating current purpose more clearly in a Framework Document.

Focus of Studies
2.11 There was a feeling among a number of interviewees that whilst the Commission's purpose had changed little over the years, its focus had altered. Some saw studies as falling into three different categories:

2.12 There was a perception that whilst the specific had been prominent some 10 years ago, there had been a shift more recently towards the integrative and the philosophical. This was generally welcomed as making best use of the Commission's particular strengths, and was seen by many as the right direction for the focus of future studies.

Current areas of uncertainty about purpose
2.13 As indicated at para 2.8, there were uncertainties among interviewees about some aspects of the Commission's purpose. In the main, these seemed to be linked to different perceptions of the intended audience for the Commission's work and the intended impact upon that audience.

Defining the audiences
2.14 All interviewees who commented believed the Commission's primary audience to be central government, with the wider policy community (including Parliament and regulatory bodies) and the international policy community (particularly the EU) being legitimate secondary recipients. A significant majority also felt the Commission's work had relevance to a 'wider public' (variously defined but including people in academia, industry and NGOs, and in some cases the general public), and that reaching a wider audience should be given greater prominence. Their argument was that the Commission had a role to play in changing the general climate of opinion in the longer term; and that getting messages across to people outside government could help increase the impact of the Commission's work through adding to the range of voices lobbying the government. If the audience were defined too narrowly, it was argued, the Commission would not maximise its potential to influence. A small minority felt strongly that making the Commission's work more available to the wider public was inappropriate, given that recommendations were directed at government, and was likely to prove an unnecessary diversion of time and scarce resources.

2.15 The Commission's 1993 statement on future strategy declared its intention to put emphasis on making its conclusions and recommendations accessible to a wider public6. The 1998 Guidelines for the Conduct of Studies (see Annex 10) say that public presentation of the Commission relates primarily to achieving the maximum impact for individual reports and disseminating their messages, but also to wider awareness of the Commission and its role. Presumably, the aim of promoting wider awareness relates to an expectation that such awareness would enhance both the value of inputs to its work and the influence of its outputs.

2.16 We look further in the next chapter at what the Commission has done over recent years to improve the accessibility to its work to a wider public, and to maximise its impact, and to what effect.

Disseminating the Commission's advice
2.17 Amongst those who felt that more attention needed to be given to reaching a wider audience, there were differences of opinion as to who should be responsible for disseminating the Commission's advice and how this should best be done. Some felt the Commission itself should do more, but acknowledged the resource implications; others believed there were various organisations better placed to communicate with the public, with whom the Commission might work in partnership. We look further in Chapter 9, on working methods, at possibilities suggested to us.

Participating in public debate
2.18 There was strong support from one industry organisation for giving the Commission a new task of taking a lead role in facilitating public debate on environmental issues. It was suggested the Commission should oversee a Stakeholder Forum set up to consider specific environmental issues. The justification was that the Commission was unique in having sufficient credibility and perceived independence from interest groups to be trusted by the public. Other interviewees were less enthusiastic about this proposition, arguing that the environmental field was already over full with similar bodies and that Commission members were unlikely to have time to devote to such activities. Moreover, they felt that such activities could impair the statesmanlike detachment of the Commission, and drag it into the political fray, and should therefore be avoided.

Advice on adequacy of research
2.19 We understand that, prior to 1991, the Commission - as a separate activity from its main studies - gave advice annually to the then DOE about the formulation of its research programme on environmental protection. Since then it has seen its role on research in terms of drawing attention in its reports to issues on which more information is needed. The Commission's 1993 strategy statement included a paragraph on the importance of the Royal Warrant's reference to research, and said that 'in all our studies...we take care to investigate the adequacy, relevance and implications of current research and development, and where necessary make recommendations about this aspect.' The 1998 Guidelines for the Conduct of Studies say that the Commission 'fulfils its responsibility for advising on the adequacy of research primarily in the context of its studies of other issues'.

2.20 These statements seem rather vague, as was recognised by the Commission when it included clarification of its role on research among its agreed objectives for 1998/9. We understand that action on that objective did not proceed because of the imminent FMPR. The following chapter, on achievements, looks at the impact of the Commission's advice on research, and Chapter 9 on working methods discusses possible options for the future.

2.21 Conclusions: There is widespread agreement among the Commission, Government and the wider policy community about the Commission's purpose and role. Key elements are

  • to apply a multi-disciplinary approach to multi-disciplinary problems, providing an integrated consideration of the scientific, technical, economic, social and moral implications of environmental issues;
  • to provide authoritative, in-depth analysis of complex environmental problems, framing available knowledge in new ways and providing innovative solutions;
  • to take a long term perspective of environmental issues;
  • to provide independent, fearless, and non-partisan advice.

2.22 There appears to have been little change over time in the Commission's perceived purpose, although its focus has altered. There has been a shift away from looking at narrowly defined single issues towards topics that span the interests of several different government Departments (integrative studies) and those which develop new cognitive infrastructures to define and tackle environmental problems (philosophical studies).

2.23 There are some areas of uncertainty about aspects of the Commission's purpose, relating particularly to definition of the Commission's audiences and the range of ways of influencing them, and to clarification of the Commission's role on research. These issues are explored further in subsequent chapters.

2 "The Role and Influence of the Royal Commission on Environmental Pollution". Susan Owens and Tim Rayner
3 Main roles identified by Owens were knowledge brokering (authoritative framing or reframing of available knowledge), enlightenment function (changing belief systems and policy frameworks) persuasive advocacy (pushing issues up the Whitehall agenda) policy entrepreneur (arguing for internally generated concepts such as BPEO) clarifying interest, and providing legitimacy for future regulation (as with GMOs)
4 The Royal Commission initiated a review of its working methods in September 1997. The review comprised two elements: a customer survey (by questionnaire) of 74 people including former Ministers, MPs, MEPs, civil servants, and staff of trade associations and non-governmental organisations; and a comparative study of methods of working of 13 other advisory and deliberative bodies in the UK and other European countries. The outcome was the" Guidelines for the conduct of Commission studies" which were adopted in early 1998. These are reproduced at Annex 10.
5 "The Commission and its work". Royal Commission on Environmental Pollution. 1998.
6 Royal Commission on Environmental Pollution: Statement by the Commission on its future strategy. July 1993

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Published 19 April 2000 / Updated 11 May 2000
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