Dear Sir/Madam

RESPONSE TO THE ‘FUTURE GENERATIONS’ BILL CONSULTATION.

1)CONTEXT IS CRUCIAL

The proposals in the Bill seem to have been drafted without any reflection on the context in which they will be applied. A very brief historical perspective on the evolution of the public services across the UK and the evolution  of Sustainable Development (SD) policy within the Welsh Government (WG) provides this important context.

i)Public Service.

In a phrase, since 1979 public services have been seen as both part of the problem and part of the solution to our economic, environmental, and  social problems.

The new Conservative Government of 1979 gradually, by the mid ‘80’s, promoted greater centralisation and tighter control of public finances and its commitment to privatisation (PFI, etc) to reduce the role of the state in service provision. The emphasis become one of outcomes and efficiency. This cultural change proceeded almost unchecked, with the most recent expression intensifying the drive for efficiencies and privatisation in the context of draconian austerity measures, which will extend at least until 2019.  The expectation is that public services will ‘do more with less’ and outsource as many services as possible.

As part of the solution public services have been ‘encouraged’ to ensure that the UK is ‘open for business’. This has found expression in the activities of  the  UK Government to make the labour market more flexible (zero hour contracts, part-time employment, more self- employment and a reduction in employment rights), all in the interests of economic growth. The  Department of Work and Pensions has played a crucial role. Before the recession sanctions were consistently at between 130,000 and 150,000 per annum, in the UK. Soon after the financial crash this figure rocketed to 540,000 cases annually,

“partly thanks to toughening regulations , but largely owing to changing mood music, which encourages officials to exploit their existing powers with less mercy, the unemployed are being punished more often” (T Clark, ‘Hard Times’, page188, 2014 ) 

Other regulatory agencies have also played their part, the enforcement of environmental and planning policies have been eased in order to facilitate and enable development to the extent , for example , that County Councillors consider the extraordinary intensification of agriculture as “the modern way”, and “natural “ (Pembrokeshire  Herald, page 13, 1^st August 2014). The impact of increasing nitrate levels on waterways is something to be managed not prevented, not that enforcement is an option given the reduced staffing levels. Affordable housing targets set by Local Planning Authorities, and required by the WG, have reached mythical and comical status as planners know that any attempt to achieve them will be countered on appeal  and likely to be frowned upon by the WG if they delay or inhibited development and growth (the wealth of purchasers adds to GDP, according to one planner).

The role of public services is to support the economic imperative and, as far as possible, ‘mop up’ the mess left behind (poverty, increasing mental illness, obesity, economic and social exclusion and increasing inequality, etc.), with the help of the voluntary and community sectors.

What this history tells us, which should encourage the WG, is that cultural change is possible if there is sufficient political will, a strong leadership and a clarity of purpose.  The downside of recent changes is an erosion of the welfare safety net and public services (both quantity and quality), greater insecurity for many, both employed and unemployed, and an erosion of empathy with and respect for service users, and with that an erosion of trust in public agencies.  This cultural change, its corrosive power, is deeply embedded  across society and is not something that can be easily reversed, if ever!

ii)Sustainable Development: Principles, Central Organising Principle (COP) and Goals.

Since an earlier consultation on the Sustainable Development Bill in 2012 the WG seems to have made very little, if any, progress on developing the concepts underpinning this Bill.  A name change to ‘Future Generations’ makes the subject more accessible, which can only be a good thing. However it is a very real concern that sustainable development was made a statutory commitment  in 1998, and  little has changed, in terms of substance, during the intervening years, except of course global economic, social and environmental  trends that demand an urgent response!

Over  the last 3-4  years SD has been adopted as a COP and you have committed to the view that long-term thinking and decision-makers, (only ‘big decisions’), ‘recognising the connection’ between social justice , economic prosperity, and the management of natural resources’ (written statement 2013), will promote cultural change and help achieve a number of, selective, objectives.

Your chosen principle is a short extract from the long discredited Bruntland definition of sustainable development. You seem unable to recognise what the function of a principle is, which is to guide and direct decisions, and that the phrase you have adopted will not achieve this.

It is difficult how understand how you have arrived at this unconvincing approach when just a few years ago you considered and sought to ‘Welshify’ the 5 UKSDC principles. Rather than seeking to clarify your approach you seem to be enmeshed in a desire to remain as ambiguous as possible. As Thomas and Rhisiart said in 2004 “there is still no fully accepted definition of sustainable development and  no real consensus as to the implications for policy prescriptions”. The same situation pertains now in 2014!

Equally as worrying is a selection of 6 goals that make no reference to bio-diversity or governance and it is unclear what the goals being proposed actually mean. What do  ‘more equal’ , ‘fair share’ , ‘healthier’ actually mean and what resources, mechanisms and policy instruments are you recommending public bodies, including the WG, adopt that will influence them and , crucially , by when? Without clear direction from the WG, clear and realistic targets , and with a timetable of milestones to monitor progress that impact on ALL  decisions, these goals will be meaningless.

It seems to the outside observer that this Bill is yet another example of ‘belief based’, rather than ‘evidence based’, policy making. The cynic would argue that dropping this Future Generations Bill into the unsympathetic maelstrom of public service restructuring, described above,  indicates that the WG is keen to be seen to doing something, anything, but that the initiative , however well intended, is bound to fail. The ‘mood music’ will not change as a result of rhetoric and a ‘light touch’.

2)CULTURAL  CHANGE: REALISTIC?

It is clear that a committed Government can , over time, bring about cultural change. On that basis the desire to do so should not be dismissed out of hand. However, any such proposal has to be convincing, after all there is no point , other than symbolism, in raising expectations knowing they cannot be met.

Without clear evidence that what you are proposing is robust and durable then it is difficult to judge  your proposals. This is a view expressed by PwC in the financial statement; a concern that as there is no baseline data on current cultures and behaviours then the nature and cost  of cultural change cannot be estimated.

There would seem to be a number of questions that the WG needs to answer in order to explain and justify this Bill:

Question 1 :How would you characterise the existing culture and the potential for change?

It is not unknown for public bodies to think long-term and to recognise the connection between social , economic and environmental objectives.  In fact many, if not all, would argue with some confidence that they do this already . As one local planning officer told me in 2007, sustainable development is;

“how the economic, social and environmental interact. It’s what planner do, it’s embedded in planning guidance”. Planning law places a duty on LPA’s to encourage sustainable development”.

I doubt very much if any public body would admit to not thinking long-term, and they could certainly find evidence to prove that they do when making big (important?) decisions.

As to the goals of healthier, more equal, etc, again it would be very easy for public bodies to claim that these goals are implicit if not explicit in their existing  statutory duties, to; ensure the wellbeing of their residents or area, and, to encourage sustainable development, etc.

Question 2: What are the barriers to change and how do you intend to overcome them?

The WG sponsors the recently established NRW, which is an amalgamation of 3 previously existing public agencies. One wonders what lessons were learned about the challenges of encouraging a unifying culture and whether they have been applied to the thinking behind the Future Generations Bill? How will you respond if cultural change is seen as a threat or an unnecessary obligation? There must be a concern that without convincing evidence and inducements the Bill may only receive a token response.

It is important that you are aware of just how strong the resistance to cultural change is likely to be, and the ability of organisations to appear to be doing something, but in fact do nothing. For example, the Local Planning Authorities who insist that their Local Development Plans  encourage sustainable development. When asked by the Local Service Board (LSB) to provide outcome measures the response was that any planning decision contrary to the plan constitutes a reduction in sustainability ! When questioned at an LSB sub-group the planners made it clear that they were using the word ‘sustainable’ to refer to the plan, i.e. the plan was sustainable as long as planning committee decisions conformed to and endorsed it!  This is a quasi-legal use of the term sustainability and has no relevance to sustainable development!!

The challenge for the WG is clear which is to amend your current approach so that: the  principles are clear enough to guide decisions, you explain what you mean by ‘long-term’ and ‘big decisions’ and why, you provide practical examples of  your understanding of the connection between economic, social and environmental objectives, and you set targets for each of the goals so that success can be measured and evaluated.

Question 3 ; How much will change cost?

It is interesting that PwC seem to conclude, in the absence of this information, that change will incur a cost to the WG, yet this may not be the case. Change and restructuring may save money in the longer term, as it has with mutual contracts in Oldham and community partnerships in North Dorset, by working closely with residents. Unfortunately the Principles of Public engagement which the WG launched and promoted in 2011 have yet to have any significant impact.

Question 4: Are your goals amenable to public sector action and intervention?

Where is the evidence that poor health, economic inequality, and poverty, for example, are the result of the  failure of public bodies to think long-term or to understand the link between economic, social and environmental objectives ? Social and redistributive policies are notoriously difficult to implement when opposing ‘market forces’. However public bodies could help reduce economic inequality and in-work poverty by changing wage differentials (the ratio of highest to lowest paid) and public sector wage levels. You could provide healthy food in hospitals for staff, and to patients to help their recovery and as an example to the public. You could use procurement law and recruitment and selection policy in the public sector to provide job and training opportunities for local people?

It  would be naïve not to recognise that current fiscal pressures and the limit to devolved powers constrain your range of responses and potential impact. However in the context of this Bill recent written statements do not encourage confidence. In July 2013 Mr Cuthbert AM said ‘make every effort’ to safeguard the long-term interest of the people of Wales  with regard to health, inequality, skills etc. ’Every effort’ is far from convincing, and sows a seed of doubt about the commitment of the WG to this new policy agenda.

Question 5:Will this cultural change lead to different decisions from those made in the past?

All the evidence to date strongly suggests that the WG is wedded to the notion that economic growth and economic regeneration will enable the ‘evils’ of poverty, etc, to be overcome. To quote Jackson, you are caught in the growth dilemma ( T Jackson, ‘Prosperity Without Growth’, 2009). It is very difficult to see how adopting your very vague understanding of SD as a COP along with thinking long-term and recognising a link between economic, social and environmental objectives will provide an effective countervailing policy and programme of action

It is even more difficult to see how public servants can be expected adopt and advocate a different culture from that which they experience day-to-day. The culture change achieved by  UK Governments over the last 30 years, described above, and the latest episode since 2010, impacts on every public body in Wales, including the individuals who work in them. Organisational culture is a consequence of economic trends  and personal attitudes, values and behaviour, which, currently, are dominated by the economic imperative: our belief in economic growth and competitive consumption. The ultimate test for the impact of the Future Generations Bill would be the response to the following questions:

· Would a proposal to build  £15bn a motorway relief road be rejected?

· Would a decision for the strict implementation of pollution control regulations to reduce nitrate levels in the Haven be approved even if it meant that dairy herd size had to restricted?

· Would affordable homes targets have a better chance of being achieved at the expense of the profit margins of land owners and developers?

· Would pay differentials in the public sector be reduced to 1:10?

· Would a One Planet Development policy be formulated for urban residential developments providing zero carbon construction, kitchen gardens and allotments?

If the answer to these questions is NO, then you will need to explain what specific interpretation of; sustainable development, a long term perspective and understanding of the relationship between economic, social and environmental objectives, you are adopting and recommending, and why?   Without this clarification it would be logical to conclude that the WG had selected an interpretation of SD which enables it to be seen to be fulfilling its constitutional commitment but at the same time continuing with ‘business as usual’ through symbolic and token legislation.

My view is that, at best, you will receive reports that public bodies have made every effort but have had to give priority to short term growth measures and managing public expenditure cuts.

 3)AN ALTERNATIVE APPROACH TO A SECURE FUTURE.

What I have characterised above is a Government, and policy advisers, struggling to  appear to  be doing something that lives up to its statutory commitment to SD, but finding the economic conditions and organisational  cultures unsympathetic and unmalleable. This can be explained by collusion and an addiction to a  collective ‘cognitive dissonance’ whereby you believe that the future you imagine or envision is actually achievable when the real world is completely different. The invitation to the ‘National Conversation’, organised by Cynnal Cymru, expresses this dissonance most clearly. It is couched in terms of ‘The Wales We Want’ as though we have the option to choose a Wales using unlimited resources and unfettered by the harsh realities which will confront us over the next 50 years. This offer is verging on the irresponsible, but not surprising in a world  fixated on consumption

Whatever research and information sources the WG’s policy advisers are drawing on I strongly suspect that it will be material that supports the current policy imperatives ( what the decision takers want in order to deliver their manifesto and promises).  I doubt whether ‘thinking the unthinkable’ is culturally acceptable, yet, as Senge , et al, make clear, it is the inability to ‘see reality’ and the imperative to change that is critical:

“ the signals of threat are always abundant and recognised by many yet somehow they fail to penetrate the corporate immune system response to reject the unfamiliar” (Senge, 2005).

I assume, therefore , that some AMs and WG policy officers are aware of the various respected commentators warnings of the limits and dangers we face and the need to adopt an alternative approach to development (ie , not growth, but doing things better in a way that reduces or dependence of fossil fuels, reuses and recycles resources and protects and minimises the exploitation of natural resources and biodiversity);

-L.Elliott and D. Atkinson argue that “ there has to be an acceptance that the UK has hit rock bottom and needs to change”, (‘Going South’, page 344, 2012)

-The OECD recently predicted 4 decades of stagflation combined with climate change impacts and increasing inequality (July 2014),

-The Ministry of Defence report ‘Global Strategic Trends-Out to 2045’, July 2014, warns of the effects of climate change, pressure on natural resources, the authority of the state diminishing in the face of multinational companies and national loyalty weakening by increased migration.

-D.Runciman, on climate change, “Anyone who thinks that technological innovation driven by market forces will solve this problem is deluding themselves. As yet, climate change hasn’t got politically scary enough: there needs to be a greater threat of violence. That’s the truly scary thought”, 2014.

-D Graeber “ If we want an alternative to stagnation , impoverishment and ecological devastation we’re going to have to figure out a way to start again”, 2014.

-F. Mount, “if you look at inequality of income alone, you will not grasp the full extent of social dislocation in Britain. You must consider also the inequality of treatment and the inequality of respect”, ( ‘The New Few’, page 257, 2012) .

The WG needs to ask itself why growth, with all its costs, is so attractive and for whom? The advocates of economic growth consistently argue that it is the only way to solve our problems, yet these problems persist and deepen as a result of our current model of growth. We can either choose to continue with our current approach, knowing that a crisis is rapidly approaching , or we can take stock and start scenario building in order to identify the steps we need to take to make the transformation to a sustainable and secure future.

Of course this will take political will and strong leadership within the WG, and all pubic bodies, and this may not be forthcoming as the focus is likely to continue to be the economic imperative at the cost of all other imperatives. In the interim, irrespective of the progress of the Future Generations Bill, I would strongly advise that  the WG  set up a ‘Futures Group’. This would be an  internal cross-departmental working group with the task of developing an alternative scenario for Wales and to propose a process for transformation from our current approach.  This group ought to take as its starting point:

- A remit to ‘think the unthinkable’ and challenge myths and assumptions about the benefits of growth.

- Adopt a set of clear SD principles, those of the UKSDC would be most suitable. 

- Appreciate that all decisions have to conform to these principles and that they are inter-related.  ‘Cherry picking’ is not an option.

- A recognition that policy statements and good intentions are not enough to effect change and that all policies are prone to distortion or failure due to the economic imperative and market forces. Therefore robust implementation arrangements are critical to avoid policy failure .

- Commit to clear meaningful objectives, and outputs and targets that are measurable.

- Be realistic about the limits to the impact of public policy. Focus on where public sector action can have the greatest direct impact.

- A commitment to engagement and accountability. Engagement with the public improves policy and service delivery, and accountability increases social cohesion.

- Recognise and draw upon the lessons from, and experiences of, the range of local activities which constitute ‘the seeds of change and transformation’

This work would provide an initial discussion paper focussing on the likely future(s) for Wales which will then stimulate discussion across the country, involving all sectors. The group should produce an interim report within 6 months of being set up and a final report within a year.

Please can you confirm that you have received this response and that you will reply to my questions?

Yours sincerely

Mr C. Mason,  

Public Policy Consultant,

Dip TP, M Litt, MSc