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Green Book Review 2020:Findings and responseCP331November 2020

Green Book Review 2020:Findings and responsePresented to Parliament bythe Chief Secretary to the Treasuryby Command of Her MajestyNovember 2020CP331

Crown copyright 2020This publication is licensed under the terms of the Open Government Licence v3.0 exceptwhere otherwise stated. To view this licence, visit /version/3.Where we have identified any third party copyright information you will need to obtainpermission from the copyright holders concerned.This publication is available at: www.gov.uk/official-documents.Any enquiries regarding this publication should be sent to us atpublic.enquiries@hmtreasury.gov.ukISBN 978-1-5286-2273-8PU3052

ContentsChapter 1Introduction and executive summary2Chapter 2Changes to the Green Book9Chapter 3Appraising environmental impacts17Chapter 4Embedding the changes to the Green Book in appraisaland decision making201

Chapter 1Introduction and executivesummaryContext and Scope of the Review1.1The Government is changing the Green Book and taking additional steps toimprove appraisal. This follows completion of the review announced atBudget 2020 to “make sure that government investment spreadsopportunity across the UK.”11.2The Green Book is the government’s guidance on options appraisal andapplies to all proposals that concern public spending, taxation, changes toregulations, and changes to the use of existing public assets and resources. Itis vital for designing interventions that both achieve government policyobjectives and deliver social value for money - i.e. that maximise the deliveryof economic, social and environmental returns for UK society for everypound of public funds spent. It is supported by detailed HM Treasuryguidance on developing business cases which reflects its principles, and bydepartmental guidance that addresses issues specific to their policy concerns.1.3The review was set up in response to concerns that the government’sappraisal guidance may mitigate against investment in poorer parts of theUK and undermine the Government’s aim to “level up” these areas. This hastherefore been the central focus of investigation, but many of the findingsand the action that the Government intends to take to address them have amuch wider relevance to how appraisal can support decision-makers todeliver their priorities. These changes will therefore turn the Green Book intoa vital tool for progressing the Government’s priority outcomes and widerpublic value agenda.1.4Given the UK’s recent legal requirement to achieve net zero carbon emissionsby 2050 and the 25 Year Environment Plan (2018), the review has alsorevisited the guidance included in the 2018 Green Book on appraisingenvironmental impacts. In addition, the Government has taken theopportunity to refresh guidance on best practice in appraising the impact ofinterventions on equalities.1.5The review has looked beyond the appraisal methodology to include thewider culture surrounding appraisal, how results are presented and theprocess around investment decisions, both in the consideration of individualbusiness cases and in the Spending Review.1Budget 2020, 2020-documents/budget-20202

Process1.6Since the review was launched, HM Treasury has consulted extensively with awide range of stakeholders, including academics, the National Audit Office,the National Infrastructure Commission, analytical experts and users of theGreen Book both in Whitehall and in the Devolved Administrations, theNorthern Powerhouse and regional and local government. HM Treasury hasalso reviewed past business cases to understand how options appraisal iscurrently applied in practice.Overview of findings1.7Our engagement has revealed that stakeholders have very different andoften divergent understandings of the function of the Green Book. Animportant first step is therefore to clarify its role: what it does, and crucially,what it does not do. The Green Book is technical guidance aimed at helpingofficials provide advice to decision makers about how to achieve an explicitpolicy objective and maximise social value. It sets out a rigorous yetpragmatic approach to weighing up the costs and benefits and illuminatingthe key issues, uncertainties and risks to decision makers.1.8The Green Book does not set policy objectives, nor does it determinedecisions. Both the setting and prioritisation of objectives and the taking ofdecisions are rightly matters for elected decision makers, who are not boundby advice made on the basis of a Green Book compliant appraisal2. TheGreen Book instead helps ministers to identify the best way of achieving theirgoals.1.9While the core methodology was not by itself found to skew outcomes, theReview has concluded that current appraisal practice risks undermining theGovernment’s ambition to “level up” poorer regions and to achieve otherstrategic objectives unless there is a step change improvement. Significantchanges are needed to both the Green Book and the way it is used inappraisal to enable ministers and other decision makers to fully understandwhat investments they need to make to most effectively drive the delivery ofthe levelling up agenda and other policy priorities.1.10One of the fundamental issues that the review has identified is the commonfailure of those writing appraisals to engage properly with the strategiccontext in which their proposal sits. Specifically, business cases frequently donot demonstrate the necessary understanding of: the proposal’s specific contribution to the delivery of the government’sintended strategic goals (such as levelling up or net zero); and the specific social and economic features of different places and how theintervention may affect them; Other strategies, programmes or projects with which the intervention mayinteract, including in a particular geographical area.2 Where the minister decides to continue with a course the accounting officer has advised against, the accounting officer should askfor a formal written direction to proceed.3

1.11This results in significant flaws in appraisals and business cases, as well asthe process for local authorities bidding for departmental funding. A failureto thoroughly understand and address the contribution of a proposal tostrategic policy goals leads to a failure to build in strategic direction from thevery first step in the process, the development of the strategic case. Thestrategic case should include well-defined objectives (and for larger projects,these should be clearly linked to government strategic policy priorities), anda robust explanation of how the intervention will deliver the change requiredto meet them, based on evidence. The review has discovered that thestrategic case for many proposals is weak. This means that the first step inassessing options -longlisting- which is designed to identify a range ofoptions that will deliver the proposal’s objectives, is fundamentallyundermined.1.12With a lack of strategic direction now baked into the appraisal process, theselection of the option to be presented as the best becomes heavily relianton a Benefit Cost Ratio (BCR)3 that is not aligned to the decision makers’objectives. The BCR instead focuses on benefits that it is easy to put amonetary value on. This in turn creates an incentive for proposers toartificially boost the BCR with such benefits that are unlikely to be realised, aswell as suggesting a level of certainty around the value of those benefits thatis not merited by the evidence.1.13This means that instead of illuminating the issues that decision makers needto consider, this process creates something of a “black box”. As a result, theminister may have to make a choice about whether to invest in a proposalwithout having a well-balanced understanding of whether that investmentwill deliver their goals.1.14A lack of strategic consideration also causes particular problems indeveloping proposals to support a specific place or places. For example, itleads to confusion about when a project has the potential to deliver impactsthat can bring truly transformational change to a place. In reality,transformational effects are rare and only seen when projects andprogrammes are part of a coherent strategic portfolio designed to deliversuch changes.1.15Central government departments also frequently fail to work together acrossorganisational boundaries and ring-fenced funding streams to develop,appraise and deliver truly “place based” strategy. This means thatinterdependencies between different interventions owned by differentdepartments, and the benefits to a place to be expected from theinterventions working together are not given proper consideration.1.16Finally, there is frequently a failure to carry out robust analysis of impacts indifferent places or to consider them in decision making, even when it isrelevant.3 Total monetisable benefits divided by total relevant costs.4

1.17In addition to problems with the content of business cases, the review hasalso identified considerable room for improvement in the appraisal anddecision-making process. This includes: A lack of transparency around how decisions are taken. Stakeholders havemade the point that it is not often made clear to them the basis on whichbusiness cases are approved, making it harder for them to understandwhat a good business case looks like. It also undermines theaccountability of drafters, reviewers, and decision makers. A Spending Review process which has been challenged for encouragingan inappropriately heavy focus on the BCR. The perception of stakeholdersis that bids are ranked purely by their BCR with adjustments to thatranking made in an opaque fashion. Similar criticisms are levelled at theprocess for bidding into departmental funding pots. A lack of capacity to engage with the full appraisal process, especially themore technical aspects. Many stakeholders in local government feel thatthey do not have the resources to fulfil all of the requirements of acomprehensive appraisal. As a result, the work is often outsourced toconsultants, who may add value in technical aspects of the appraisal, butmay also be less familiar with the strategic policy context of theintervention, and may have been tasked with producing a high BCR ratherthan a properly well-rounded appraisal. This also risks creating a viciouscircle where the use of consultants further erodes the expertise of officials.There are also capacity issues across Whitehall, with a shortfall in thebandwidth, understanding and in-depth experience necessary to carry outconsistent, rigorous scrutiny of business cases. Under-investment in rigorous ex-post evaluation means there is often alack of good evidence on what works to support current policy andprogramme appraisals. Equalities impacts are too often considered as an afterthought rather thanintegrated into the appraisal process.Overview of HM Treasury’s response1.18HM Treasury is introducing a package of actions, designed to deliver a stepchange in appraisal quality. Firstly, we have made changes to the GreenBook to include: A stronger requirement to establish clear objectives from the outset thatmust be the drivers of the policy development and appraisal process looking across departmental and other silos where necessary. Therefreshed Green Book will include clearer guidance on how to set the rightmeasurable objectives at the right level of decision making (strategy,programme, project) in a way that best supports the delivery of thegovernment’s overall strategic ambitions, whether economic,environmental or social. Stronger and clearer advice on what constitutes value for money, how toappraise it, and what information to provide to decision-makers. This willset out the factors which must be taken into consideration, and the5

requirement that only options with a strong strategic case should be shortlisted for detailed cost benefit analysis. The BCR will then only becalculated for options which pass this test. New guidance on the appraisal of transformational changes. This will helpusers identify when transformational change may be relevant, how toappraise transformational potential within the existing Green Bookapproach and how to handle and present uncertainty in this context. Appropriate emphasis on the analysis of place-based impacts, includingfor projects and programmes where these are not the objective of theintervention. There will be a new expectation that appraisal must assessthe likelihood and extent of differential place-based impacts where itappears likely to be significant, or else explain why it is unnecessary. Newguidance clarifies how and when employment effects may be included inbenefits calculations at a UK, and separately, at a place-based level. Measures to improve analysis on differential impacts, including inassessments stemming from the Equality Act public sector equality duty,and under the Government’s ‘family test’. An expert review into the application of the discount rate forenvironmental impacts. This will scrutinise the current guidance onenvironmental valuation and discounting and investigate the case forusing the same discount rate as currently applied to the valuation of lifeand health effects.1.19Secondly, in order to fully embed the lessons from the review, we will takesteps to strengthen the approval and decision-making processes and theculture around the development of business cases: A new approach to the Spending Review process to reflect the findings ofthis review. Early findings of the Green Book Review were incorporatedinto the Spending Review 2020 process. As part of an evidence-basedreview of capital, Departments were asked to articulate clear objectivesand a robust strategic case for each capital proposal, alongside any placebased impacts. This will also apply at Spending Review 2021, whereDepartments will be expected to work-up proposals in accordance withthe guidance in the refreshed Green Book. A new emphasis on the role of business case reviewers as criticalgatekeepers. HM Treasury will reset expectations about the role of thosewho review and scrutinise business cases, both in departments (especiallyon investment committees) and in HM Treasury spending teams. We willstrengthen the use of current reviewers’ training. Reviewers in HMTreasury and across Whitehall will be empowered and equipped toconstructively challenge business cases and appraisals and to work withscheme proposers to bring them up to the required standard at eachstage in the process, before approval is given. More extensive and flexible support for users of the Green Book. This willcomprise more accessible online, bite size training on specific aspects ofthe methodology, and establishing active networks to support those whouse the Green Book, including in local and regional government.6

Greater transparency with a new requirement to publish a summarybusiness case within four months of it receiving final approval. This willbegin in April 2021 for all infrastructure projects and programmes on theGovernment’s Major Projects Portfolio. An ongoing commitment to auditing and reviewing business cases toensure high quality is maintained, identifying weaknesses as they ariseand developing plans to address them through further changes topractices, guidance or training, as necessary.1.20The changes to the Green Book and appraisal process that HM Treasury ismaking should be seen within the wider context of work across Whitehallaimed at supporting improved delivery of government objectives in general,and of levelling up in particular. This includes the agreement of priorityoutcomes for each department, also published at Spending Review 2020.Some of these are closely linked to supporting the Government’s levelling upagenda and many can be monitored at a regional/local level. The delivery ofthese will be a key factor for consideration at next year’s Spending Review,and departments will be required to publish their strategies for deliveringthem as part of the business planning process.1.21As part of this stronger focus on outcomes, the Government is placinggreater emphasis on the importance of high-quality evaluation, which iscritical to understanding what works. In preparation for Spending Review2020, departments provided a detailed overview of their evidence bases andevaluation plans, which have informed the Government’s decisions.Improved knowledge of what truly delivers for citizens over this spendingreview period, supported by a new Evaluation Taskforce, will drive futurechoices.Objectives of the changes1.22The Government’s ambition is that, taken together, the changes will makeimprovements throughout the business case development and deliveryprocess. Applied to the spending review process, to decisions on individualproposals by all levels of government, and to the evaluation of competitivebids by local or regional authorities into funding pots, they will, in turn: Help policy makers understand how to develop interventions and optionsinformed by evidence and that clearly support the delivery of strategicobjectives, including levelling up. They will provide incentives and supportfor scheme promoters to integrate these goals into properly balancedappraisals from the start; Help scheme promoters to better understand the possible impacts of theirproposals in their wider strategic context - including impacts on particularplaces, on the environment and on groups of individuals, including thosewith protected characteristics; Better equip and empower reviewers to scrutinise business cases, and toconstructively challenge proposals that do not provide appropriate data,evidence and analysis or match policy goals; and7

Improve the accuracy, clarity and relevance of advice that decision makersreceive when they take decisions on how best to achieve levelling up, orany other policy objective.1.23Ultimately, this should promote better decision-making in support of clearlyexpressed policy objectives, and improved public confidence in that process.And as a result of the changes set out in this report, including more robustanalysis of transformational potential, including in areas that have beenconsidered as “left behind”, and improving the analysis of regional and localimpacts more generally, the Government would expect future investments tobe better aligned with its ambitions to level up the country.1.24The following chapters set out the changes proposed and their intendedimpact in more detail, starting with changes to the Green Book text, andthen explaining how these changes will be embedded in the appraisalculture and decision-making process.8

Chapter 2Changes to the Green BookDefining value for money for a balanced appraisal2.1A central finding of the review is that some business cases do not have astrong strategic case. They may lack a strong rationale for intervention, aclear objective aligned to government priorities, or robust evidence andanalysis for how different options for delivering that intervention willadvance that objective (a ‘logical process of change’). Partly as aconsequence of this, appraisal advice – and decisions – can rely heavily on aBenefit Cost Ratio (BCR) that is unrelated to a compelling strategic case, inorder to justify the project.2.2While the BCR is a useful metric for capturing quantifiable costs andbenefits, there is a tendency to place an inappropriate emphasis on it, in away that frames value for money as an absolute concept: a proposal with aBCR above a certain arbitrary threshold is seen as offering good value formoney, whereas a proposal that falls below that threshold offers poor valuefor money. Considerable time and effort is expended to ‘boost’ the BCR thatwould have been better spent developing and testing the other elements ofthe business case including its strategic coherence, ris

1.2 The Green Book is the government’s guidance on options appraisal and applies to all proposals that concern public spending, taxation, changes to regulations, and changes to the use of existing public assets and resources. It is vital for de

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