Rural Proofing in England: A Formal Commitment in Need of Review

Rural Proofing in England: A Formal Commitment in Need of Review

Jane Atterton



Centre for Rural Economy Discussion Paper Series No. 20


November 2008







Summary

The Government launched its formal commitment to rural proof all domestic policies in the 2000
Rural White Paper. However, since then, progress with rural proofing has been patchy and
inconsistent across Government Departments. There have been some notable successes, such as
the rural proofing of the 2002 and 2004 Treasury Spending Reviews, but in the main rural proofing is
not well embedded into Departments’ policy making processes and tangible outcomes from rural
proofing activity have been disappointing. Following the Modernising Rural Delivery Review and
2004 Rural Strategy, a greater range of organisations are involved in rural policy delivery at regional
and local level, but confusion remains about their different responsibilities with regard to rural
proofing. At a national level, the roles of Defra and the Commission for Rural Communities (CRC)
shifted following the Natural Environment and Rural Communities (2006) Act. Defra has taken on
the role of rural proofing ‘champion’, yet it has become increasingly pre-occupied with climate
change and sustainability issues. In 2007, in its role as ‘rural watchdog’ with responsibility for
monitoring rural proofing, the CRC called for a review of rural proofing. This paper examines the
process of rural proofing and, with reference to the shifting policy and institutional context for rural
affairs, reviews its history and success drawing particularly on the annual reports produced by the
Countryside Agency/CRC since 2001. It then discusses the future for rural proofing in the context of
the Government’s mainstreaming agenda, and draws on the recent rural proofing review to
suggest ways in which rural proofing activity may be strengthened.










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Introduction

The Government’s formal commitment to rural proof all of its domestic policies – in short, to ‘think
rural’ when developing and implementing policies - was introduced in the 2000 Rural White Paper
(DETR/MAFF, 2000), and was subsequently refreshed in the 2004 Rural Strategy. While individual
policy makers have responsibility for undertaking rural proofing as they design and develop policies
within their Government Departments, Defra acts as rural proofing champion across government,
and the CRC (and prior to that, the Countryside Agency) is responsible for independently
monitoring rural proofing progress by Government Departments and Government Offices in the
Regions (GOs), most notably through the production of an annual rural proofing report. Although
there have been some rural proofing successes, these reports note inconsistent progress over the
last seven years.

In its 2007 report, the CRC argued that “the importance of rural proofing has not diminished” and
that it should be “re-established” (CRC, 2007a, p.2-3), and it called for a review of the process.
Alongside this, Defra has also recently been reviewing all of its activities and policies, including rural
proofing and mainstreaming, the latter being an agenda which has been gathering pace across
Government. Mainstreaming refers to the need for rural circumstances to be considered as part of
everyday policy making and not separately throughout government. Recently, however, rural
issues have fallen off the national political agenda as the attention of Defra civil servants has
increasingly been focused on climate change and sustainability debates (Ward and Lowe, 2007).
Regionally and locally, the institutional set-up and responsibilities for delivering rural policy have
become ever more complex.

Almost eight years since it was formally launched, and given this shifting institutional and policy
context, this paper provides a timely review of the process of rural proofing and its achievements
since the 2000 Rural White Paper. Sections 2-4 describe what rural proofing is, how it is done and
who it is done by. Section 5 reviews progress with rural proofing drawing on the evidence
contained in the annual rural proofing reports produced by the Countryside Agency and CRC.
Finally, Section 6 discusses how rural proofing may develop in future, with reference to the
mainstreaming agenda.

What is rural proofing?

At the time of the 2000 Rural White Paper there was a long-standing charge against the
Government that it did not adequately ‘think rural’ when developing and implementing policies
(DETR/MAFF, 2000). The Labour Government elected under Tony Blair was regarded by many as
being particularly insensitive to rural concerns (Lowe and Ward, 2001, p.389; Ward and Lowe, 2007).
In recognition of this, the 2000 Rural White Paper contained a ‘clear and continuing’ formal

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commitment for the Government to undertake systematic procedures to ensure that all of its
policies, programmes and initiatives, both nationally and regionally, take account of rural
circumstances and needs. Therefore, as part of the policy making process, through from design to
delivery, policy makers should systematically ‘think rural’ by:


Considering whether their policy is likely to have a different impact in rural areas, because
of particular rural circumstances or needs;

Making a proper assessment of those impacts, if these are likely to be significant;

Adjusting the policy, where necessary, with solutions to meet rural needs and circumstances
(DETR/MAFF, 2000).

The Rural White Paper gave the Countryside Agency a rural proofing monitoring and reporting role,
backed up by national and regional sounding boards bringing together rural interests. This role as
rural watchdog represented a significant and high profile role for a statutory body, and a role that
had the potential to ensure that rural issues were not overlooked, but rather were at the heart of
Whitehall policy making (Lowe and Ward, 2001, p.389). Government Departments and GOs were
charged with providing evidence of rural proofing activity to the Agency for its independent
annual rural proofing report.

Each Government Department has a designated central contact to co-ordinate rural proofing
activity. The White Paper made provision for regular meetings between this contact and
Countryside Agency staff and suggested that, where possible, Departments should undertake rural
pilots of programmes and policies and develop targets and monitoring systems for key
programmes to identify their rural impacts. Policy makers would be equipped with improved rural
policy and skil s awareness through training and secondment activities (DETR/MAFF, 2000). The
White Paper also confirmed the need for the Government to take full account of the rural
dimension at regional level and that GOs would work in partnership with a range of organisations in
delivering rural policies and programmes and in ensuring a more co-ordinated approach to rural
data and information col ection and sharing (ibid.). GOs were charged with providing an individual
annual rural report to central Government and collectively reporting on the regional implications of
national rural policy developments, drawing on the Countryside Agency’s regional offices for
advice where necessary.








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How policies are rural proofed

Following the 2000 Rural White Paper, the Countryside Agency produced a policy makers’
checklist, providing a systematic framework for rural proofing (Countryside Agency, 2002a)1. The
checklist should be applied from the early stages of policy making, although it may also be used
during implementation and evaluation. It is designed to act as a screening tool, and contains a
series of questions for policy makers to work through when designing a policy and some
considerations for appropriate rural adjustments, with a suggestion that they contact the
Countryside Agency for advice when necessary. For example, the checklist asks whether a policy is
likely to cost more to deliver in rural areas where clients are more widely dispersed or economies of
scale harder to achieve. If so, it suggests that policy makers might wish to consider solutions such as
higher unit delivery costs in funding formulae (e.g. a ‘sparsity’ factor) or encouraging joint provision
to reduce costs. The results of any policy appraisals that take place (including solutions adopted)
should be fed into the decision-making process and details should be included in the Department’s
annual rural proofing report.

However, the checklist has two important limitations. First, it only covers the more typical policy
challenges presented by rural areas, raising questions as to how a single checklist can account for
the huge diversity of circumstances across rural England. The need for more than a national ‘one-
size-fits-all’ approach was recognised in the North East in 2005, for example, when a regional task
and finish group met to develop rural proofing toolkits for the different sub-regions (Northumberland
Strategic Partnership, 2006). Second, the checklist is not a substitute for consultation with rural
communities, businesses or organisations. This limitation reflects a major criticism of the checklist:
that it is nothing more than a ticklist exercise for Government Departments that does not require a
real, in-depth consideration of the challenges that rural areas present. Yet undertaking such a
consideration demands that policy makers have adequate training, advice, information and
guidance on rural proofing and that they have access to reliable and appropriate evidence on
the situation in rural areas.

The checklist also raises two fundamental questions about the process of rural proofing. First, it
states that if the policy impact is likely to be significantly different in rural areas, policy options to
produce the desired outcomes or avoid/mitigate any undesirable impacts should be explored. But
who decides if an impact is ‘significantly’ different and how is that decision reached? The checklist
also states that “This exercise may also highlight opportunities to maximise positive impacts in rural
areas” (Countryside Agency, 2002a, p.5). In her Foreword to the 2003/04 rural proofing monitoring
report, Pam Warhurst (Acting Chair of the Agency at the time) noted that “Often policies are being
amended or refined to take account of rural issues; to try and ensure that rural communities or

1 A range of other guidance has been produced for organisations operating in other sectors drawing on the Agency’s
checklist (see for example, the Improvement and Development Agency and Rural Stress Information Network websites;
NCVO 2007; SOLACE and CRC, 2005).

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areas benefit” (Countryside Agency, 2004a, p.2, italics added). Is rural proofing therefore about
favouring rural areas? Would that be fair to urban areas? Or is it about ensuring that the impact of
a policy is neutral or, at the very least, not negative, for rural areas?

Who does rural proofing?

Ultimately, the responsibility for rural proofing lies with policy makers working to design, develop,
implement and evaluate policies in their respective Departments. They are therefore expected to
have some knowledge of rural issues to be able, at the very least, to recognise policies that may
have a differential impact, although assistance is available from designated Departmental rural
proofing contacts and from the CRC (and formerly the Countryside Agency) as required. The 2000
Rural White Paper gave responsibility for monitoring rural proofing to the Countryside Agency
through the production of their annual report on the work of Government Departments and GOs.
The Cabinet Committee on Rural Affairs (established prior to the 2000 White Paper) was intended to
play an important role in overseeing the development and implementation of the Government’s
policies on the rural economy and rural communities and in driving forward the rural proofing
agenda, but it was wound down. The Rural Affairs Forum for England (formally established in
January 2002 but replaced by new arrangements, proposed in the Haskins Review and confirmed
in the Rural Strategy 2004) also had a role in rural proofing at the national level, through its role as a
‘national sounding board’ with direct contact with a range of rural groups and the Regional Rural
Affairs Forums (RRAFs).

Four years on, the 2004 Rural Strategy and Modernising Rural Delivery (MRD) Review offered an
opportunity to review progress with, and re-emphasise the importance of, rural proofing. It also
represented a challenging time for rural proofing with a larger range of organisations involved in
rural policy making and delivery locally and regionally, and organisational restructuring at the
national level, with the demise of the Countryside Agency and the establishment of the much
smal er CRC. As set out in the Natural Environment and Rural Communities (NERC) (2006) Act, CRC
and Defra responsibilities in relation to rural policy development and implementation changed,
including with respect to the process of rural proofing. Together, Defra and the CRC have a shared
objective to realise the Government’s commitment to rural proofing and to promote the concept
and practice across a wide range of organisations including local authorities and other bodies and
sectors. However, the onus is stil very much on policy-makers nationally, regionally and sub-
regionally to ‘do’ rural proofing. The NERC Act gave the CRC a rural watchdog role, with a
widened rural proofing monitoring role, enabling the CRC to both advise on and judge how the
rural proofing process is undertaken by organisations as they develop their strategies, and to
provide Government Departments and other bodies with an impartial, expert view on the way in
which their policies are meeting rural needs. The CRC was also given a role in providing some
leadership for rural proofing, in proactively developing it, in independently advising and

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challenging Departments on specific issues or policies, and in promoting rural proofing outside
government, for example to the private and voluntary sectors.

Defra’s roles as set out in the NERC Act are to champion rural proofing within Government and to
take the lead on setting and promoting rural proofing policy to Government bodies at all levels.
Defra’s other role is to advise colleagues across Government (again at all levels) on how to deliver
their rural proofing responsibilities most effectively and how best they can support delivery of the
Government’s rural agenda. The GO rural leads deliver these responsibilities on behalf of Defra
below the national level, and they also have a function to rural proof the activities of all the
organisations with a part to play in the regional delivery framework, including Regional
Development Agencies (RDAs) and Regional Assemblies. Sub-regionally, the role of local
authorities is to rural proof “all policies to ensure that they can be delivered locally”… and to “feed
back local issues to regional Government” (Countryside Agency, 2004b, p.2)2. Rural Community
Councils also have a role in feeding the views of local rural residents and others into the process of
rural policy making.3

What has been achieved since 2000?

The Countryside Agency’s (now the CRC’s) annual reports provide a regular review of progress with
rural proofing since 2000. The first report in 2001/02 (Countryside Agency, 2002b) notes that the
Agency had circulated its checklist fairly widely within Government and that most Government
Departments had completed the initial steps to implement rural proofing as set out in the Rural
White Paper. Each Department had a designated person to be the main contact point on rural
issues, with regular liaison taking place between the Agency and that individual. However, less than
half of Government Departments had built rural proofing into any existing policy-making and
appraisal systems or promoted it internally and there was only modest evidence of an increase in
the degree of rural awareness and thinking by policy-makers (ibid.).

In the 2003 and 2004 reports, the overall message was again one of mixed progress across
Departments, although both reports note year-on-year progress (Countryside Agency, 2003;
2004a). Rural issues were being discussed across a wider range of policy areas and rural proofing
was increasingly becoming a routine and integral part of some Departments’ policy making,
although often not early enough in the process. The most successful outcomes were achieved
when rural proofing was integrated into policy-making from the outset and/or where it had senior
level support, such as rural proofing the 2002 and 2004 Treasury Spending Reviews (Countryside

2 The launch of the eight Rural Delivery Pathfinders in 2005 represented an attempt to tackle the lack of clarity over the role
of local authorities in securing the delivery of rural policy goals for their communities (Defra, 2008, p.6). One of the key
themes that recurred across the Pathfinders was a recognition that rural proofing techniques had limitations and that the
guidance was not readily understood by many service managers. There was widespread agreement that current
approaches to rural proofing, and the reasons for doing it at all, should be reviewed and refreshed (Defra, 2008, p.8).
3 It could also be argued that other organisations have a role in rural proofing. For example, the Centre for Rural Economy
was asked by One NorthEast (the RDA in the North East region) in 2005 to rural proof the Regional Economic Strategy.

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Agency, 2003; Countryside Agency, 2004a) and the building of a rural dimension into Departmental
PSA targets (Countryside Agency, 2004a). However, some failures were also noted, not least the
disappointing scale of tangible outcomes from rural proofing, although this was sometimes due to
Departmental under-reporting rather than an absence of rural proofing. Data limitations and the
lack of urban-rural markers for datasets were seen as weaknesses (Countryside Agency, 2003).
Therefore the launch of the new urban-rural definition in 2004 was seen as an important step
forward (Countryside Agency, 2004a). It was noted that further work was needed with more
regional and local actors to formally extend rural proofing responsibilities to these tiers of
government, where most delivery takes place. The 2004 Rural Strategy and MRD Review were
recognised as offering opportunities to extend responsibilities and to re-emphasise the role of rural
proofing.

The 2004/05 report (CRC, 2005) was the first to be produced by the CRC (as an operating division of
the Countryside Agency), and for the first time it brought together an assessment of rural proofing
delivery and progress with the Rural Service Standard. The report acknowledged that responsibility
for rural policy and delivery may rest with a range of different bodies as a result of the increasing
devolution of public service priority setting and delivery to bodies at the regional and local level
(ibid., p.7). It noted that the success of rural proofing will not be judged with reference to policy
processes alone, but also with reference to the actual impact of rural proofing on the quality of life
of rural communities on the ground (ibid., p.2). The report makes more explicit recognition of the
diversity of circumstances that rural proofing must reflect. Examples of key successes noted in the
report are the building of a rural checklist into Regulatory Impact Assessment4; the Treasury’s
requirement for all Departments to rural proof their budget assessments and to ensure that all PSAs
can only be met if they are implemented in both urban and rural communities; and particular
cases where rural proofing is having a positive impact, for example in terms of the Countryside
Communities programme of the Big Lottery Fund (ibid.). The report also notes some tangible
outcomes from rural proofing activity, such as the inclusion of a sparsity weighting in the
Department for Trade and Industry’s broadband grant.

However, the overall message from the 2005 rural proofing report is not markedly different from
previous years, with a sense of some achievements and successes, but also a recognition that rural
proofing still does not deliver everything wished for by the CRC or rural communities (ibid.).
Particular challenges are the delay between the national formulation of policy and its
implementation and delivery local y (ibid., p.11, 13).

Regionally, the report also notes mixed progress, with a “…need for some further clarification of the
roles (and the resourcing) of rural proofing at the regional level; in particular with regard to the key
regional strategic documents including spatial, housing and economic strategies” (ibid., p.9).

4 Regulatory Impact Assessment is an analysis of the likely impacts of a policy change and the range of options for
implementing it. As of May 2007, RIA has been replaced by Impact Assessment (Cabinet Office 2005).

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The report notes the need for more systematic rural proofing by local authorities and better
mechanisms for identifying and sharing best practice between local authorities (ibid., p.10). Moving
forward, the report notes that rural proofing must address core issues of funding and resource
allocation, that there should be more widespread use of the urban-rural definition across
Government, and that there needs to be much stronger means of drawing on the experiences and
concerns of rural people in informing monitoring work and hence influencing change (ibid., p.4).

The 2006 report (the first to be produced by an independent CRC), took a different approach to
reporting rural proofing activity, incorporating evidence from policy makers on rural proofing a
sample of policies and complementary advice and opinion from national and regional
stakeholders on the evidence gathered (CRC, 2006, p.2). However, the overall message is again
the same, with a failure by policy makers to systematically undertake rural proofing and use the
urban-rural definition, and few processes in place to check the impacts of any rural proofing that is
taking place, although the report cites some examples of good practice, including Defra’s Climate
Change Adaptation Framework and the creation of regional sub-groups to consider the rural
aspects of Regional Spatial Strategies (ibid., p.7). There is an acknowledgement that Defra is
beginning to establish itself successfully as rural proofing champion across Government, although
also a recognition of the need for it to develop a more proactive strategy for promoting rural
proofing. Third sector organisations are also called on to do more to rural proof their activities. The
report outlines a number of specific actions to bring about better scrutiny of rural proofing, by
Parliamentary Select Committees (especially the Environment, Food and Rural Affairs Committee),
the National Audit Office and Audit Commission and by Regional Rural Affairs Forums and Regional
Assemblies.

The most recent rural proofing report (CRC, 2007a) again notes disappointment with the
inconsistent performance of Government Departments in only partially meeting their commitment,
with rural proofing largely reliant on the judgments of individual policy makers rather than being
embedded into the day to day systems, cultures and processes of Departments (ibid., p.9).
Support tools, such as the checklist and Regulatory Impact Assessment are not being used to
undertake systematic rural proofing. Where a policy has a specific spatial element to its
implementation, rural proofing is more likely to have occurred (although not necessarily early in the
policy making process), and lobbying from external interest groups and stakeholder engagements
and consultations were found to be effective at bringing about rural proofing (ibid., p.2). GOs
particularly highlighted the approach of local needs driven implementation as a good way of rural
proofing delivery, although such refinements are not always enough to meet the additional cost
pressures faced in order to implement policy and deliver services in rural areas (ibid., p.11). The
report also notes that monitoring and reporting systems are often not adequately set up to allow
the impacts of a policy on rural areas to be assessed and compared to the effects on other areas.

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In summary, the report notes that “It is clear that there is more to be done to mainstream properly
and systematically, ‘rural’ into the work of Government Departments” (ibid., p.17).

Therefore since 2000, the overriding message from the annual rural proofing reports has remained
largely unchanged; some specific successes have been achieved and rural issues are more widely
known about but overall progress with rural proofing remains inconsistent and disappointing. Direct
evidence of rural proofing outcomes is limited, although this may be as much due to inadequate
monitoring and under-reporting as to a lack of systematic progress. Opportunities to strengthen
rural proofing, at the time of the MRD Review or the formation of the CRC, seem to have been
missed, and responsibilities with regard to rural proofing (particularly at the regional level) remain
confused. These key messages are repeated in other recent CRC work, including the 2007 Rural
Advocate’s report in which one of the overarching themes is the need for better rural proofing both
nationally and sub-national y (CRC, 2008a, p.27). In his recent report on England’s rural economies
(CRC, 2008b) the Rural Advocate again calls on the Government to demonstrate a greater and
more transparent commitment to rural proofing relevant policies, research, evaluations, speeches,
consultations and so on, drawing on the CRC for advice. The Government’s recent “Enterprise:
Unlocking the UK’s Talent” and “Innovation Nation” reports are specifically mentioned as illustrating
the need for better rural proofing.

What is the future for rural proofing?

In the 2007 rural proofing report, the CRC Chairman noted that the organisation is looking to re-
establish and strengthen rural proofing over the coming months, and to consider reforms to the
process. The report was designed to mark the beginning of a period of consultation and reflection
aiming to see rural proofing ‘refreshed’ (CRC, 2007a, p.3). GHK consultants were appointed to
facilitate and lead discussions with policy making and delivery staff about how to take rural
proofing forward. Their report revealed a number of barriers to successful rural proofing, including a
lack of familiarity amongst policy makers about sources of information, advice and guidance and
about the 2004 urban-rural definition, a lack of understanding about when rural proofing is needed
and spatial blindness amongst policy makers in central government. The report also revealed
confusion between central and regional/local government about who is responsible for rural
proofing, with policy makers in central government often feeling that rural proofing is less important
where you have a principle that those who have to deliver a policy have local flexibility; on the
other hand, the report revealed a perception amongst local and regional government that the
‘missing link’ is central government (GHK, 2008). This review has been taking place in the context of
shifting Government policy drivers. Three such drivers are particularly important: climate change
and environmental sustainability, mainstreaming and devolution. Although the creation of Defra
was partly aimed at raising the profile of rural affairs within Government, the Department’s
attention has become ever more focused on climate change and environmental sustainability,

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leading to rural issues becoming politically marginalised and being allocated ever diminishing staff
and financial resources. This has led to concerns that it is not adequately equipped or strongly
enough inclined to act as a forceful champion of rural interests with the RDAs (with their increased
responsibilities for promoting the social and economic welfare of rural areas), or indeed across
other Government Departments (Ward and Lowe, 2007, p.8). Moreover, other ‘rural champions’,
such as the Countryside Agency, the Rural Affairs Forum for England and the Market Towns Advisory
Forum have been wound down. It will be interesting to see the extent to which the transference of
Defra’s climate change responsibilities to a newly created Department of Energy and Climate
Change (as announced in Gordon Brown’s October 2008 Cabinet reshuffle) will open up the
possibility of a refocusing of attention on rural issues.

Mainstreaming refers to the consideration of rural circumstances as part of everyday policy making
rather than separately throughout Government. In a speech to the Local Government Association
in March 2007, Barry Gardiner MP set out Defra’s case for mainstreaming, arguing that rural issues
are simply reflections of wider societal questions and should be addressed by the Government as
such and that, although Defra will continue to provide a lead within Government on rural issues,
there is a need to ensure that rural needs and priorities are understood in wider Government
activity, including at the regional and sub-regional level. For example, rural disadvantage or rural
housing needs should be taken into account in mainstream policy and delivery not through stand-
alone, area-based ‘rural’ projects and programmes. Gardiner argues that the diversity of rural
areas in England means that a simple rural proofing exercise is not enough, an argument that
chimes with the Government’s place agenda which advocates the tailoring of national policy to
local circumstance whether it is rural or urban. Gardiner’s speech sets out a much clearer and
more central role for local government in ‘community proofing’ than was the case for rural
proofing (Gardiner, 2007). The CRC (2007a, p.19) acknowledges that mainstreaming represents an
important opportunity to refresh rural proofing, but it also argues that it should not cloud the
purpose of rural proofing, which is to see improved outcomes for rural communities (ibid., p.4-5).
The CRC argues that mainstreaming should certainly not replace the need for Defra to lead the
way within Government on rural issues, for continued reporting by CRC on rural proofing activity or
for a continued drive to develop effective rural proofing at regional and local levels and across
different sectors.

Defra’s report on the Rural Delivery Pathfinders contains further discussion about the future of rural
proofing (Defra, 2008). It acknowledges the concern that rural areas (and what makes them
distinctive) risk being ignored if policies and programmes are not explicitly examined and modified,
but argues that this might be looking the wrong way through the telescope. Rather than seeking to
defend rural interests by basing policies on rural needs, the argument should be that rural areas
make a positive contribution to the overall health – economic, environmental and social – of an
area, and so should benefit from interventions directed at improving this overall health. At the same

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