Developing approaches to ex-post assessment of regulatory change impacts at the farm level - John Powell
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Developing approaches to ex-post assessment of regulatory change impacts at the farm level - John Powell

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Overall aim: ...

Overall aim:
develop a methodology to improve understanding of the systemic and other factors influencing impacts arising from the implementation of regulatory change

Objectives:
Understand the form and magnitude of errors in current impact assessments
Identify potential improvements in the general methodology in order to reduce errors
Develop a framework methodology for the conduct of ex-post assessment of regulations

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Developing approaches to ex-post assessment of regulatory change impacts at the farm level - John Powell Presentation Transcript

  • 1. Developing approaches to ex-postassessment of regulatory change impacts at the farm level: prototype study John Powell Jane mills CCRI University of Gloucestershire
  • 2. Aims and objectivesOverall aim:• develop a methodology to improve understanding of the systemic and other factors influencing impacts arising from the implementation of regulatory changeObjectives:• Understand the form and magnitude of errors in current impact assessments• Identify potential improvements in the general methodology in order to reduce errors• Develop a framework methodology for the conduct of ex-post assessment of regulations
  • 3. Role of IA in the policy process
  • 4. Research Design1. What does the Literature say?2. Selection of regulations3. Collection of empirical data4. Comparison of ex-ante and ex-post impact assessments5. Identification of causal factors accounting for differences6. A framework methodology for undertaking ex-post impact assessment of regulatory change.
  • 5. Evaluating regulatoryimpact assessmentsReasons for ex- Recent studies ante /ex-post • Significant variation in differences quality – Use of worst case • Limited policy options scenarios considered – Strategic behaviour • Limited impacts – Compliance issues might alter costs explored – Incorrect assumption • Limited utility
  • 6. Selection of Regulations•Criteria for selection•Nitrate Pollution Control regulations 2008•Agricultural waste Regulations 2006
  • 7. Comparison of ex-ante and ex-post impacts: Nitrate Regulations 2008Costs ex-ante: Costs ex-post: – £655 - 1,009 million – £300 - 900 million Total present value concentrated in the short- discounted over 20yrs at term period after 2008 3.5%• Benefits • Benefits – £28 - 274 million TVP – No monetary estimate, over 20 years potentially long-term and small• Comparisons between • Main differences related measures to behavioural changes
  • 8. Ex-ante/ex-post differences – Nitrate RegulationsCategory Magnitude of differenceTotal costs LowTotal benefits Unclear - LowCompliance costs:Storage capacity MediumCovered yards/run-off reduction measures LowReduction in stocking rate UnclearAdditional spreading costs UnclearSpreading techniques LowCompliance costs:Moving and making more efficient use of slurry HighReduction in fertiliser use UnclearCompliance costs HighIncreased farm labour/time costs HighDairy Derogation Unclear – possibly high.Planning costs LowImplementation and enforcement Costs Unclear – possibly lowSmall firms impact test LowCompetitiveness Unclear – possibly high
  • 9. Comparison of ex-ante andex-post impacts: Agricultural WasteRegulations 2006 Ex-ante: Ex-post: • Costs: • Costs: – Haz. Waste £28.7 – 69.8 – Haz. Waste £35.4 m/yr m/yr – On + off farm £124-750 or – On-farm £177-430/yr ave. £219/farm/yr. – Off-farm 1 – 12% income • Benefits – high, linked to • Benefits – not estimated – improvements in soil and water Environmental possibly lower; quality indirect benefits higher • Comparisons with ex-post • Main differences due to high measures implementation costs; farmer behaviour; level of re-use and recycling
  • 10. Ex-ante/ex-post differences– Waste Regulations Category Magnitude Reason for difference Environmental Benefits Environmental impacts overstated Ammonia; Loss of fishery value; Bathing High Many practices altered to comply with waters pollution; Direct impact of faecal farm assurance schemes. pathogens to soil/water No mention of emissions from burning plastic and other wastes. Compliance Most farmers already in compliance •On farm hazardous waste storage Low Largest waste stream (plastic) is •On-farm disposal/recovery recycled. •Off-farm disposal/recovery Farmers not disposing of all wastes. Implementation costs Communication costs not considered – The Environment Agency (EA) will face High in particular those of associated increased costs in administration, stakeholders outside of government. monitoring and enforcement. Costs to the court system Lack of waste focused inspections. Estimated 11 court prosecutions involving High EA prefers light touch approach the agricultural sector. Small firms Unclear No consideration of significance of plastics recycling.
  • 11. Exploring reasons for thedifferences in estimates Causal Category Description Assumptions Differences caused by assumptions Methodological Difference caused by ineffective or inaccurate methods Technological Unforeseen changes in technology; anticipated changes that did not develop, or not had an impact Sector Knowledge Erroneous or imperfect understanding of the sector External drivers Failure to account for the impact of external forces Implementation support Erroneous accounting Systemic Failure to carry out actions or undertake studies required; or, specific ‘ways of doing’ that cause errors.
  • 12. Exploring the differences inestimates: Nitrate regulations Assumptions •Derogations Technological •Anaerobic digestion •Reduction in stocking rates •Spreading of slurry External drivers •Fertiliser pricesMethodological Implementation•Costs annualised over 20 yrs•Increased time to manage nitrates support •Provision of advice/guidance •Mapping and appeals •monitoring Systemic •Timing •Options explored Sector knowledge •Renting land •Methodological •Variable impacts
  • 13. Exploring the differences inestimates: Waste regulationsAssumptions Implementation•Recycling behaviour support •Provision of advice/guidance •Communicating complex definitions Methodological •IT system - registration •Estimating on farm costs External drivers •Value of waste materials Systemic •Limited options explored Sector knowledge •Effects on other stakeholders
  • 14. Suggestions for improvingex-ante approaches• Workshops/case study methods• Scenario modelling• Guidelines for implementation impact measures• Market forces• Cost-benefit estimation
  • 15. A framework for the conduct ofex-post assessment of regulations
  • 16. Proposed approach: keyissues•IA documentation•Identification ofimpacts•Collecting data•small sample size•Qualitative•Validating data•Accounting fordifferences
  • 17. Evaluation of theproposed approach:Strengths•Impacts considered from the perspective of thebusiness unit affected•Business and external influences are brought together•Focus on identifying causal•Pattern matching approach•Qualitative assessment of costs and benefits•Feeds recommendations into the next round of policyreview
  • 18. Evaluation of the proposedapproach: Weaknesses •Level of compliance •Capturing variability •Systemic differences •Benefit measures •Timing •Resource requirements
  • 19. Resource implications ofthe modified approachesEx-ante IA•70-90 person daysPIR•35-75 person days•Size/complexity oflegislation•Potential benefits