Behaviour Change: Science and Technology Committee Report

Baroness Smith of Basildon Excerpts

Wednesday 11th July 2012 Grand Committee

[Baroness Smith of Basildon]

My Lords, I think I should start my contribution with a confession: I arrived at this debate as both a novice and a sceptic, to start with. I found the report and the debate itself absolutely fascinating. It has been extremely enjoyable and interesting. When I first heard about the Government’s new Behavioural Insights Team, I was very sceptical—partly, as today’s debate has drawn out, because it is very difficult to assess what factors influence behaviour. First, on an individual level, which I appreciate is not what the Behavioural Insights Team is about, what people say the factors are that influence their behaviour are often not the ones that influence them but the ones that they want the questioner to think influence their behaviour. Because any policy initiative is unlikely to involve just one intervention, it is also difficult to isolate different policy interventions and decide which one has had the impact and what that impact has been.

For this nudge theory to have any real credibility and weight it needs effective evaluation, as the report makes very clear. I pay tribute to the committee chaired by the noble Baroness, Lady Neuberger, and to her team because I found this report to be very readable and enjoyable. It illuminated as much in what it did not say as in what it did, which I think was the point that the noble Baroness drew out a moment ago. The committee has been extremely helpful to the Government on behavioural change in its recommendations, and helpful also to the Government’s Behavioural Insights Team or nudge unit. Clearly, the Government were very attracted by the Thaler and Sunstein book, Nudge, which argued that a range of non-regulatory interventions can influence individual and public behaviour. Given that the Government have set up the unit, this is an extremely welcome contribution and not just to a debate, because it has to be more than that. It has to be something practical. The report brings a kind of detailed scientific analysis to what can become a very theoretical debate.

Part of my scepticism at some of the press reports that I read before on the value of Nudge—or nudge alone, which the report drew out as well—was the problem of evaluation. When the National Audit Office was looking at this even the Minister, Oliver Letwin, told it that it was,

“open to question whether any of this will have any effect whatsoever”.

He continued,

“I don’t want to pretend that behavioural science is a sufficiently developed science to give us complete confidence or even sort of 95% confidence that any given technique will produce given results”.

I am pleased to hear that the BIT is now looking at evaluation, because to move any further forward without evaluation would be a big mistake. However, the National Audit Office itself found that there was no evidence that government departments were taking up the theory or the background of nudge, so this debate is very timely and will bring some clarity to the issue.

For me, the report emphasises that the need for evaluation has to be evidence-based. There are recommendations on the way forward, but I have to confess to your Lordships that part of my scepticism is about what is meant by a nudge and how it is defined. I appreciate that the debate has different facets on different issues. However, if I have understood correctly, it is essentially about what the levers are that drive and lead behavioural change, and what the relative merits or otherwise are of rules and laws to lead and force that change—as regulatory intervention or as campaigns, provision of information, et cetera, which is non-regulatory intervention. My understanding is that the provision of information, advice and knowledge can lead individuals or society as a whole, or groups in society, to make those changes.

That is the nudge concept theory, if I have understood it correctly. But in all that I have read, including this report and other information that I have sought there is still no definite answer as to what constitutes a nudge and what counts as a regulatory intervention. What does it really mean? I have seen different interpretations but, for me, if it is to be a non-interventory way of changing behaviour, it has to be about providing information, leading by example and giving the individual a free choice while seeking to influence that choice. It could be argued that it is more empowering for the individual to make that choice than for a wider group in society to make choices. I looked at table 1 in the report, where Nuffield takes the view that a regulatory intervention that is not directly aimed at the individual whose behaviour they are seeking to change is a nudge rather than regulatory change. I do not know whether noble Lords have looked at table 1, but I had some issues because of the examples used. It argues that changes to the physical environment would be a nudge, and gives the example:

“Altering the environment e.g. traffic calming measures or designing buildings with fewer lifts”.

To me that is more like an intervention, because action has been taken to change behaviour. The behaviour change is not a free choice—it is making one choice more difficult than another choice. If we install speed humps cars will go more slowly in that road. If we have fewer lifts in buildings, more people will walk. So it might be a nudge in changing an individual’s behaviour, but in making a collective difference I struggle to see that as nudge behaviour rather than something more interventory.

I have a new theory. I think that it is more like a shove; it does not give the individual the opportunity to opt in or out. I cannot see that it is giving information or empowerment to make a choice, but by regulation it limits choice to influence behaviour. So it is not a nudge but a shove, because I lean towards a nudge being about giving power for choices to be made. An intervention, whether targeted at an individual, a community or business, such as speed humps, removes choice. I am not saying that that is bad in any way, but I am trying to acknowledge the difference. I am not saying that one is less effective, but we have to clear up what a nudge is.

Business has to have legislation to inform customers, and we have heard about the traffic light system—and then there is information about obesity, which the report looks at as well. It has to be presented in a way that is easily understood, showing the potential danger of problems from a product. That becomes an intervention. When the noble Lord, Lord Krebs, was making the argument about phones, I looked at my iPhone. I have no idea whether I have the best tariff for my iPhone; I had a choice, but I was certainly nudged to make a certain choice. I suspect that I have not got a particularly good deal.

The issue of smoking was raised, as well, by the noble Baroness, Lady O’Neill. I am more likely to agree with her on that issue. Various warnings on packets of cigarettes over the years and numerous advertising campaigns have had a marked but incomplete effect, as she said. There have been interventions, saying that, “Smoking can damage your health” and “Smoking kills”. They are all interventions, however mild, to try to influence behaviour. We can argue that they had a limited impact or effect, but we cannot consider it a success at this stage, because we are still talking about what interventions to take. Although it was not referred to as a theory at the time, various evaluations that have taken place over many years have not said that those interventions on their own were a success because further interventions had to be taken. There has been initiative after initiative, and it is still going on. What really did influence and drive change was something that was very much an intervention from Governments banning smoking in public places. You could argue that levels of taxation have had an impact as well. It is far more regulatory than nudging.

The noble Lord, Lord Krebs, referred to drink-driving. The seriousness of the problem was recognised long before any significant action was taken; there were various awareness campaigns. I am told that when the breathalyser first came in, by those who were drivers at the time—I hasten to add that I was not—they were told that three or four or even five pints would put them within the breathalyser limits. So what was the influence on behaviour? It could be the thought that drivers could be prosecuted and lose their licences. That is what made a collective and significant difference. Part of the difficulty is that there needs to be a significant change in collective behaviour to make an effective assessment of whether an intervention is effective. It is also very difficult to isolate one specific aspect of a range of interventions to try to say which intervention was successful. We need a critical mass of change to indentify cause and effect.

I worry, and this was mentioned by other noble Lords, that at a time when the Government are making huge and very significant cuts in public expenditure the proposal of a nudge theory to change behaviour, without other interventions and without any real evidence base of success, could be a cheap alternative to effective and efficient actions by Government that could really make a significant difference. That is why I think the recommendation in the report for a social scientist is very important. Unless the Government make an assessment and know what works, then nudge interventions really have no value.

The report was very clear that to affect behaviour and make a difference, a range of interventions is needed, not nudge or even shove alone. The key points I took from the report were that non-regulatory intervention should be used when there is evidence that it works, not because it is cheaper or easier. It should not be used without any assessment of its effectiveness, nor because it fits somehow with the Government’s philosophy or policy to cut expenditure and look at ways of changing behaviour rather than having formal regulatory interventions. There has to be an independent, quantifiable, evidence-based assessment of the value of any non-regulatory intervention, particularly if the Government intend to use it to replace regulation or regulatory intervention.

I did not get from the Government’s report— I would not have expected it in the S and T report—where they see the balance, if they have ascertained that yet, between regulatory and non-regulatory intervention. The Government have to look at it and it is quite a serious issue for them—it is a wider issue than across one department. If the Government are seeking to influence behaviour in one area they have to recognise that actions taken across government as a whole, and other agencies, all contribute to the result and can often be contradictory. The reason for taxation on fuel has been to support the environment and to try to reduce car use. However, at the same time the Government support significant above-inflation increases in train fares and many people who would go by train are forced off the train and into their cars because it is cheaper for them. Governments have to work across departments to have a holistic policy that makes a difference rather than one department acting against another one.

We can accept that nudge does have some impact. Commercial organisations have used it for years alongside other strategies. However, they also recognise, as the Government have to in public policy making, that different problems require different solutions. One size does not fit all. One thing that I saw in this was the carrot-and-stick approach, I think the noble Lord, Lord Hunt, referred to that as well. If we look at traffic in London and our numerous attempts over the years to reduce the congestion, what has worked, it seems to me, is the carrot—ensuring that there are more buses and better public transport. That has an impact. The congestion charge had an even bigger impact initially. One of the problems with fiscal interventions is that their impact reduces over time as people get used to them. There has to be an assessment of whether regulatory interventions lead to long-term behaviour change or whether once the impact of the intervention is lost the impact lessens. We have to look at new ways of trying to influence behaviour.

I appreciate that I have added a new concept and am perhaps making it slightly more complicated, but at what point does a nudge become a shove and does it matter? If an intervention works does it matter if it is a nudge, a shove or a regulatory intervention? There seems to be an assumption, and I am not suggesting for a moment it was from the committee, that a nudge to influence behaviour is better than regulatory influence. I am not sure whether that works or is relevant. What matters is what works. If a change in behaviour is necessary, what is the best way to achieve that change? Without an evidence-based evaluation of the different approaches it is very difficult to make that judgment.

Several noble Lords referred to the fact that this is not new. Perhaps articulating the concept of nudge is new and different, but the idea that we are inventing a nudge theory is not: Governments have been using it for many years. The noble Lord, Lord Kreb, made a similar point about seeking to use it in a different, perhaps more conscious, way, but it has been used in the past and will continue to be used. However, the willingness to try to understand what works, and why is new.

I congratulate the committee and the noble Baroness, Lady Neuberger, in particular. The report brings clarity and common sense to the debate, which is welcome. The danger for the Government—I am looking forward to the Minister’s reply—is that this matter should not be allowed to become an academic discussion. There should be a practical response about whether or not there are interventions through nudge that the Government can make. I am not clear from the printed response about the degree of determination and clarity with which the Government intend to take this matter forward.