Food Policy Coherence in Local Government: Who does what?

by Rob Kidd, our Associate Consultant

Photo by Clem Onojeghuo:

Associate Consultant Rob Kidd is on a mission to understand which parts of local government are responsible for making and implementing food policy – and he needs your help to do so.

Policy coherence means how successfully (or otherwise) two or more policies are aligned with each other. Drafting policies in isolation, without considering context and potential interactions, can result in conflict, with one policy counteracting the other. This is known as policy incoherence and can undermine efforts to improve systems through policy interventions. Food policy incoherence is especially common because of the size and complexity of the food system. A common example is one part of government promoting oily fish consumption while another department warns of overfishing.

While food policy is often made at the central government level, by ministers and departments representing the national interest, it is often interpreted and implemented (or not) by councils. In her research, Kelly Parsons identified 16 central government departments with collective responsibility for food policy (reproduced below). This helps practitioners to understand the complexity of, and conflict within, the food policy environment at the national level. More research is needed to understand the food policy environment at the local level.


© Kelly Parsons 2020

Local government in the UK is a complex patchwork of powers. Responsibility for different policy areas is distributed across different regional groups and devolved to varying degrees of localisation. There are more than 400 councils, each of which is a distinct organisation; although what it does is largely prescribed in legislation, how it does it is up to the council to determine. It is therefore easier to consider local government functions as a corollary to central government departments. The Institute for Government has a handy list showing what functions councils are responsible for and at what level of devolution.

I conducted a literature review to try to understand which of these functions was involved in making, interpreting and implementing food policy, and to find examples of policy (in)coherence. 

By far the most common local authority function referenced in the literature is public health. A prominent theme is the role of councils in addressing obesity by using local powers. These include the use of planningrules to restrict unhealthy food outletstrading standards (in enforcing HFSS sales restrictions), or even in its role as a transport operator by restricting advertising. The role of ‘regulatory services’ (trading standards, environmental health, consumer protection, all three of which are often conflated) in protecting the public from food adulterationfood poising and food fraud was also a popular subject for study.

These public health and regulatory services functions were also the most common sources of policy incoherence and conflict. As noted by several researchers, there can be a conflict between councils’ economic development functions (encouraging businesses to open and prosper) and the need to limit the sales of businesses selling unhealthy foods as a means to tackle obesity. Food safety and environmental health inspections are also sometimes perceived as being a burden on business and hindering the growth councils are charged with enabling. Several researchers note the impact on food insecurity caused by austerity measures or other cuts to local authority services. One went as far as arguing that cuts to all the above-mentioned services, plus more tangential ones like housingsocial care and even highways, have a disproportionate impact on people on low incomes, causing a rise in hospital admissions due to malnutrition.

The role of local authorities as provider of food, particularly in institutional settings, was another common theme. 22 studies related to councils’ education function, most of which concern improving the standards of school food or the provision of free school meals. Several studies on education noted the potential for well-fed students to be more successful or productive, reducing inequalities and contributing to economic development (a rare opportunity for policy coherence identified in my research). Only six studies looked at councils’ role as providers of social care, including children’s services, with two looking at nutrition in vulnerable elderly people. This research gap concerning social care is perhaps surprising given a large and growing proportion of councils’ expenditure goes on social services. The poor standard of food in many care homes and other institutional settings may perhaps be caused by this lack of attention from researchers. 

Another important function with widespread coverage by researchers is that of waste management(collection, recycling, disposal); food waste was the subject of 11 studies. Unlike the other functions identified above, waste management appears largely isolated from other council responsibilities, with limited opportunities for policy incoherence identified. A conspicuous gap in the research is around the redistribution of surplus food via food banks which would otherwise enter the waste stream. At first glance, this addresses public health goals and reduces food waste – an obvious win for policy coherence. However, the food distributed by food banks is not always as healthy as it might be, and the increasing reliance on them is seen by many as perpetuating inequality by enabling the retrenchment of the welfare state

Six studies conducted research into markets, noting the potential for councils to boost tourism by promoting markets and food festivals, alongside more prosaic council functions of planning (where markets should be) and consumer protection (monitoring trading practices of stallholders).

Other local government functions had more tangential food policy links. One study described the need to engage with arts and recreation (through cultural and community centres) to deliver health promotion activities (including nutrition advice). Tim Lang, Emeritus Professor of Food Policy at City University, noted the importance (and absence) of food policy in councils’ emergency planning, in the context of Brexit-induced food shortages

My literature review has shown that many functions of local government have an impact on, or are impacted by, food policy decisions. The literature shows a few ‘focus’ areas, like public health, planning, regulatory services and economic development, though this does not feel like a complete picture. Some local government functions (notably births, marriages and deaths, burials and cremations, and public toilets) seem unlikely to have a significant overlap with food policy, but absence of evidence is not evidence of absence. As many food policy practitioners working in local government have found, this is a complex system with many tangential links and vested interests. More research is needed to establish the full range of food policy actors in local government, and the links between, them to give initiatives to improve the food system the greatest chance of success. 

Get involved

Rob is undertaking research on this topic as part of his MSc in Food Policy and is looking for interviewees to share their professional experience. If you have experience of making, interpreting or implementing food policy in the local government context, please get in touch. 

About the author

Rob is an associate consultant at Bremner & Co and a freelance management consultant focusing on the food industry. His background is in local government, housing and non-profits, but for the last six years has focused his attention on the food industry, running business improvement projects for clients including Pret a Manger, GAIL’s, The Bread Factory, the Soil Association and Elior. At Bremner & Co, Rob has led a review of food and beverage operations at Salford University and is about to embark on an impact evaluation at The Felix Project.

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