Examination of Witnesses (Questions 20-39)
MS SARA
EPPEL AND
MR FAROOQ
ULLAH
29 APRIL 2008
Q20 Dr Turner: That raises several interesting
thoughts. To what extent are you able to discuss with departments
the methodology by which they derive their data?
Ms Eppel: We do discuss that a
lot. My team discusses it in a lot of detail. We will be going
back and forth for quite a long time. They will give us the first
set of data and we will get our consultants, Entec, to put it
through the process, do some cleansing, but the back and forth
is quite considerable. We will try and interrogate the data because
we want to be sure that we feel reasonably comfortable with it.
I would say we have a fairly accurate view of whether the data
is solid or not, but as far as we are aware no department does
full external verification of the data and without that external
verification it is on trust.
Mr Ullah: The issue really is
that there is no third party data verification by any department.
Some of them do partial verification, but we have not seen any
department do a full dataset. While we take this data on trust
and goodwill, without having the assurance that a third party
has gone through it we can never be fully confident that the data
is accurate.
Q21 Dr Turner: So there needs to
be a robust audit process?
Mr Ullah: There does, yes. We
have recommended for the last two years running that all departments
have their data third party verified before sending it on to us
because, at the end of the day, that is the only way that we can
be fully assured that it is as accurate as it could be.
Q22 Dr Turner: Do you think the Sustainable
Development Commission itself is in a position to carry out that
audit function?
Mr Ullah: No, I do not think so,
not with the resources we currently have. It is not our core function.
Our job is there as Government's assessor and scrutiniser, not
as its statistician. I think that something needs to be put in
place: either departments must verify their data or another body
does it before it comes to us.
Q23 Dr Turner: It sounds like more
expensive consultants coming into view. Are there people out there
with the expertise to do this sort of job at a reasonable cost?
Ms Eppel: Yes, it could be expensive
consultants but it does not have to be. There are smaller organisations
that can do this. It does not have to be PwC, let us be honest.
In addition to that, as the watchdog we could do spot-checks but
we have not done that yet. It is something that we can do in another
year or so. For us it is about the best use of our pretty limited
resources.
Q24 Dr Turner: You derive a lot of
the information by sending out questionnaires. Is there a possibility
of having direct access to departmental computer systems so that
you can extract data directly?
Ms Eppel: I do not think so. OGC
are trying to centralise the collection of data much more. They
have got a system called EPIMS which at the moment is just focussed
on buildings, but this year they are trying to align our questionnaire
with their system and from next year we are hoping that the EPIMS
system will actually collect all the data for us. As far as I
understand it OGC are also trying to do ongoing monitoring. It
will not just be an annual process of collecting the data and
assessing it, it will be quarterly or even monthly in some cases
if they want to examine the data through the year to see what
level of progress they are making. I do not think that the SDC
would ask for direct access to the report systems. I think Government
should be responsible for its own data. It is just that as the
Government's watchdog we want to be confident that that data has
been externally verified and is therefore of high quality.
Mr Ullah: Can I give the Committee
a bit more detail about the future intentions of data collection?
We are working with the OGC this year for the first time to use
EPIMS as the online platform which we use to collect data. Formerly
it was done very separately; basically the data was held in my
computer at my desk. EPIMS is a central government database, which
means that once the data is verified and checked and we are happy
that it is free to be signed off it is accessible to anybody in
Government, which means in effect that we are working towards
giving ownership of the data back to Government. We hope that
this will engender a sense of ownership and responsibility in
the data and thereby improve the quality of it. The other aspect
of EPIMS is the fact that it is related to real-time information
collected from each building site. The property benchmarking scheme
was made mandatory for all departments on 1 April 2008, which
means they have to collect data and feed it into EPIMS for every
building over 500 metres squared. This can then directly be pulled
in real time to a report that can be downloaded quarterly or weekly
and it will give departments a real view. Instead of just waiting
for us to produce this report 13 months after the year end, they
can know on real-time what their performance is and take steps
to improve it as quickly as possible. In the future we hope to
give the data collection back to them and somehow build a system
using EPIMS collect all data in real-time or more regularly and
allow departments to get a view of their performance as soon as
possible.
Q25 Dr Turner: What is the view on
the coming inclusion of departments in the Carbon Reduction Commitment?
Do you think this is going to improve departmental performance?
Do you think the departments have sufficiently good environmental
management systems within them to be able to participate meaningfully
in the Carbon Reduction Commitment?
Ms Eppel: I think the Carbon Reduction
Commitment will actually be another means for them achieving some
considerable improvement in their delivery. I think it is hugely
important that all government departments are involved and, in
fact, that all public bodies are involved, including the NHS and
the wider public estate. I think it is going to be an additional
driver to achieving change. I think it is very important.
Mr Ullah: It is a financial incentive
that they have never really had before. This is taxpayers' money
and so if they do not achieve a reduction through the scheme they
will have to pay. I do not think they have ever been held to account
financially in that way for the carbon emissions before as they
are yet to start offsetting.
Q26 Martin Horwood: I would like
to ask you a bit about the way in which you have brought together
the data and assessed it and presented yourselves. I should say
just before going on to slightly critical comments that I do think
this is a very impressive piece of work and a very important report
and I think the Sustainable Development Commission should be congratulated
on it. There are two ways in which you have summarised data which
have been criticised by some of our evidence. One is the star
rating system where you seem to give equal weighting to policies
as well as impacts. For instance, if somebody actually reduces
their carbon emissions that might contribute to getting a star
but so does just including a statement in their policy objectives
and those do not seem like equal things at all. For instance,
I think the Export Credit Guarantee Department, as WWF pointed
out, gets a four star rating and that is presumably on the basis
of quite a lot of policy commitments, whereas the Export Credit
Guarantee Department might not get such a good rating.
Ms Eppel: I think there are two
things to clarify. The star ratings are assessed to see if the
departments are on track to meet the targets. They are not saying
the departments have met the targets, they are saying at this
point, 2008 or 2007, depending on when we are reporting, we consider
them to be on the right point of the trajectory. The second thing
is about the ECGD issue, which is slightly different. The Sustainable
Development in Government Report is only focusing on operations
and some elements of procurement. What it is not covering at all
is policy, that is covered in the Sustainability Development Action
Plans, so there is a distinction between the two reports. We have
a whole programme of work around the Sustainable Development Action
Plans, part of which is to support departments and encourage them
to deliver and develop SDAPs and the other part is to look at
them and to assess their progress. All of that we publish on our
website and those are available in parallel. This particular document
is specifically focused on operations and procurement; it is not
covering policy.
Mr Ullah: There are two types
of star ratings in this report. One is the performance star rating
solely on the SOGE targets which Government has set themselves,
these are their targets and we simply assess performance against
it. You can find it on page 25. There is another rating which
we call the mechanisms rating which rates the mechanisms that
departments have in place, that is on page 35, which we think
are fundamental mechanisms in delivering these kind of operational
improvements. There are things like, for example, the BREEAM standards.
If the BREEAM standards have been met they get points for that.
The two things are very separate. I do not know if WWF has confused
the two, but we keep them very separate. One is purely based on
the SOGE targets and the other is based on what we consider to
be the key mechanisms to deliver performance improvements.
Q27 Martin Horwood: If we concentrate
on the SOGE performance star rating and the page 25 table, you
are saying that you cannot contribute to a star just by adopting
a policy there, it has to be based on impacts?
Mr Ullah: No. The scoring mechanism
is purely based on performance against the targets.
Q28 Martin Horwood: So CLG can get
five stars despite the fact that its level of recycling has gone
down later in the report?
Mr Ullah: This is an indication
of performance being on track. No one department is on track at
all target areas, they are not at 100%. If you look at the percentages,
it is a clear indication of where they sit against performance
against the targets.
Q29 Martin Horwood: Can you not see
that that is potentially misleading because you are effectively
giving credit for people being on track and not for the actual
outcomes and performance?
Mr Ullah: I do recognise that,
yes. I guess the thresholds that we have used in terms of the
percentages to assign the stars may be the misleading part. Anything
over 85% we feel warrants a five star performance in terms of
the progress they are making towards achieving these targets.
Q30 Martin Horwood: I would like
to ask you briefly about the "traffic light" system
as well. Clearly there is a lot of good hard data in this report
and you clearly have to simplify it and I think that is a good
thing to do to make it accessible, but it is important that those
simplifications are not misleading. On page 89 you use your "traffic
light" system, which has blue for excellent progress and
red for no or poor progress. It does not have a category for going
backwards and since several government departments seem to be
doing so I think that should be the case. Can you explain to me
how DCLG and the Department for Transport both appear to be recycling
less waste than they were the previous year and yet they still
have excellent progress blue scores?
Mr Ullah: This is performance
against the targets themselves. It is not a direction of travel
indication; it is purely a snapshot for one point in time.
Q31 Martin Horwood: But the direction
of travel is backwards in both cases, is it not?
Mr Ullah: They are still performing
above the target. Regardless of the drop in their recycling rate,
against the target they are still performing excellently. These
are the Government's own targets and we report simply against
them. The issue is maybe with the target itself.
Q32 Martin Horwood: In what world
is going backwards making excellent progress?
Mr Ullah: I think we need to look
at the trend overall they are making.
Q33 Martin Horwood: The trend is
backwards.
Mr Ullah: I do not know if that
is necessarily the trend. It is maybe a one-year blip. We need
to look at the direction in which they are really travelling over
the period of their examination, not simply during one year through
to the other.
Ms Eppel: I think it is fair to
say that if you draw it on a graph you can say the target is to
be met here and a straight line would be like this, which is what
we do, the straight line is like that, but departments are going
to go up and down each year because some years it is more difficult
and then you will get a sudden rise because they may be making
an investment or they change a contract or they do something that
makes a big change. The fact that it is going up and down like
that, if it is still above the line, which is where we would expect
them to be in terms of meeting the target, is worth accrediting
them for.
Q34 Martin Horwood: The Department
for Transport in 2005-06 recycled 85% of its waste, in 2006-07
it was only 57% and you give them "excellent progress".
You refer on the next page to the fact that it may be something
to do with better data management but it is not fully explained.
If the target is only 45% or something like that then clearly
they are well above it in both years and in your world that may
count as excellent progress. There is something very strange going
on there that is not really explained.
Mr Ullah: There is a lot of context
in this that obviously we cannot get into. We do not know what
that department is doing. If they have had a major office relocation
then they could have recycled a lot more material that year. If
they were having to move offices in 2005-06 their recycling rate
could have skyrocketed because they would have recycled a lot
more material.
Q35 Martin Horwood: If you were presenting
this as financial results and we were the Public Accounts Committee
you would have an explanatory note saying that the reason this
one is particularly weird is because X happened, but we have no
such explanations here.
Mr Ullah: This is always the problem
with this process. We work with the information departments give
us. We do not have the ability, the time or the resources to necessarily
go around the doors and ask everyone why their number has changed
and say, "Can you give us a full list of what has happened
in your own department for the last year?" It is a failing
of this process that that information is not pulled into the process.
If they do not give it to us, we simply do not have the time and
resources to go round and find out all the reasons for this. We
try our best. We have our consultants look at the changes in the
data and then ask for clarification if there are any.
Q36 Martin Horwood: That is a major
anomaly, is it not, that the DfT has dropped spectacularly and
apparently in its percentage of recycling and there is not a very
clear explanation?
Mr Ullah: I agree. I can do some
examination and come back to the Committee with an explanation
as to why that might be, but I could not tell you off the top
of my head and it is not in the report.[3]
Joan Walley: I think we would welcome
that very much.
Q37 Mr Chaytor: This report was based
on the new SOGE targets published in 2006. Has that made a significant
difference in terms of the reporting? Are you satisfied with the
new SOGE targets? Do you think there are any areas in which they
could be made more stringent?
Ms Eppel: The new targets simplified
it a bit for Government. They were slightly more outcome focused
than the previous ones. We were not totally satisfied with them
and we have said that in this report and in previous reports.
I guess there are two areas. One is in the transport data which
we are given, which has a target. That only covers road transport
and we feel that the whole transport footprint is more important,
so it should include air travel and rail. Basically it is about
how the public sector is moving around and what the impact of
that is. The other area of concern is the coverage. As Government
outsources more of its operations into NDPBs or out to private
companies we feel that there does need to be an audit chain for
going out beyond the central government departments. At the moment
that is not covered within the sustainable operations targets.
We welcomed the simplification but we were not totally happy about
the coverage.
Q38 Mr Chaytor: In terms of coverage,
the Department of Health gets a five star rating in terms of performance
overall, but that does not include hospitals. What is the logic
in excluding hospitals or GPs' surgeries from the Department of
Health's assessment whereas prisons are included in the Department
of Justice's assessment?
Mr Ullah: It is purely an issue
with the mechanics of how Government is organised. Prison services
is an executive agency now of the Ministry of Justice. However,
the NHS and the NHS Trusts are operated locally and do not fall
within the remit of central government. This is why Government
really needs to sit down and decide who is in and who is out and
who they need to be assessing and who should be a part of this
report itself.
Ms Eppel: Last year when Government
published its response to the Sustainable Procurement Action Plan
it was just focused on central government but at the same time
there was a parallel process with local government, the education
sector and the health sector to get them to take on something
as ambitious as this. The NHS probably has a long way to go but
there are various mechanisms in which it could do this. We feel
that the Department of Health should be leading the NHS to delivering
to a higher standard on most of this operational performance.
Mr Ullah: The NHS is undertaking
a similar review to this themselves as their own body through
their own initiative. While we do not cover them, they are doing
a lot of work. The score is an indication of the fact that they
are a leading department and they are passing those messages down
their supply chain as well.
Ms Eppel: The NHS PASA was the
procurement body for the NHS and that was quite a leading organisation,
it was doing good work. I think they were quite exemplary in many
ways, but, as with all these things, it is a moving target.
Q39 Mr Chaytor: But there is not
a parallel report to this produced for the NHS, is there? Given
the NHS is arguably the largest employer in Europe, it is clearly
absolutely central to any assessment of the Government's overall
report on sustainability, is there not a handy document that pools
together the record of the NHS through all its agencies and trusts?
Ms Eppel: No, there is not.
Mr Ullah: Not yet. They are working
on something. I do not have the details of what that might be.
3 See Ev 37. Back
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