Supplementary written evidence submitted
by Newport City Council
Letter to Damian Green MP, Minister for
Immigration, Home Office from Councillor Matthew Evans, Leader
of the Council, Newport City Council
When I gave evidence to the recent hearing of the
Parliamentary Welsh Affairs Committee in which I highlighted key
areas of concern, I had hoped for greater levels of transparency
from IPS as a result of the Committee's deliberations. I regret,
however, that we are still receiving only very limited levels
of cooperation in our efforts to fully understand the processes
being followed by IPS. It is important that the rationale for
the proposed closure and the assessment methodologies being adopted
are fully articulated by IPS and understood by all parties, otherwise
the lasting impression will be that key considerations have not
been taken into account and that unsafe and inaccurate conclusions
have been reached. This is so important, given that a decision
to close, or substantially down scale, the IPS presence here will
have such a devastating impact on the future prospects for our
City.
Clearly, one of my principal concerns is the social
and economic impact of the proposed job losses. A significant
number of Newport Passport Office staff live within the City of
Newport, where strenuous efforts are already being made to deal
with some of the worst community deprivation in Wales. Other staff
live in our adjoining local authorities, towns and communities,
which are also suffering their own severe challenges in addressing
both economic and social deprivation. With the current austerity
measures taking hold and reducing recruitment capacity across
both the public and private sectors in Wales, it is highly unlikely
that the 250+ affected IPS individuals will find appropriate alternative
skilled employment within the area, adding to an already over-burdened
UK welfare benefits system.
The proposed closure/part-closure will also significantly
affect the reputation and economy of Newport's City centre. Wales'
only Urban Regeneration Company, Newport Unlimited, was established
in 2003 to help turn the city's economy around following thousands
of job losses in the area. Following a much needed commitment
by public sector partners over the past seven years, aimed at
bringing in future private sector investment, our City's economy
is now very delicately balanced. Important steps have been taken
towards creating a more self sustaining economy for Newport, but
we have not been immune to the economic downturn. Securing and
retaining investment and employment that reinforces the heart
of the City is our absolute top priority. The retention of the
Passport Office is therefore all the more important when considering
the challenging process that we have embarked upon to secure a
private sector partner to deliver a significant and pivotal retail
development in the centre of Newport. A decision to close or substantially
reduce the scale of the Passport Office at this stage will not
only discourage retailers and developers from considering Newport
as a viable option, but will also send out negative messages to
other potential business investors who may wish to consider Newport
in the coming years.
So significant are our concerns about the robustness
of the 'Full Data Package' provided to justify the rationale for
the Newport closure, that we have taken the decision to commission
specialist economic analysts Aecom to undertake an independent
assessment of the IPS material. This work is still in progress,
but has very importantly identified a number of key issues so
far which cast serious doubt on the conclusions reached by the
IPS. The most serious concerns that I would wish to draw your
attention to are;
- The failure of IPS to provide a detailed cost-benefit
analysis.
- The limited range of options or scenarios that
have been analysed.
- Fundamental inconsistencies in the criteria weightings
which have been applied.
- The apparent lack of sensitivity testing.
DETAILED COST
BENEFIT ANALYSIS
The IPS Full Data Package indicates that a Multi-Criteria
Analysis approach has been adopted but only examines the internal
costs of office closure from a narrow perspective. It does not
report any detailed cost benefit analysis to show the overall
impacts of proposed changes, for example local social & economic
impact. The Treasury Green Book is clear that Multi Criteria Analysis
should not be a substitute for Cost Benefit Analysis.
LIMITED RANGE
OF OPTIONS
The Treasury Green Book is clear about the process
of selecting and testing options and the need for it to be wide-ranging,
but this approach does not seem to have been followed completely
in the IPS analysis. The objective of the IPS analysis appears
to focus on the single purpose of "closure" and therefore
only a limited range of scenarios or options have been examined.
In addition, the options that are carried forward do not include
a "do-nothing" scenario. Alternative options such as
reducing excess capacity across all centres are also not carried
forward in order to see if alternative options might be found
with a lower overall cost to society.
Reference is made to a partial closure option being
discarded at an earlier stage of analysis. However, the headline
costs and benefits of this option which led to this decision are
not expanded on in detail in the note. Arguments are mounted to
suggest that this option is not feasible. However, paragraph 7.6
suggests the Durham option is also not feasible and yet it is
included in the short-listing. This runs counter to the Green
Book principles.
The inconsistencies in defining the options and the
narrow range of scenarios examined continues to leave doubts in
the veracity and objectivity of the option appraisal process and,
therefore, confidence that the selected option truly demonstrates
value for money to the public purse.
INCONSISTENCIES IN
CRITERIA WEIGHTINGS
There appear to be internal inconsistencies in the
presentation of the approach taken to weighting in the IPS Full
Data Package. It is not clear that equal weighting is given to
each of the criteria as there are in fact 20 rather than six criteria
which contribute to the analysis, thus potentially skewing the
results. Greater clarity is needed to ratify the range of criteria
adopted and more explanation as to the basis of weighting the
criteria.
NO SENSITIVITY
TESTING
Sensitivity tests are needed to determine how much
the option analysis may be affected by different weighting assumptions.
IPS have suggested that the result of their assessments gives
a "clear view"—recommending the Newport Passport
Office for closure. The IPS view appears, however, to be based
on only a very small margin of tolerance, with Newport ranking
only two points above Peterborough and six points above Durham,
out of an overall total potential score of 100.
I am sure you will agree that it is important for
all of us to work together to ensure that when a final decision
is made about the Passport Office in Newport that it is based
on robust analysis which can be reported clearly. It is also important
that the decision minimises what might be seen as unintended consequences
that would be so detrimental to the economy of Newport.
December 2010
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