New OfS paper shows move towards sustainability

25th February 2020

Since HEFCE was disbanded in 2018 and replaced by the Office for Students (OfS), there has been a gap in formal policy oversight and regulation for the Higher Education sector on sustainability and emissions reduction. In particular, EAUC has been a vocal opponent of the decision to remove the mandate from institutions in England and Northern Ireland to provide emissions data through the EMR.
 
OfS stated that in accordance with the Higher Education and Research Act 2017 they are required to be a low-burden regulator, and stated that measures on sustainability are not part of their statutory functions.
 
A fortnight ago (10^th February 2020), Wonkhe published an article titled ‘Are we losing focus on the sustainability of the English university sector?’ critical of the OfS and the lack of value they have placed on the EMR data.
 
OfS responded with their own article; ‘OfS won’t be silent on sustainability’. In it, Chair of the OfS, Michael Barber, said: “I was surprised to see comments in Wonkhe’s Monday morning briefing that the OfS “doesn’t care” about the work universities and colleges are doing to cut carbon emissions. This is simply not true. The OfS board recently met to look at precisely these issues.”
 
It goes on to talk about how sustainability is the issue of our time and they want to support the sector on this agenda.
 
Last Friday, OfS published the Board meeting minutes mentioned - featuring a paper proposing an approach to reducing the higher education sector's carbon emissions. So we can now get a really good look at the discussions going on at Board level in OfS.
 
What are OfS saying?
Firstly – they have acknowledged that OfS should act on carbon emissions resulting from Higher Education in the UK. This is a big step in the right direction as previously they have said it isn’t – stating that measures on sustainability are not part of their statutory functions (as mentioned above).
 
They have now outlined three areas in which they believe their statutory functions would allow them to help on this agenda:

• Carbon emissions reporting for providers
• Drawing attention to the sector’s carbon emissions
• Funding for decarbonisation

 And they have come up with five recommendations:
 

• Agree that the OfS should support registered providers to meet the targets set by the Climate Commission for UK Higher and Further Education, through the interventions described below
• Agree that there should be a consultation by the OfS on the future collection and publication of carbon emissions data from registered providers
• Agree that the OfS should publish information on the sector’s carbon emissions, and students’ attitudes to climate change, to encourage providers to act
• Agree that the OfS should signpost the option of Salix loans to providers and explore the possibility of linking OfS capital funding to decarbonisation
• Note the development of an internal OfS sustainability plan.

 
They also suggested they could:

• Survey students on whether information about providers’ efforts in tackling climate change could influence where they choose to study; and if they feel their provider is doing enough
• Publish an Insight Briefing and convene an Insight Event focused on student concerns about the climate emergency and the sector’s record on reducing carbon emissions. The briefing would include publishing an analysis of data from the HESA EMR to determine the sector’s progress against the original HEFCE emissions reduction target from 2010. It could also include survey data on student attitudes to climate change.
• Motivate the providers that are not already involved with existing sector initiatives that see the supply of EMR data. This might be in the form of collecting data as part of an existing mechanism, such as the annual financial return.

 
OfS and EAUC
OfS mentions EAUC multiples times in the board paper, referencing EAUC’s work on the Sustainability Leadership Scorecard alongside AUDE, funded initially by the former HEFCE, and EAUC’s work with UUK, GuildHE and AoC on the Climate Commission. They also mention EAUC’s work with Salix as well as the Global Climate Letter. They say EAUC is playing a leading role in the sector.
 
OfS and risk
We were pleased to see a good comprehension at OfS of the risks they face by NOT acting on this agenda. OfS say that ‘pressure to tackle emissions will only increase, from students and the public, as the effects of climate change become more evident’, that the lack of attention given to the sector and their emissions will not continue and that ‘OfS risks political and reputational damage if it is seen as having actively ignored the issue by ending the collection of emissions data’. These are risks that institutions also face if they do not act to reduce their emissions and report on this. We hope this comprehension spreads more widely to executive level staff throughout tertiary education.
 
Concerns
Despite how promising this discussion is, EAUC is concerned about a few elements:

• There is much to do, and many of these recommendations do not reflect the urgency in which we need to act as a sector.
• We need clarity on what ‘support’ looks like for the Climate Commission targets – because it needs to be funding and regulation. Without regulation in their remit, OfS should work with DfE to look at regulatory possibilities on emissions reductions across the whole education sector.
• In the recommendation relating to continued collection of EMR data, OfS have suggested they will look to support institutions that have not continued to voluntarily submit EMR data (or never did) by getting them to submit information through other pre-existing reporting processes like annual financial returns. This is problematic because EMR data requires a lot more detail that this, it is a rich source of data, and alternative sources would not enable this level of data to be provided. There was also a suggestion that smaller institutions could be exempt – but no one can be exempt. The legislated 2050 net zero target for England (and alternative devolved targets) mean everyone must get a handle on their emissions now – no exceptions. Smaller institutions will need more support with this.

 
Conclusion
So in conclusion, this could be the start of constructive conversations with OfS on the sustainability agenda. We are hopeful.

Aude's view on this
AUDE’s Executive Director Jane White has said: 
"AUDE remains firmly of the opinion that the decision to make collection of the EMR data a voluntary rather than mandatory one for English and Northern Irish universities was a backwards step. A complete national dataset is an essential decision-making tool in our universities. It is interesting to see the interaction between the OfS and the NUS around these issues via the published OfS minutes. AUDE is happy to co-operate across the sector on the shared sustainability agenda, and we believe we would all benefit from continuity around the data which until recently of course we had. There is no need to tie ourselves in knots searching for a solution here – we simply need to reverse the decision, so that once more we have a national EMR dataset that we can all use to benchmark, provided by mandatory instruction.
 
"The Sustainability Leadership Scorecard was co-developed with AUDE, the EAUC and Arup - using public money. It is our best current tool in supporting the sector to face up to sustainability challenges. It is being used already in more than 100 institutions. It is based around the EMR data – the very dataset at risk of degradation over time unless we reinstate its collection as a mandatory activity. Given that HEFCE funded the development of the SLS, the risk to the SLS caused by such degradation of the underpinning data following the OfS decision, is ironic to say the least.
 
"Our students and parents, and staff, view climate change as “the number one issue”. Nothing about our shared work on sustainability should be “optional” – whether that is in our thinking about recycling, renewables and energy generation, or our policies around scope 3 emissions. It is a collaborative task and we have to set out firmly in the mindset of helping others to help ourselves."