It is well over two years now since a highly significant “Procurement Policy note” emerged from the team at the UK government’s Cabinet Office. PPN 06/21 laid out how suppliers to government would have to provide “carbon reduction plans” (CRPs) if they wanted to bid for major public sector contracts. The new policy was aimed at supporting the wider government strategy for the UK to be “Net Zero” by 2050.
My sources tell me that the lead author of the policy was David Brambley-Crawshaw, previously a procurement practitioner by background who has worked on the policy side in Cabinet Office for a few years now. That means his writing has almost certainly been read by more people than I ever reach, as PPN 06/21 is still widely read, quoted and referenced today. He was also involved in running training sessions around the public sector after publication, and speaking internationally about the UK approach, which was pretty ground-breaking at the time.
But has the policy worked, has it actually moved UK carbon reduction forward? Well, the most fundamental point to make is that thousands of firms now have carbon reduction plans that they didn’t have before, and might not have done by now if the government hadn’t pushed them into it. And because the format was defined, plans are generally consistent, standardised, repeatable and recognisable from one supplier to the next. That is a big step forward from where we were.
Whilst some would like to see government pushing harder, equally no sensible procurement person wants to see large numbers of potential suppliers getting kicked out of procurement processes. Personally, I’ve been concerned for some time that various “sustainability” demands we put onto potential suppliers must be carefully targeted and managed – there is no point buyers making it virtually impossible for smaller, younger or less well resourced firms to do business with them. So there has to be a balance here. In a similar vein, I think the self-certification route for bidding firms was the right approach. We don’t want to see bidders having to employ expensive consultants to help put their plans together or to accredit those plans.
CRPs are supposed to be in the public domain so we should be able to find them on firms’ websites somewhere. That is obviously good from a transparency point of view. But whilst we don’t want to see mass exclusions, we would expect that maybe some suppliers have failed and been kicked out of a procurement process. My understanding is that has happened, but we are talking a very small single figure percentage of bidders.
The Cabinet Office is collecting data on CRPs from Departments, so has a grip on what is happening, and there have been training sessions for Departments. Crown Commercial Services has offered supplier training too, and has even reviewed a large number of firms’ CRPs and offered comments – that’s impressive and positive.
But any review of progress has to offer a few caveats. If a firm reports that its emissions are actually going up at the moment, there is no sanction on them. As long as the plan meets the criteria and shows an eventual decline, that’s OK. Surely that is a bit of a soft approach. Shouldn’t we be tougher on bidders who aren’t making progress?
However, this is a difficult area. Think of the outcry if “unelected civil servants” started barring suppliers because they “don’t think their plan is good enough”. Imagine the legal challenges as well! It is hard for any of us to question and make judgements on how exactly firms are going to hit net zero, particularly if we don’t really understand their business, their operations and their sector. And, for instance, business growth or acquisitions can change the picture.
No doubt some commentators would like to see government tightening the process; but the risk as described earlier is of unintended consequences, perhaps less competitive markets and higher barriers to entry – and indeed a cost burden on bidding firms. I do wonder however whether some sort of intermediate targeting might be a sensible next step. 2050 is a long way away and many firms have plans which are suspiciously “hockey stick” in nature – slow reductions in the next few years then a sudden miraculous decline as we get closer to 2050!
The other possible step would be to bring more contracts into the process. At the moment, in England the policy only applies to those with a value of over £5 million a year. That threshold could be reduced – but then we get into the issue of the burden for smaller firms who want to bid. It is another tricky question.
Of course, the policy should not be seen simply as a burden and a negative for suppliers. There are opportunities for firms to make savings and reduce emissions, whether that is through energy efficiency, more recycling, reducing waste or finding more efficient suppliers of their own. Pushing some suppliers who weren’t previously thinking about these issues into doing so as they construct their plans must be a positive.
We are in the age unfortunately where our Prime Minister has decided he is “on the side of the motorist” and green action is all a bit too “woke” for the average British voter. Hence the work on carbon reduction probably has not got the political support it deserves in the last year or so. I’ve also never been convinced quite how strongly Gareth Rhys Williams (government’s Chief Commercial Officer) feels about this. I can’t find any motivational speeches from him on the topic anyway! But maybe that too is a sign of how a top civil servant has to respond to the political currents.
But overall, I feel this policy has been a qualified success, a seven or eight out of ten. We can’t really measure its effectiveness in terms of the ultimate desired outcomes; however, let’s give Cabinet Office and the team credit for making a difference, and doing more than most countries have managed.