Written evidence from Prospect Trade Union (UKR0029)

Introduction and summary

Prospect is proud to represent more than 157,000 members working across several regulated and safety-critical sectors of the economy including aviation, defence, education, energy supply, food, IT and telecommunications, media and entertainment, nuclear, science, and transport, as well as in a wide range of regulatory bodies and agencies.

Prospect believes that effective, evidence-based regulation is vital to protecting our health, our safety and our natural environment, and provides an essential foundation for a well-functioning economy and a fair society.

Regulation in the public interest protects consumers, businesses, society or the environment from disproportionate risks of unfair treatment or serious harm, and ensures the appropriate monitoring or management of those risks. Regulation is not a burden, but an intrinsic expression of government determined to ensure activities that could otherwise create risks or harm are eliminated or mitigated.

This is also the mainstream view of UK businesses and consumers. Most businesses do not see “the overall level of regulation in the UK” as “an obstacle to business success”, or disagree with the statement that “most regulation is fair and proportionate”.[1] The CBI has been clear that “businesses are not … clamouring for red tape to be reduced”.[2]

A report on post-Brexit public opinion by right leaning thinktank Legatum found few subscribing to the view that “regulation is often an unnecessary burden”, with most believing “regulation is often necessary”.[3] The former Tory chair of the Treasury Select Committee has recently argued that weakened regulation is creating a “crisis in capitalism” as citizens, consumers and workers feel ripped off and unprotected.[4]

These views are echoed by Prospect members working in industries for which regulation is particularly important:

              “We need regulators to help ensure safety in all its guises.”

- Prospect member, electricity supply industry

“Personally, I’m happy with the environmental regulation we have – the limits can make life tricky but that seems [a] small price to protect our home.”

- Prospect member, nuclear sector

Effective regulation requires both the right frameworks of rules and responsibilities, and, critically, properly resourced organisations to promote and enforce those frameworks. Many of the UK’s regulatory agencies are rightly regarded as world leaders in their fields. Their expert employees constantly work to identify emerging new risks to individuals, communities and the environment, adapt to a changing economy and technological landscape, and improve their efficiency and effectiveness.

But their jobs have been made more difficult by recent policy trends. Since the 1980s,[5] governments have placed great stress on reducing the alleged “burdens” on business[6] of complying with regulations without adequately weighing the potential costs and risks of excessive deregulation to businesses and society.[7] This has been compounded by deep cuts to the budgets and staffing levels of most regulatory agencies as part of the government’s austerity agenda.

Prospect is proud to champion the dedication and expertise of our members employed in safety, environmental and other regulators, whose hard work, in often challenging circumstances, protects and enhances all of our lives in countless ways. We also stress that effective regulation is a collaborative enterprise, contributed to by many others we represent – such as those who help to deliver the science upon which good regulation is based, or those who contribute to the upholding of standards in their role as health and safety reps, environmental reps, or more generally as advocates of good business and workplace practice.

1) Are UK regulators being given a clear job to do?

The answer to this question is bound to be varied. Many regulators have comparatively tight and technical remits, others carry out a range of functions – not all of them exclusively regulatory – and can find themselves subject to public expectations and political pressures that can be complicating and, at worst, in conflict with one another. We would argue too little has been done to develop a coherent expression of the basic tenets of public interest regulation which would provide the platform for the broad span of regulatory activity.

Responding to this inquiry, Prospect members at the Health and Safety Executive (HSE) highlighted the expanding range of issues the organisation was expected to address in response to recent policy and political developments:

“HSE has a clear role to regulate the Health and Safety at Work Act and associated regulations, more recently its remit has expanded (post-Brexit chemical regulation and post-Grenfell building safety regulation). This has broadened its role from the workplace to the built and natural environments. These expanded roles are currently funded from the accounts of other government departments (DEFRA and DLUHC). Currently HSE has been asked to contribute to the government’s Net Zero commitments, looking at how the move towards Net Zero will impact on workplace and public safety. The traditional roles of HSE – workplace health and safety – are constrained by government policy (see below) and also HSE’s inability to prioritise enough resource towards being truly effective in ensuring that workplace death injury and ill health are minimised.”

The Government’s attempt to add the promotion of “economic growth” to regulators’ jobs has also raised concerns about potential tensions and trade-offs. Prospect members at the Civil Aviation Authority (CAA), for example, are sceptical about this agenda:

“Economic growth is often conflated with commercial interests and those interests are sometimes in conflict with public safety. The CAA’s primary role is aviation safety and this should not be compromised.”

Members at the Office for Nuclear Regulation (ONR) suggested that their recently established statutory footing gave them a comparatively clear and contained job:

“Having a relatively new statutory base (The Energy Act 2013), our purposes are well defined legally, as are our statutory duties and those where, as a regulator, we have discretion. We also have clarity over how ONR is funded, largely directly from the industry we regulate.”

Economic regulators focused on commercial and cost considerations may not have the resource or bandwidth they need to take adequate account of social, safety or strategic issues – issues that “market forces” alone cannot solve and may actually work against. As recent work by the Resolution Foundation has argued:

“The primary focus [of economic regulators at the point of their establishment] was on improving operational efficiency, and privatisation was designed to introduce commercial incentives and freedoms to drive down costs, including through workforce reform. Improving access to capital, which had been constrained under public ownership, was also a goal but primarily with a view to network upgrades and maintenance, rather than investment or transformation at scale.”[8]

For example, at times Ofcom’s regulatory interventions in the telecoms sector have prioritised price reductions or new market entrants over long-term investment in and modernisation of the digital infrastructure and services that have become critically important for building a more productive and competitive economy and fairer and more inclusive society.[9]

Similarly, there have been concerns that in the energy sector “network price controls have the potential to stifle investment at the exact moment it is most needed”.[10] In addition to Ofgem facing public criticism for falling short on financial oversight and fair treatment of customers, Prospect has for some time been raising concerns about Ofgem’s failure to prioritise the investment in workforce development needed to deliver the transition to net zero. We welcome the new net zero duty for Ofgem introduced in the Energy Act 2023 but believe government needs to go further to clarify Ofgem’s role in developing a skilled workforce. This could be done, for example, through explicit expectations set out in the government’s strategy and policy statement for energy governed and enforced by a net zero energy agency.

The need for proactive development of the energy skills base is illustrated by Prospect’s recent survey of workers in transmission and distribution networks which showed that:

         More than two thirds (69%) of workers report skills shortages or gaps in their organisation, with widespread concerns about a lack of engineers.

         Four out of five (82%) say staffing levels are too low in their workplace.

         Nearly two thirds (63%) currently have vacancies in their team.

         Three quarters (74%) describe their workload as ‘heavy’ or ‘extremely heavy’ and excessive workloads are cited as the biggest factor driving low staff morale.

The UK’s net zero infrastructure will not be delivered without a wider commitment to investment in skills. Yet Ofgem continues to declare itself content for networks companies to pursue their own workforce strategies without active oversight. If this is deemed not to be a core issue for Ofgem then responsibility and accountability should be allocated elsewhere.

We do agree with the approach in the Winser review that achieving net zero requires a structure for transmission projects (both new generator connections and wider network reinforcement) that allows for a more efficient holistic/strategic system approach to be taken when designing these, rather than the current structure that drives treating each project in isolation. For example, under the current Ofgem regime, a new connection project is set up now to only consider that connection. There is no effective or easy mechanism to install or design for more than is necessary at the time for that one developer, otherwise the transmission company would need to pay for it itself with no guarantee of recovering those costs.

As one Prospect member put it:

“This means that it is difficult to spend a penny today to save a pound tomorrow on works that will be, on balance of probability, required in the future. There needs to be an easier way for transmission companies to have their costs underwritten when there are opportunities to carry out additional works that would facilitate future foreseeable developments of the system.”

2) Is the right balance being struck between the responsibilities of regulators and those of the Government, particularly where there are political or distributional trade-offs that need to be resolved?

In many areas the answer has to be no. Regulation needs to be sufficiently independent of the Government of the day to be fair, credible, and have the confidence of stakeholders and the wider public. Government should be responsible and accountable for issues over which it has control, such as overarching policy and funding allocation.

Too often regulators’ effectiveness and credibility are put at risk by politically driven decisions and agendas. Our members at the HSE told us that:

“Government continue to meddle and constrain the HSE, in size and policy direction, preventing it from developing an approach/model of regulation that considers broader public/stakeholder expectations - expectations that became visible during the pandemic.”

Failures or shortcomings that can result from poor policy or decision-making at Government level can then too often be blamed on regulators themselves. At least some of the recent public criticism of bodies such as Public Health England (regarding Covid responses) or the Environment Agency (regarding river pollution) would be better directed at governments that have underfunded these agencies or in other ways constrained their ability to recruit and retain the staff they need to deliver the services that are expected of them.

3) Are regulators appropriately independent of government? Is the right balance being struck between strategic and political input from government and preserving the operational independence of the regulators?

One of the most important factors determining the effective independence of regulators is resourcing. Most are dependent on Government for a major proportion, if not the overwhelming majority, of their funding. This means their ability to carry out statutory or other publicly proclaimed functions is significantly affected by decisions over which they have no control, and which are too rarely subject to public scrutiny or accountability.

This point was strongly made by our members at the HSE in response to this inquiry:

“In HSE independence is fettered by government’s tight control of resources in terms of Grant-in-Aid cuts over thirteen years. Alternative funding models could raise further income if an industrial levy based on risk (collected via employers’ liability compulsory insurance providers) was introduced – this would allow long term planning and enable independence from political funding decisions. The 2011 ministerial statement made by Chris Grayling (Good Health and Safety, Good for Everyone) set the deregulatory agenda of the then and now current governments. This included the introduction of the Fee-For-Intervention model, the cessation of inspecting many sectors (classified as “low risk”) and the introduction of the finding of the Löfstedt review. HSE has had to work within the parameters of government policy, and not necessarily in line with appropriate regulatory oversight, nor consultation/consideration of the concerns of other stakeholders with a different perspective, such as trade unions. The Public Bodies Review of the Health and Safety Executive (HSE) and the previous Tailored Review recommend that HSE should become a Non-Ministerial Department.”

In the past Prospect members have also highlighted the impact of funding cuts on the effective independence of regulators such as Natural England, which was forced to merge IT, finance, HR and communications functions with its parent department. Former chair Andrew Sells commented that “what I think started as a cost saving has run over into something which feels more like less freedom, frankly … in truth, we have lost a lot of independence.”[11]

Independently of funding sources, most of the regulators which have a statutory role and are organised as public bodies are subject to policies and controls on pay and other workforce issues imposed from the centre of Government. This can significantly compromise their independence and effectiveness. For example, Prospect members at the Office for Nuclear Regulation said that establishing the body “with its own board and independent freedoms” had been key to its effectiveness, but warned that:

“increasingly government focus on control over ‘public sector’ pay and other aspects of public body operation reduces the effectiveness of these freedoms.  We are independent in our regulatory decision-making but less so in the use of resources to make those decisions.”

Arguably the decision for Ofgem to determine and introduce a quarterly price cap for consumers has drawn it perilously close to political decision-making. 

4) Does the Government provide too much or too little guidance to regulators in making decisions, particularly in deciding between different objectives and priorities?

Scholars of regulatory systems have long recognised that ensuring regulatory agencies have  expert and experienced staff with the ability to exercise appropriate discretion and provide well-tailored advice is one of the most important ways of ensuring regulation does not rely on overly mechanical or prescriptive rules.[12] This is implicitly recognised in the Government’s recent work on regulation and innovation, which combines a renewed commitment to “an outcome-focused” system with promises of more “clear and timely regulatory advice”. [13]

Prospect welcomed the Government’s decision earlier this year to designate the first strategy and policy statement for energy, which allows it to provide strategic direction to Ofgem while maintaining regulatory independence. However, we are concerned that the draft statement published by government fails to sufficiently clarify government’s priorities for the energy system or Ofgem’s role in delivering it. 

6) How effectively do regulators co-operate with one another, and how could this be improved?

In the Labour Market Enforcement Strategy for 2022/23, the Director of Labour Market Enforcement, Margaret Beels, indicated that there were enforcement gaps between agencies. As a result, the sectors most likely to exploit vulnerable workers were the same each year, despite intervention from agencies that are part of the Office of the Director of Labour Market Enforcement’s Strategic Coordination Group. Beels says this is partly because each agency is responsible and accountable for delivering against issues that fall within their own legislative domain. The risk then is that gaps between these remits can be exploited.

These issues have led some to call for the creation of a Single Enforcement Body. However, we are concerned that moves such as this can result in a loss of focus, expertise and resources in areas that are already woefully underfunded. In particular, we are strongly opposed to any risk to the independence and discrete role and focus of the Health and Safety Executive.

In general, we believe the solution to such gaps is increased investment and powers for regulators, and better focus on information sharing across them, not potentially costly and distracting reorganisations. In this case the Director of Labour Market Enforcement herself calls for "better joined-up thinking, where the enforcement bodies take a more holistic approach in tackling issues across the labour market working even more effectively with agencies and stakeholders beyond the labour market".[14]

7) Do the UK’s regulators have the necessary skills, capabilities and expertise internally to perform the roles they have been given? If they do not, how could this be improved?

It is vital to ensure that regulations are well designed, evidence-based, and enforced through sufficiently resourced and staffed research, monitoring and enforcement agencies.

Some of the challenges regulators face in this area are the result of industry- and economy-wide pressures, such as the general shortage of key technical skills in areas such as digital and data, science and engineering, and more specialised professions. For example, members at the Office for Nuclear Regulation noted that:

“the level of real deep competence and capability across ONR sees the same challenges as the industry we regulate - capacity and capability are not the same and a strong, effective regulator needs that deep understanding not only of regulation, decision-making, strategy and insight, but a deep understanding of the industry we regulate which is essential for good outcomes and this experience and strategic view does link to higher salaries than perhaps some more routine regulatory bodies and challenges.”

However, ONR does seem to offer a positive example of a regulator where, in the view of members, resources and flexibility have been sufficient to allow it to focus on recruiting and retaining the skills and expertise it needs:

“ONR has been well resourced and focussed on professional rates of pay for professional people, largely because the public expects a strong, well-resourced independent regulator where hazard potential is high. Moving ONR outside the Civil Service and establishing it with its own board and independent freedoms has been a key part of that.”

This is not always the experience of industry-funded regulators, however. Prospect members working in the aviation sector have highlighted that:

"The CAA is likely to face extensive challenges when attempting to recruit candidates for the technical, expert and specialist roles that require industry qualifications, skills, knowledge and/or experience. In response to the existing shortages of trained and qualified staff in the industry, employers are obliged to use pay and conditions to retain and recruit – something which is likely to make the CAA increasingly uncompetitive.”

This is because:

“The CAA’s current funding model does not support paying industry wages or benefits packages, which is increasing the challenge in recruiting the right staff with adequate knowledge and experience to carry out safety oversight work, exacerbating the pressure on existing staff and increasing the challenge of retention.”

Most government-funded regulatory agencies have seen their capacity and capabilities severely stretched over recent years as a result of real terms funding reductions and other constraints such as the Civil Service pay cap. Increases in funding seen by some regulators in recent years still fall well short of a restoration of previous real terms levels, and in many cases (seen in the HSE, for example), reflect or are earmarked for additional responsibilities and workloads.

Sources: Prospect analysis of Annual Reports, adjusted using OBR figures for GDP deflator.

Sources: Prospect analysis of OBR data, annual Civil Service Pay Remit Guidance, and private sector pay award data from Incomes Data Research

Funding cuts and pay caps have left social and environmental regulators struggling to fulfil their statutory duties or recruit and retain the staff they need. Last year, the Chief Executive of the Environment Agency issued a rare public warning that “the EA’s ability to deliver all the vital outcomes on which the nation depends” - including “regulating industry to protect people and the environment; protecting our water, land, air and biodiversity; supporting economic growth” was being negatively impacted by “the growing gap between the salaries the government allows us to pay our employees and private sector salaries”. One Prospect member at the Agency recently told us:

“I’ve worked at the EA for 24 years in permitting and front-line regulatory functions. For the last 14 years my job has been assessing environmental compliance at large industrial installations in the South West of England, including major landfill sites and food manufacturing facilities. I am a criminal investigator responsible for bringing polluters to justice and have achieved multiple convictions for serious pollution offences by nationally significant companies, with national press coverage. Where appropriate I intervene using statutory powers to ensure communities are protected from amenity pollution (especially odour and noise), and that industrial emissions to rivers are tightly controlled to minimise adverse impact. In all this time I have never known morale in the Environment Agency fall so low...

“The pay crisis has become an emergency in the last couple of years, with steep rises in inflation rapidly eroding our spending power. For many staff there is now too much month left at the end of the money. Nobody works at the Environment Agency to get rich, but you expect to be able to live with dignity and pay your bills...

“There is less and less to keep skilled staff at the Environment Agency now, and more staff are leaving for much better paid jobs either in private consultancy, at water companies or other private industries, or even in entirely unrelated sectors.”

In relation to habitats regulation assessments, Natural England has warned that “there is a lack resources across government bodies and local authorities to effectively implement environmental regulations and deliver the Government’s ambitious environmental agenda. The sector lacks sufficient capacity and specialist environmental skills, particularly for ecology, landscape and soils... Natural England, like other government bodies, has difficulty recruiting and retaining suitably qualified and experienced staff”.[15]

In evidence to the House of Lords inquiry on the impact of environmental regulations on development, the Deputy Chief Executive of Natural England reported that while relief from the funding cuts of the past decade had enabled the organisation to recruit again, “we did lose experience” and “the skills we have brought in are not necessarily as expert as some of those we have lost”. The Chair also noted that growth in staff capacity “has stopped for now” and that “considering that we have, I would say, uncompetitive salaries compared to some other organisations, we find that in some skill sets, including planning, we struggle to recruit … We are dipping in the same pool as the developers and everyone else”. As an example, the Deputy Chief Executive cited “development planning for offshore wind energy” where “we have at times been at only 70% capacity in those work areas because of the difficulty in finding the right skills on the market”.[16]

Prospect members at the Environment Agency and Natural England[17] as well as other key agencies like the Health and Safety Executive[18] have been highlighting the costs and risks these false economies create. A member at the MHRA recently told us:

“We have lost a stream of experienced and well qualified experts over recent years, and most of them have been replaced by fresh graduates because we can’t afford to recruit experienced staff. Our IT systems are out of date and woefully inadequate. This means that we are using outdated systems and processes at a time when public interest in medical device safety is at an all-time high.”

The recent independent Public Bodies review of the Health and Safety Executive reported a “shortage of staff in specialist areas such as pipelines, radiation, fire and occupational hygiene, as well as digital and IT” and that “a level of pay commensurate with the importance of the roles involved would be most effective” in addressing this.[19] In response to this inquiry, members at the HSE told us:

“in general HSE has the appropriate people, but capacity is an issue, recruitment in many specialist fields is difficult, as pay is low to comparators, leading to gaps, and retention in many areas is problematic as recently trained staff go to the private sector for better pay and HSE then have to replace them with new trainees – this is a drain on resource, to recruit and train (particularly in through grading areas) and also impacts on productivity acting as pressure to reduce outputs . The Public Bodies Review provides commentary on the concerns expressed outside of HSE around resourcing levels. The review report also lists shortages of specialist staff in pipelines, radiation, fire, occupational hygiene, and digital/IT. Prospect would argue that this list is not exhaustive and should include, regulatory inspectors, regulatory scientists and a range of other specialist disciplines.”

As a trade union with members in regulatory agencies and regulated sectors, we see the problems this can create from both ends. In recent years, members working in safety-critical industries have highlighted concerns about the impact of funding cuts and staff shortages on their own areas of work. One told us:

“I am the manager of a service which is directly regulated by the Health and Safety Executive under the terms of the Ionising Radiations Regulations … There are widespread concerns that a diminished engagement by regulators could lead to the gradual slippage of standards … and more importantly leaves services such as mine more exposed to commercial and other pressures, which often operate in the short term and don’t consider the longer-term challenges of maintenance of skills and capabilities.”

Some regulators have sought to manage with constrained resources by merging roles or widening staff responsibilities, but this can pose a risk to regulatory objectives. In response to this inquiry one of our representatives at the Animal and Plant Health Agency told us

“Some roles are blurring and arguably being dumbed down. The all singing, all dancing inspector has long been a holy grail for some in official side. Too wide a spread of knowledge and responsibilities can result in a lack of depth of expertise – ok until something goes wrong. The specialist is to some extent seen as a luxury. Beware diluting expertise to such an extent that it is threadbare and unable to cope with only the basics of a role. Blended and multi roles can give rise to a lack of clarity and conflicting demands on an individual with different lines of command jockeying for position/priority.”

In some areas pressures have been exacerbated by the additional functions and workloads, and lost access to shared resources, following from the UK’s exit from the European Union. The National Audit Office last year highlighted these pressures at the Health and Safety Executive, which said it “expects it will be a further four years before it reaches the full capacity it has planned for its post-EU Exit regulatory regime”, and the Food Standards Agency, which was “facing challenges in recruiting increasing numbers of staff with expertise in toxicology”.[20] Our members at the Civil Aviation Authority report similar issues:

“EU exit has increased the workload on the authority through the divorce from EASA and becoming an independent National Aviation Authority (NAA), and changing political priorities complicate the regulatory environment increasing the demands on staff. The oversight of international aircraft maintenance organisations has over doubled the domestic oversight requirement, and the workforce to meet this demand has not yet doubled.”

There are also challenges in ensuring that economic regulators, such as Ofgem, have an appropriate skills base to effectively manage expansions in scope. For example, Ofgem’s additional duty to promote Net Zero will requires broader technical expertise than its core focus on consumer price regulation. Additional duties must be underpinned by appropriate and adequate resourcing.

8) Who should hold the regulators accountable for their performance against their objectives? What is the appropriate role of Parliament in performing this scrutiny role?

Regulators should be appropriately independent of the government of the day but clearly accountable to relevant stakeholders, Parliament and the wider public. The trend has been for these lines of accountability to be confused and corroded.

In response to this inquiry members at the HSE told us:

“The tripartite Health and Safety Commission was replaced with a board to which the government appoints employer and employee representatives. Several appointments have not followed the long-standing protocol of preferred employee nominees being nominated from the TUC. The process should be reviewed so that preferred nominees have a seat on the board.

“The current way that HSE develops its long-term strategies is flawed as it doesn’t consult widely to obtain a broad range of views/expectations.

“Current KPIs for HSE (which are set by HSE) do not include anything other than some vague references to efficiency, ie. doing a percentage of an activity within a set timescale. For example, 90% of non-fatal accident investigations should be completed within a year of incident. This sounds reasonable, but if there are 10,000 serious accidents, and resource only allows for the investigation of 1,000, the majority are not considered in the aim. The other 9000 have to be neglected, and not followed up, meaning they are discounted from the counting, and the 90% target becomes achievable.

“Metrics for percentages of RIDDORs (accident reports) investigated, enforcement notices served, and prosecutions are no longer reported in Annual Reports. This means there is limited scope for year-on-year comparisons of performance. In addition, the way in which HSE categorises its staff - in particular the inspectors - is opaque; over years it has lumped all grades together, failed to differentiate between regulatory inspectors and trainees, and more recently it presents the regulatory staffing to include non-inspector visiting officers.”

9) How should the Government and the regulators themselves facilitate appropriate scrutiny and accountability of regulators? Are regulators sufficiently transparent about their own performance?

Prospect welcomed the inclusion, in the new “Public Value Framework” that the Treasury has indicated will inform the next Spending Review, of key questions around “workforce capacity” including the need for “good, accurate workforce data” and a requirement on public bodies to develop a plan “to build the skilled workforce it will need to continue to deliver and adapt to future changes”.[21] But there is little evidence that this approach has been embedded as anything other than a tick-box exercise.

Against this background we see a strong case for a new formalised, statutory responsibility for civil service leaders to maintain, over time, the capability of the UK Government to provide expert, evidence-based policy advice, to execute policy decisions efficiently and effectively, and to monitor and evaluate policy impacts and outcomes. 

Regulators’ engagement with, and openness to, relevant stakeholders, including representatives of affected groups of workers, is highly uneven.

A broadly positive example of effective partnership working between regulator, business and workforce is found in the electricity industry’s National Health and Safety Advisory Committee (National HESAC) which brings together representatives from member companies with trade unions and the Health and Safety Executive. This has led to the development of a number of campaigns and guidance which, along with the ability to share information about industry trends and developing risk, have helped protect workers' health and safety.

Stronger formalisation of stakeholder engagement, consultation and representation in other areas could offer a valuable counterweight to the threats posed to regulators’ independence directly from political interference or more indirectly by their general dependence on Government or regulated businesses for funding.

10) What mechanisms and metrics could be used to hold regulators accountable on a regular and ongoing basis and to judge whether a regulator is performing well?

Members at the HSE told us:

“HSEs current metric do little to prove it is performing well as a regulator. It can show it is performing well against its arbitrary internal derived targets, but this masks the struggling nature of the organisation created by thirteen years of resource cuts. Metrics, should be determined by a broader view, via an external consultation, and should be comparable over time.”

30 November 2023