APPENDIX 1
PUBLIC SECTOR COMPARATORS AND CAPITAL
CONSTRAINTS (PAC 99-00/247)
Supplementary memorandum by the National
Audit Office
The Committee has recommended that sound decisions
on whether to proceed with PFI deals should be based on a systematic
examination of comparisons between each proposed deal and realistic
alternative options [42nd Report, Session 1997-98 (HC 348): Skye
Bridge]. In the case of the National Savings deal with Siemens
Business Services the C&AG's report [HC 493, Session 1999-00]
states that the Department constructed a public sector comparator
against which to assess the proposed PFI deal. The Department's
analysis showed that the PFI deal was expected to lead to a net
present cost of £635 million, £158 million lower than
the Public Sector Comparator net present cost of £793 million.
In evidence to the Committee, the Managing Director
of Siemens Business Services said that one of the reasons why
his company's bid was so much cheaper than National Savings' Public
Sector Comparator was that it would not be subject to the constraints
on capital spending to which National Savings would be subject.
The question therefore arose as to whether it would be legitimate
in comparing the PFI deal with the Public Sector Comparator to
include the impact on the Public Sector Comparator of presumed
constraints on the public funds available to the department.
There are currently two prime sources of guidance
from the Treasury on the use and construction of comparators in
the appraisal of Public Finance Initiative projects:
Treasury Task Force Policy Statement
No 2: Public Sector Comparators and Value for Money.
Treasury Task Force Technical Note
No 5: How to construct a Public Sector Comparator.
These documents refer to a further source of
guidance, "The Green Book" (Appraisal and Evaluation
in Central Government, HM Treasury 1997).
The question of capital constraints is addressed
in Policy Statement No 2, which distinguishes two cases:
(a) where there is a genuine choice between
procuring a service following PFI principles and procuring the
same service using conventional funding;
(b) where the realistic alternative to PFI
procurement will be the pursuit of the same policy objective with
no or much lower investment in new assets.
The Policy Statement recommends that the Public
Sector Comparator be based on the full cost of providing the services
specified to bidders including the full cost of the assets that
the public sector would have constructed. In the latter case,
the Statement says that there is a choice to be made between preparing
a comparator on the basis of what is affordable, within the existing
public expenditure allocation, or preparing a notional calculation
based on the assumption that additional public funds are available
to construct new assets. The Statement advises procurers to consider
two points in making this choice:
the likelihood of conventional funding
being made available and whether the creation of a comparator
which is unaffordable would be misleading; and
the difficulties of making an objective
comparison between a bid and a constrained comparator which is
necessarily based on different levels of service.
Where the arguments are very finely balanced
the Statement says that it may be appropriate to examine both
the constrained and unconstrained options.
The issue is also examined in Technical Note
5, which states:
"Sometimes Public Sector Comparators are
constructed on the assumption that major construction work will
be delayed due to constraints on the availability of public capital.
This approach is not recommended as any assumptions made re inherently
non-verifiable and recent history, particularly in the health
sector, has shown that levels of available public capital can
be quite volatile even over relatively short periods. If there
is any doubt regarding the availability of public capital, sensitivity
analysis should be undertaken to quantify the effect of delayed
construction work. However, assumptions about the start, completion,
and if applicable, the phasing of construction work should reflect
what could be realistic to expect in the public sector and will
not necessarily correspond to bidders' proposals."
The Green Book contains guidance on investment
appraisal in general. It addresses the issue of expenditure constraints
in the following terms:
"Expenditure may be constrained in particular
years. An expenditure constraint does not reduce the importance
of appraisal, but rather enhances the importance and technical
difficulty of choosing those uses of limited funds, which will
provide the greatest benefits. It may influence the choice of
options, if options, which would otherwise be preferred, require
higher expenditure in the period during which the constraints
are expected to be most severe.
However, if the constraint is expected to be
no less severe in the longer term than the shorter term then this
should not generally lead to capital rationing of investments
which reduce public costs or increase public revenues. Making
room for such investments within the overall expenditure ceiling
may cause great difficulty; but the savings they generate will
bring equally great relief."
National Savings followed all of this guidance.
Because National Savings senior management considered that there
would be doubt about the availability of public sector capital,
in accordance with the guidance, they examined the sensitivity
of the comparison between the PFI bid and the public Sector Comparator
to changes in the assumption about availability of public sector
capital. The outcome of this sensitivity analysis was that, in
the absence of any constraints on the availability of public sector
capital, the Public Sector Comparator would have had a net present
cost of £748 million. This figure was still higher than the
£635 million cost of the PFI deal, but by a smaller margin
than the £793 million cost of the Public Sector Comparator
without access to additional capital funding.
National Audit Office
4 October 2000
|