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HEFCE Consultation for 2013-14 and Beyond: Student Number Controls and Teaching Funding

The Higher Education Funding Council for England (HEFCE) has launched a consultation into Student Number Controls and Teaching Funding. More information about the consultation is availble here:

Submission to the HEFCE Consultation for 2013-14 and Beyond: Student Number Controls and Teaching Funding

This submission has been produced jointly by five organisations which, between them, represent a significant part of the UK geoscience community, spanning academia, industry, government and the student population. They are:

i. The Geological Society of London (GSL) is the national learned and professional body for geoscience, with over 10,000 Fellows (members) worldwide. The Fellowship encompasses those working in industry, academia and government, with a wide range of perspectives and views on policy-relevant geoscience, and the Society is a leading communicator of this science to government bodies and other non-technical audiences.

ii. The Committee of Heads of University Geosciences Departments (CHUGD) is the subject association of Geoscience (geology, applied geology, Earth science, geophysics, geochemistry and some environmental science) departments/schools based within universities in the British Isles. It promotes discussion and exchange of information between departments and provides a point of contact between these and professional, government and quality control agencies.

iii. The British Geological Survey (BGS) is a world leading geological survey and the United Kingdom's premier centre for earth science information and expertise. The BGS provides expert services and impartial advice in all areas of geoscience. Its client base is drawn from the public and private sectors both in the UK and internationally.

iv. The Petroleum Exploration Society of Great Britain (PESGB) represents the national community of Earth scientists working in the oil and gas industry, with over 5,000 members worldwide. The objective of the Society is to promote, for the public benefit, education in the scientific and technical aspects of petroleum exploration. To achieve this objective the PESGB makes regular charitable disbursements, holds monthly lecture meetings in London and Aberdeen and both organises and sponsors other conferences, seminars, workshops, field trips and publications.

v. The British Geophysical Association (BGA) represents geophysicists in academia and industry who are members of the Royal Astronomical Society and/or the Geological Society of London. Its role is to promote geophysics and knowledge about geophysics at national and international levels.

Since the start of 2011, our organisations have worked together when appropriate in communicating with government, parliamentary committees, HEFCE and Research Councils on matters relating to national geoscience skills needs, and Higher Education policy and funding.

Q1: We have proposed a set of principles (listed in paragraph 94) to inform our approach. Do you agree with the principles we have outlined?

We support the first five principles. We have no comment on the sixth principle, which reflects HEFCE’s duty to implement a policy decision of government.

Regarding the seventh principle (to make funding interventions only where there is a strong case that competition will not produce outcomes that are either to the public’s benefit, or in the collective student interest), in most cases it is likely to be difficult to make a strong case for a negative statement of this kind (that outcomes will *not* be produced by an action), even if true. In making such judgments we suggest the test should be that, on the balance of probability, competition will not produce the desired outcomes.

We welcome HEFCE’s intention to be mindful of any unintended consequences of competition (paragraph 109). It is disappointing that the present consultation does not include questions on the approach to be taken to (and possible consequences of) removal of AAB+ students from student control numbers and the core/margin arrangements for reallocation of places towards lower fee provision, following on from the questions asked in the earlier consultation on transitional arrangements for 2012-13. We reiterate the concerns raised by our community in response to that consultation, and urge HEFCE to monitor closely the effects of these changes to ensure that they do not have a negative impact on the number of places available to geoscience students.

Q2-Q6: No comment

Q7: Do you have any comments on our proposal to supporting high-cost subjects?

We agree with the focus of the reduced HEFCE teaching grant on supporting high-cost subjects, and in particular the proposal to maintain the differentials between the subject price groups, pending a more thorough-going overhaul of the approach to support of high-cost subjects, which HEFCE indicates may done in time for the academic year 2015-16.

However, in light of the earlier consultation on transitional arrangements for 2012-13, we had expected that a full review of funding for high-cost subjects (including the additional funding stream for very high-cost science subjects) would be taking place now, for implementation from 2013-14 and are disappointed that the exercise has been deferred. As noted in our response to that earlier consultation, and in previous correspondence with Sir Alan Langlands, we are concerned that geoscience may be disadvantaged by the current arrangements relative to other subjects, with implications in terms of current and predicted skill shortages. It is important that such a review is conducted with some urgency.

In particular, we support the continuation of additional funding for very high-cost science subjects. However, we believe that the basis for decision-making about the subjects to which it applies, and how funding is allocated between them, should be revised. The simple allocation of additional funds to broad subject areas on the basis of aggregate cost data, as has happened in recent years, may fail to take account of significant differences in cost between programmes within these subject areas.

For example, TRAC data for 2009-10 show that the mean full teaching cost per student FTE in ‘Earth, Marine and Environmental Sciences’ across all 57 universities offering degrees in this broad subject classification (which includes geoscience/geology) is £9,298. However, at the 13 Russell Group universities the average cost for ‘Earth, Marine and Environmental Sciences’ is £11,279. This is over £1,000 more than the average cost of teaching Physics at Russell Group universities (and at all universities). (The courses offered by Russell Group universities are more frequently geology/geoscience courses sensu stricto, rather than less costly Environmental Science courses which are more commonly taught at other institutions. Many non-Russell Group universities also offer high quality accredited geoscience degrees, however, and are likely to experience a similar funding shortfall. Russell Group institutions are highlighted here only because they seem likely to provide the best proxy data on the costs of different programmes of study within the broader subject area, in the absence of direct data.) This substantial additional annual cost usually includes some or all of the costs of the mandatory fieldwork required of all students on accredited geoscience degrees. (Most geoscience departments have signaled their intention to avoid passing on these additional costs to students under the new funding regime.) These data suggest that the costs of providing high quality geoscience degrees, compared to other mainstream science disciplines, are not fully recognised within the current regime.

The presentation of TRAC(T) costing data at Annex C, taken alongside the explanation in the body of the consultation document of the basis on which additional funding has been allocated to very high-cost science subjects, is confusing. Only at paragraph 217 is it explained that the £23m additional support for these four subject areas has been removed from the TRAC(T) costs, and that this is the reason for the underestimate of cost per student for these subjects (which is referred to earlier in the document without explanation). (As a result of this, Chemistry appears to be less expensive than ‘Earth, Marine and Environmental Sciences’, for example.) It would be much more helpful and transparent to see the overall cost per student in each subject area, as the basis for both the allocation of subjects into price groups (A, B, C1, C2, D) and the additional funding stream. It would also be helpful to see the £23m of additional funding expressed as an amount per student. By analogy with the proposed split in group C, these four subjects effectively constitute a price group ‘B1’ (with other B subjects in group ‘B2’), but the relativities between groups are impossible to ascertain accurately under the current treatment.

We recognise HEFCE’s wish to minimise the administrative burden associated with running two systems while both old- and new-regime students remain. Therefore, while we would strongly prefer to see a thorough review of support for high-cost subjects brought forward, we understand that this may not be realistic. In this case, we would urge HEFCE to make a firm commitment to undertake such a reassessment for implementation in 2015-16, clearly signaled to universities now to minimise the chances that institutions make short-term decisions about where to focus provision in the mean time, to the possible detriment of subjects like geology which may be under-costed at present. It is important, against a backdrop of marginally increasing student demand, that the level of geology/geoscience provision is carefully monitored until such a review is undertaken.

We welcome the recognition that the level of funding may be further differentiated between subjects in future (paragraph 220), and for the reasons set out above we believe that this should also extend to reviewing the subject area definitions (and, where appropriate, to differentiating the levels of funding between programmes currently within the same subject area. We strongly agree with the need to develop the evidence base to support such a review, including through improvements to the collection and use of TRAC(T) data, and we are keen to help with this work in any way we can.

Q8: Do you agree that we should provide funding support for postgraduate provision including for price group C, as a transitional approach together with further development of the evidence base for future investment?

We are very pleased that HEFCE has recognised the potential threat to postgraduate taught provision, particularly in sectors for which postgraduate study is an established route into a profession (or indeed the preferred route, as it is in several sectors of geoscience, such as engineering geology and hydrogeology). Like HEFCE, we also recognise the risk that new-regime students may be deterred from going on to postgraduate education given the greater levels of debt with which they will graduate compared with old-regime students, especially as student loans are not available at postgraduate level, and we welcome HEFCE’s intention to monitor this.

We particularly welcome the higher level of funding per student for postgraduate teaching to sustain provision. Government has been almost silent with regard to postgraduate provision and uptake, in the 2011 White Paper and in subsequent consultations. It is most encouraging that HEFCE has listened to concerns in this area, and is now taking a lead. We assume that one purpose of providing this funding is to help ‘plug the gap’ between undergraduate fees and (lower) postgraduate fees, and to discourage increases in postgraduate fees (with the concomitant risk of disincentivising uptake), without institutions losing out (so that provision is not threatened). We note that the typical gap between undergraduate and postgraduate fees is greater than the proposed £1.1k differential. Nonetheless, given constraints and competing demands on resources, this is most welcome. We recommend that HEFCE monitors the level of student fees for taught postgraduate provision, to ensure that its objective of keeping them relatively in check is met (and that uptake is not thereby disincentivised).

We note that this is an interim arrangement, pending a review once better data on postgraduate fees and costs are available. We would be pleased to discuss and help with this process.

Q9: Do you have any comments on our proposal to use an approach based on TRAC(T) – with modifications – to inform our development of the future funding method for high-cost subjects?

As noted above (Q7), we support this proposal. We are keen to discuss further how this might best be done, and to help in any other way we can.

Q10-Q16: No comment

Q17: We have been asked by Government to consider a new approach to strategically important and vulnerable subjects and whether any subjects may require support to avoid undesirable reductions in the scale of provision. Do you have any comments on our proposed new approach to supporting this area through recurrent funding?

We agree with the principle that HEFCE’s approach to teaching costs should be determined with a view to providing suitable levels of support to higher-cost subjects, to create a ‘level playing field’ which does not disincentivise provision by institutions or uptake by students (for instance, if institutions were to introduce differential fees across subjects).

If such an approach is implemented effectively, cost of teaching should not be a factor in subject vulnerability. This should allow SIVS status to be addressed separately, in cases where informed student choice and institutional competition does not deliver a sustained flow of graduates, or a supply of programmes and expertise in the national interest, as pointed out at paragraph 310. (Indeed, in much of the document they are treated separately, although in other places they are conflated, and elements of funding for high-cost subjects are cited as support for SIVS.)

We agree that the need for intervention may be at the level of a particular specialism. Indeed, vulnerability in terms of capacity and supply of programmes is most likely to be a concern in numerically small (though strategically vital) specialisms, such as micropalaeontology (an example we have flagged in previous consultation responses and correspondence – we would be pleased to re-supply details). With this in mind, we welcome the proposal that there be no fixed list of top-level SIVS, and that the health of all subjects be monitored with a view to making highly targeted interventions. We find it confusing that the previous fixed list of top-level subjects continues to have some kind of special status, though it is not clear how this will be operationalised, and the implication appears to be that there will be a strong presumption in favour of intervention in these subject areas (contradicting the admirable new approach set out in principle). It is difficult to see how intervention across the whole of a large top-level subject area could be justified under the principles set out in the document. (The URL provided at paragraph 312 for further information on assessment of risk to broad subject areas ( does not work.)

Particular geoscience specialisms which we believe should be carefully monitored and may require targeted interventions, along the lines set out in the document, include micropalaeontology, geophysics, hydrogeology and geoscience specialisms which require a high level of mathematics. Our community is looking actively at all of these areas, but would value dialogue with HEFCE about how we might work together to address concerns. We note that government has passed to HEFCE consideration of strategic importance, and we would be happy to discuss and provide evidence for the national strategic importance of any of these specialisms.

Q18: No comment