Thirty-Fourth Report - The Creation of the UK Infrastructure Bank

The Treasury and the Bank have not yet put in place the conditions necessary for the Bank to be a successful and long-lasting institution. The government wants the Bank to be a “long-lasting institution”, providing financing for infrastructure projects well … Read more The Treasury and the Bank have not yet put in place the conditions necessary for the Bank to be a successful and long-lasting institution. The government wants the Bank to be a “long-lasting institution”, providing financing for infrastructure projects well into the future. The £22 billion made available to the Bank covers its first five years of operation; beyond then, the Treasury expects the Bank to be self- financing. However, there is no guarantee the Bank will achieve this, with little clarity over whether the Treasury will provide further funding in the future. If the Bank does prove to be profitable, there is little to prevent it being sold off, in a similar manner to the sale of the Green Investment Bank in 2017, beyond assurances from Treasury officials that government wants to keep it within the public sector. Staffing challenges are acting as a brake on the Bank’s ambition, as its capacity to 6 The Creation of the UK Infrastructure Bank make complex and innovative deals is limited by a lack of suitably qualified staff. Currently there are 16 permanent employees, a significant shortfall against its plan of having 270 in place by September 2023. The remaining 150 or so staff are contractors or Treasury secondees. The Bank is also reliant on the Treasury in other ways, including its IT systems for day-to-day operations. Recommendation: • The Treasury and the Bank should report to Parliament six-monthly on the roll-out of the Bank, including updates on recruitment, deals made and progress towards the operation of their own internal systems (e.g., IT systems). This should include timescales for future milestones. • The Treasury needs to be much clearer in its reporting of its expectations of the Bank, including its financing support, its plans for taking dividends, and the long-term ownership plans by defining more clearly what it means by the phrase ‘long-lasting institution’. Show less

We are not convinced the Bank has a strategic view of where it best needs to target its investments. The Bank’s 10 deals to date have mostly been relatively conventional investments, including seven loans. While the Bank’s early deals reflected … Read more We are not convinced the Bank has a strategic view of where it best needs to target its investments. The Bank’s 10 deals to date have mostly been relatively conventional investments, including seven loans. While the Bank’s early deals reflected a sensibly cautious approach, it is not yet capable of making the full range of investments it could potentially make, and will not be able to do so until it has sufficient staff qualified to make more complex transactions. The Bank claims to be filling gaps in the market and making investments the private sector would not consider, but so far the Bank has provided financing to deliver broadband and build solar farms, both relatively common projects. The Bank struggled to articulate the priority areas for investment, and how it will recruit staff necessary to fulfil its role. The Bank can only deliver on the government’s ambition and wider objectives if it moves beyond making “safe” investments, because the scale of the challenge is so severe. The Bank has not demonstrated it has a clear idea of how its investments complement each other and provide additionality. In addition, they are not yet making direct equity investments, instead investing through equity funds. Recommendation: The Bank should write to the Committee within 3 months outlining its investment strategy for making a full range of investments, including a timeline for when it expects to be making deals proactively. Show less

The Bank’s advisory function remains in the early stages of development and uncertainty remains on how it will be funded and how smaller local authorities will benefit from its activities. The Treasury intends the Bank to provide advisory services to … Read more The Bank’s advisory function remains in the early stages of development and uncertainty remains on how it will be funded and how smaller local authorities will benefit from its activities. The Treasury intends the Bank to provide advisory services to local authorities regarding infrastructure projects. This function is currently in pilot phase with three large unitary authorities—Manchester, West Yorkshire, and Bristol—with the aim of creating solutions that are replicable across all local authorities. However, we are concerned that smaller local authorities who may need more support than larger ones (owing to the size of their resources, capacity and capability) should not be left behind in receiving the Bank’s support. The Bank has not worked through how this function should be funded and is currently planning to offer this advice for free while it seeks to establish the replicability of The Creation of the UK Infrastructure Bank 7 its advice. However particular attention needs to be given to avoid past mistakes of making risky loans to local authorities on property and other capital projects which put the authorities’ overall finances at risk. Recommendation: Upon completion of its three pilot schemes, the Bank should write to the Committee setting out how its advisory function will work in practice, including how it will design a funding model that reflects the cost of the support provided, and regulates demand. The Bank should also outline how it will ensure smaller authorities are not left behind. Show less

Maximising the Bank’s impact will depend on close cooperation with government departments, but it has not yet worked out how this will operate in practice. The Treasury intends the Bank to play an important role in achieving key elements of … Read more Maximising the Bank’s impact will depend on close cooperation with government departments, but it has not yet worked out how this will operate in practice. The Treasury intends the Bank to play an important role in achieving key elements of this government’s wider agenda on net zero and levelling up, as reflected in the Banks dual objectives. The Treasury expects the Bank to set out how it intends to work with stakeholders, including policy departments across government. To date the Bank has had limited communications with key stakeholders at senior levels, including the Department for Levelling Up Housing and Communities (DLUHC) and the Department for Environment Food and Rural Affairs. Engagement with DLUHC in particular will be critical to understanding the needs of local authorities, which will then inform the Bank’s loan and advisory programmes. The lack of clarity surrounding relations with other departments raises the risk that different organisations responsible for net zero and levelling-up could be pulling in different directions. Recommendation: In its Treasury Minute response, the Bank should describe its engagement strategy for working with government departments, focussing in the very short term on how it engages with those departments most critical to delivering its mission, including the Department for Environment Food and Rural Affairs, the Department for Levelling Up Housing and Communities and the Department for Business, Energy and Industrial Strategy. Show less

The Bank has not fully set out how it will measure and report its performance, and how it will evaluate its activities to ensure that it can demonstrate additionality. Evaluation is crucial to ensuring the Bank delivers additionality and that … Read more The Bank has not fully set out how it will measure and report its performance, and how it will evaluate its activities to ensure that it can demonstrate additionality. Evaluation is crucial to ensuring the Bank delivers additionality and that the benefits justify the costs of creating it. The Treasury has set a financial return target, but the Bank has only just started work on developing its own performance measures, and has not fully defined what success looks like, to inform future monitoring and evaluation. There are tensions within the Bank’s objectives; for example, pursuing a project that delivers against its economic growth objective would not necessarily be compatible with its climate change objective. The Bank is yet to set out how it will address these tensions in practice. The Bank has also made little progress in measuring additionality; this is challenging but essential for determining whether the Bank is genuinely adding value, and not ‘crowding-out’ private sector investment. The Bank has developed arrangements for reporting performance and emerging issues to its shareholder, the Treasury, through the shareholder representative, UK Government Investments. However, the Committee has seen other examples in government where similar arrangements failed to escalate problems to Parliament. 8 The Creation of the UK Infrastructure Bank Recommendation: By March 2024 the Bank should write to us detailing how it has implemented a full suite of performance metrics and targets including productivity and green performance, together with a forward plan for evaluation that includes additionality assessments. It should at the same time outline how it will publicly report its performance and the results of its evaluation over time. The Creation of the UK Infrastructure Bank 9 1 Accountability and governance Show less

On the basis of a Report by the Comptroller and Auditor General, we took evidence from HM Treasury (the Treasury) and the UK Infrastructure Bank (the Bank) on the creation of the Bank.1

The Treasury told us it took a “phased approach” to the Bank’s set-up with “checks and balances in place” to ensure it would be delivering value for money to the taxpayer.17 The Treasury seconded officials to key Bank posts, and … Read more The Treasury told us it took a “phased approach” to the Bank’s set-up with “checks and balances in place” to ensure it would be delivering value for money to the taxpayer.17 The Treasury seconded officials to key Bank posts, and initially had “very tight controls” over the Bank, including retaining the authority to sign-off all deals, which it exercised to approve several early low risk Bank deals. Six months after launch, once the Bank recruited the staff it needed, authority was largely transferred to the Bank except for deals above a certain size and any considered novel, contentious, and repercussive, which still require Treasury approval.18 The Bank has now improved its corporate governance arrangements, with most executive positions now filled on a permanent basis and the non-executive directors are in post and independent.19 The Bank told us that the decision to set-up at pace has proved to be beneficial. It announced six deals in its first full year of operation and told us it has now announced a total of 10 deals, of around £1.1 billion in value.20 10 Qq 13, 32, 36 11 Q 2; C&AG’s Report para 5 para 12 Q 70 ; C&AG’s Report para 2.3 13 Qq 3–4 14 Q 70 15 Q 69 16 Q 67 17 Qq 36, 69 18 Qq 4, 67, 70 19 Q 67; C&AG’s Report paras 8 and 2.24 20 Q 31 The Creation of the UK Infrastructure Bank 11 Conditions for a long lasting and successful institution Show less

The Treasury intends the Bank to be a “long-lasting institution” providing financing for infrastructure projects well into the future.21 This label echoes the Green Investment Bank’s status as an “enduring institution,” which was subsequently sold to the private sector five … Read more The Treasury intends the Bank to be a “long-lasting institution” providing financing for infrastructure projects well into the future.21 This label echoes the Green Investment Bank’s status as an “enduring institution,” which was subsequently sold to the private sector five years after its creation. In our 2017 report The sale of the Green Investment Bank we found that the term ‘enduring institution’ had little meaning in practice, and insufficient protections were put in place to prevent it from being sold.22 Show less

The Treasury provided the Bank with £22 billion in capital to cover the first five years of operation; beyond then, it expects the Bank to be self-financing. We asked whether this was a realistic target. The Bank told us it … Read more The Treasury provided the Bank with £22 billion in capital to cover the first five years of operation; beyond then, it expects the Bank to be self-financing. We asked whether this was a realistic target. The Bank told us it expects to be profitable within five years, with its income exceeding the £70 million to £80 million a year cost of running the Bank.23 However, if the returns from current investments are needed to finance future deals, this would be “more challenging” to deliver within five years. The Bank told us that infrastructure financing is typically much longer dated that five years. When asked whether it would provide additional financing to the Bank after five years, the Treasury told us that if the Bank was additionally investing and meeting its targets,24 When challenged on whether the Bank would be sold in the future if it proved to be profitable, the Treasury told us that profitability wouldn’t be the only factor in any decision, and that the Bank’s contributions to major government goals such as working towards net-zero, and putting the Bank in statutory legislation, would make it “more difficult to sell”.25 Show less

The Bank’s capacity to make complex and innovative deals is limited by the lack of suitably qualified staff members. The Bank has worked with Treasury to complete recruitment to key senior leadership positions that were not filled at launch. At … Read more The Bank’s capacity to make complex and innovative deals is limited by the lack of suitably qualified staff members. The Bank has worked with Treasury to complete recruitment to key senior leadership positions that were not filled at launch. At the time we took evidence in early November 2022 the Bank had 162 employees, of which 16 are permanent, the remainder being contractors or Treasury secondees. This is a shortfall against the Bank’s plan to recruit around 272 permanent employees by September 2023. The Bank reimburses interim staff at day rates. The Bank’s Chief Executive said that recruiting permanent staff is his biggest leadership challenge. The Bank told us that while it has very good temporary staff, “every (permanent) role is competed for” on quality, which is adding time to the recruitment process.26 The Bank added that it would “not compromise quality for speed” and wanted to wait for the right candidates.27 Show less

The Bank told us that, as a result of having insufficient skills and expertise, it has only entered into relatively low risk, more straightforward investment deals, as those are the only deal types it is comfortable delivering with the available … Read more The Bank told us that, as a result of having insufficient skills and expertise, it has only entered into relatively low risk, more straightforward investment deals, as those are the only deal types it is comfortable delivering with the available staff.28 It currently has a small banking team of 15 to 18 people which it will need to expand to around 70 before it is capable of delivering more complex, direct equity deals. It expects to start delivering 21 Q 82 22 Committee of Public Accounts, The Sale of the Green Investment Bank, Twenty-Fifth Report of Session 2017–19, HC 468, 14 March 2018 23 Qq 12, 21, 30 24 Qq 21, 22 25 Q 14 26 Q 74 27 Q 66 28 Qq 4, 24 12 The Creation of the UK Infrastructure Bank direct equity deals within the first three months of 2023.29 The Bank is still working to develop its own banking systems to support deals and IT systems, as it is currently reliant on Treasury systems for a range of functions.30 Performance measurement and evaluation Show less

The costs associated with setting-up the Bank as a separate institution, such as procuring new IT systems, make it a more costly option than alternatives such as extending the remit of existing bodies.31 The Bank told us it is working … Read more The costs associated with setting-up the Bank as a separate institution, such as procuring new IT systems, make it a more costly option than alternatives such as extending the remit of existing bodies.31 The Bank told us it is working towards a “triple bottom line”, consisting of its two policy objectives—helping to tackle climate change and aiding regional growth; alongside two financial objectives—generating a financial return and “crowding-in” additional private investment.32 The Treasury set the Bank a target to earn an annual return on equity between 2.5% and 4% by 2025–26. It also told us that it has set the Bank a target to attract additional private finance of £18 billion.33 The Bank told us that “to be additional every time we invest”, that “additionality is a judgement” and that there are many ways the Bank can be additional. The Bank explained that it can be additional by filling financing gaps or taking risks, including policy risk, that the private sector is unwilling to accept. The Treasury told us that “but it is not there just to get as much money out the door as it can. It is there to do the things that are truly additional.” The Bank told us that it “can look to be additional to all those market moments by working with the government departments, understanding the private market appetite and then figuring out what we think our intervention is”, but that it has “not got there yet”.34 Show less

The Bank told us it is currently developing several Key Performance Indicators (KPIs) to measure its success. For its two policy objectives, these include carbon emissions abated, jobs created and productivity. The Bank told us it expects to abate 2 … Read more The Bank told us it is currently developing several Key Performance Indicators (KPIs) to measure its success. For its two policy objectives, these include carbon emissions abated, jobs created and productivity. The Bank told us it expects to abate 2 million tonnes of CO2 and create or support 3,900 jobs from the 10 deals it has made so far. The Bank still does not have targets or other success criteria for these KPIs. The Bank has yet to establish ways of measuring its contribution to productivity.35 The Bank added that it was developing other potential impact metrics and that these metrics will be reported, on an aggregate basis, in the Bank’s annual report. The Bank has started to develop ways of measuring wider aspects of additionality, which will include providing a narrative for each transaction it does.36 Show less

The Bank recognises there could be tensions between its two policy objectives.37 For example, there is a risk that a project could promote local growth but be harmful to the environment. The Bank told us that for any investment that … Read more The Bank recognises there could be tensions between its two policy objectives.37 For example, there is a risk that a project could promote local growth but be harmful to the environment. The Bank told us that for any investment that is primarily focused on regional and economic growth, its needs to ensure the investment is not doing any significant harm against the net-zero objective. When questioned on how the Bank will assess this significant harm criteria, the Bank told us it would look on a case-by-case basis and assess “what significant harm is or is not”.38 29 Qq 7, 54 30 Qq 6–7, C&AG’s Report para 2.18 31 Q 11, C&AG’s Report para 18 32 Qq 22, 25, 27 33 Qq 25–26 34 Qq 22, 42 35 Qq 27, 28 36 Q 27 37 C&AG’s Report, para 14 38 Qq 58–60; C&AG’s Report, paras 3.18 – 3.20 The Creation of the UK Infrastructure Bank 13 Show less

The Bank has developed arrangements for reporting performance and emerging issues to its shareholder (the Treasury), through the shareholder representative (UKGI). However, the Committee has seen other examples in government where similar arrangements apply and where things have gone wrong … Read more The Bank has developed arrangements for reporting performance and emerging issues to its shareholder (the Treasury), through the shareholder representative (UKGI). However, the Committee has seen other examples in government where similar arrangements apply and where things have gone wrong long before Parliament has received any warning.39 In addition, neither the Treasury nor the Bank have plans to share UKGI reports more widely with Parliament. The Treasury confirmed the importance of notifying Parliament of an emerging problem, including where UKGI was involved. It acknowledged that there are areas where Managing Public Money rules apply but notifications to Parliament “are a bit patchier than we would like”. Treasury told us that there is an “improvement process” going on, in relation to UKGI.40 39 Q 18 40 Qq 16–19 14 The Creation of the UK Infrastructure Bank 2 Building out the Bank’s operations Investment Strategy Show less

The Bank was set up to address market failures and fill gaps in financing for infrastructure investment.41 The Bank told us that it can do this by taking risk that the market is just not willing to take, for example … Read more The Bank was set up to address market failures and fill gaps in financing for infrastructure investment.41 The Bank told us that it can do this by taking risk that the market is just not willing to take, for example in “first-of-a-kind” technology. It also told us that it can take policy risks in areas that the market might not be comfortable with, developing an understanding of the direction of policy and working to amplify interventions in those policy areas.42 In general, equity investments are more suitable for higher-risk projects and are more complex transactions to undertake. In due course the Bank plans to build a portfolio of different financial instruments covering a range of different technologies and risk.43 The Treasury has specified the five sectors it wants the Bank to prioritise – clean energy, transport, digital, water and waste.44 Show less

The Bank’s 10 deals to date have mostly been in relatively conventional investments.45 This total consists of seven loans and three equity investments made through funds rather than directly. The Treasury told us that the Bank was deliberately designed to … Read more The Bank’s 10 deals to date have mostly been in relatively conventional investments.45 This total consists of seven loans and three equity investments made through funds rather than directly. The Treasury told us that the Bank was deliberately designed to start with “those less controversial things, less equity driven” as it builds up resources over time.46 The Bank acknowledged that it is comfortable with senior debt transactions, but does not have the skillset and resource within the Bank to undertake direct equity investment.47 It told us that it took the decision to deploy equity through qualified third-party managers, rather than not deploy any equity until it had the resource to do so. The Bank told us that this is a “technique that has been deployed successfully in Government before”, for example through the Digital Infrastructure Investment Fund and Charge Infrastructure Investment Fund – both of which are now the responsibility of the Bank. The Bank expects such “outsourcing” to moderate over time as it develops the skills necessary to make direct investments, to the point where it will not outsource equity investment further.48 Show less

The Bank’s 10 deals to date have focused on clean energy (five) and digital (four) projects.49 These deals have generally been in areas of technology and risk where projects are relatively common, for example broadband and solar power farms.50 The … Read more The Bank’s 10 deals to date have focused on clean energy (five) and digital (four) projects.49 These deals have generally been in areas of technology and risk where projects are relatively common, for example broadband and solar power farms.50 The Treasury told us that the Bank “needs to take a judgment going forward as to the areas in which the private sector might not be able to invest without the encouragement of the bank”.51 The Bank told us it has a small banking team of 15 to 18 people and will need to increase this to around 70 people to cover the market and the investor base.52 41 Q 37 42 Q 42 43 Q 47 44 Q 10 45 Q 24 46 Q 36 47 Qq 24, 43 48 Q 43 49 Q 10 50 Correspondence from the Chief Executive Officer of the Infrastructure Bank to the Chair, 1 November 2022 51 Q 24 52 Q 7 The Creation of the UK Infrastructure Bank 15 The Bank’s advisory function Show less

The Bank’s functions include providing an expert advisory service to help local authorities and other project sponsors to develop and finance infrastructure projects.53 The Bank told us that establishing this service is not straightforward, compared to its local authority lending … Read more The Bank’s functions include providing an expert advisory service to help local authorities and other project sponsors to develop and finance infrastructure projects.53 The Bank told us that establishing this service is not straightforward, compared to its local authority lending function which is already operational. The Bank has three advisory function pilot projects up and running with some larger local authorities—Manchester, West Yorkshire, and Bristol—covering zero emission buses and heat networks.54 Show less

The Bank told us that in developing the pilots, it wanted to try to understand and define problems that it thinks will be most common across the local authority landscape, such as financing heat networks, zero-emission buses and social housing … Read more The Bank told us that in developing the pilots, it wanted to try to understand and define problems that it thinks will be most common across the local authority landscape, such as financing heat networks, zero-emission buses and social housing retrofit projects. The Bank will then find the most capable local authorities already working on these problems and work with them to develop a proposition that it could then “replicate across other local authorities”.55 This approach has led the Bank to focus its three pilots on larger local authorities. We asked the Bank why it was not giving advice to smaller authorities. The Bank said it did not mean to suggest it was restricting access to the smaller authorities, but “the reality is that we do not and will not have the resource to cover them effectively”. It told us that it has started with larger authorities because it thinks it will learn lessons there quickest, and the challenge for the Bank would be “to figure out how to get that to the smaller authorities in a way that is usable and useful to them.”56 Show less

The Bank has not reached a decision on how it will fund its advisory function. Decisions on funding will be important given the Bank’s expectation that demand will be significant, and that it will not have the resource to cover … Read more The Bank has not reached a decision on how it will fund its advisory function. Decisions on funding will be important given the Bank’s expectation that demand will be significant, and that it will not have the resource to cover all requests effectively.57 The Bank told us it has considered models for charging local authorities to use the advisory service but as things stand, it does not intend to charge directly. It told us this was because local authorities are already resource-constrained, and it is more likely that the Bank’s interventions will be successful if it can help local authorities as “cheaply and efficiently” as possible. The Bank indicated that the revenue generated from its local authority lending will probably end up paying for the advisory function.58 Engagement with government departments Show less

The activities and policy objectives of the Bank overlap with departments across government. For example, the Department for Levelling Up, Housing and Communities (DLUHC) has policy responsibilities in relation to local government and to regional and local economic growth.59 The … Read more The activities and policy objectives of the Bank overlap with departments across government. For example, the Department for Levelling Up, Housing and Communities (DLUHC) has policy responsibilities in relation to local government and to regional and local economic growth.59 The Treasury expects the Bank to set out how it intends to work with stakeholders, including policy departments across government, as part of the Framework Document setting out the formal arrangements between Treasury and the Bank.60 53 C&AG’s Report para 1.9 54 Q 39 55 Q 41 56 Qq 41, 53 57 Q 53, C&AG’s Report para 3.5 58 Qq 50–51 59 Q 91, C&AG’s Report Figure 3 60 C&AG’s Report para 3.7 16 The Creation of the UK Infrastructure Bank Show less

We asked whether the Bank had mechanisms in place to manage pressures from competing government departments looking for the Bank to invest in their policy areas. The Bank told us that it is operationally independent to make its own decisions, … Read more We asked whether the Bank had mechanisms in place to manage pressures from competing government departments looking for the Bank to invest in their policy areas. The Bank told us that it is operationally independent to make its own decisions, with an Accounting Officer and a Board as part of that independence.61 The Bank told us it has “very active discussions” with the Department for Business, Energy and Industrial Strategy because its portfolio overlaps with that of the Bank. The Bank also described working with DLUHC, the Department for Transport and the Department for Environment, Food and Rural Affairs (Defra). However, the Bank’s Accounting Officer told us he had not yet established personal connections with DLUHC or Defra, 16 months into the Bank’s operations.62 61 Q 92 62 Q 91 The Creation of the UK Infrastructure Bank 17 Show less