This blog post is based on a speech by Nick Hillman, Director of HEPI, to a Pearson UK Hot Breakfast on 9th November 2015.

First, there weren’t many surprises. Mark Leach of Wonkhe has said ‘For UK higher education, the world changed on Friday.’ I’m not so sure. The green paper is in tune with the few weighty speeches Jo Johnson has made since May – especially the one to UUK in September. Those foretold the measuring of teaching quality, the new entry and exit regime for providers and the different system for regulating higher education that are included in the green paper. Some commentators nonetheless say the green paper betrays Jo Johnson’s own instincts. For example, one academic blog says: ‘Jo Johnson … , seemed like a relatively sensible and centrist Conservative; he appeared competent; he didn’t seem to have the temperament for yet another revolution, on top of all the others. … But Mr Johnson couldn’t resist it. He couldn’t keep his hands off the tiller. The desire to tinker, to play around, to impose more targets and limits and numbers and data and signposts and gateposts and hurdles. He just couldn’t help himself.’ Anyone who thinks like that has almost certainly misread the signals emitted since May.

Secondly, anyone who think likes that lacks understanding of the Conservative Party because the green paper is an explicitly Conservative document. When I worked in BIS under the Coalition, Number 10 would occasionally ask us, ‘If there were to be a Conservative-majority government rather the mish-mash of a Coalition, how would higher education policy differ?’ Friday’s green paper is a large part of the answer. For example: the TEF is a response to the fact that politicians find it hard to prove their £9,000 fees have produced much more demanding students; a smoother entry regime is a response to innovative new providers the Conservatives support, like the New College of the Humanities and Pearson, who have felt like they are in the world’s longest obstacle course with ever-changing rules and no finish line; and the folding of Offa into HEFCE and the changes to the distribution of research funding are in tune with the desire to reduce the number of arms-length bodies.

But, thirdly and despite all this, the paper is surprisingly green. We used to describe the 2011 white paper as white with green edges and we had thought the 2015 green paper would be green with white edges – nearly a white paper in fact. That is not the case. The number of known unknowns is large: we don’t know exactly what will be in the TEF or how it will operate; nor where the remaining HEFCE teaching grant will end up; nor what the research landscape will look like. Some people might think that is a cop-out. I don’t. I think it is a brilliant opportunity for the higher education sector to shape the final proposals. Indeed, the paper is so green that anyone who says its proposals are wonderful or terrible should be taken with a pinch of salt.

Fourthly, there used to be a fierce debate in education policy on whether to focus on structures or standards as the best way to raise quality but the green paper is full of both. The TEF seeks to raise standards and the replacement of HEFCE with the Office for Students is a big structural change. Yet, to understand the green paper fully, you need to recall that structures follow funding. A new structure for higher education regulation has been necessary ever since the majority of teaching funding started to flow through students. My old boss, David WIlletts, used to say tripling fees without changing the regulatory structure resembled selling off a nationalised utility without changing the legal framework under which it operates.

Fifthly, I worry about the potential consequences of some of the proposed changes to HEFCE. In particular, I worry about the loss of expertise as I doubt people will want to stay at HEFCE during all the upheavals and when it is to end up as a bureaucratic body rather than a funding one – after all, with money comes power.

Sixthly, I also worry about the potential threat to autonomy if decisions about the remaining teaching grant, or even the Quality-Related money paid to institutions on the back of the REF, were to end up much closer to Ministers. Not everyone agrees with this. Kieron Flanagan of the University of Manchester, who is a brilliant thinker on science and policy, wrote on Friday: ‘Given that ministers have made the decision to abolish HEFCE, the only logical solution is to move its research functions into BIS, which is effectively England’s higher education ministry.’ But that would bring BIS Ministers much closer to the decisions about what and where funding should land and BIS does not have the expertise to do it anyway. Our cat is nicknamed ‘Quango’ because when we got her she always stood an arm’s length away. She thought it wasn’t a good idea to get too close to those who feed her. There might be a lesson there for the sector.

Seventhly, I am intrigued by some of the balancing acts. For example, the TEF is to end up with an element of peer review and will be less explicitly metric-based than originally planned, while the REF is to become more metric-heavy. Perhaps the two will meet somewhere in the middle. That is perhaps rather different to the original promise that the TEF would not be ‘big, bossy or bureaucratic’. I am also intrigued that the Director of Fair Access is to continue, possibly with more powers, despite the threat that the spending review poses to Student Opportunities Funding.

Eighthly, we can’t understand the green paper fully until we get the other two parts of the trilogy that haven’t been published yet: the Nurse review and the spending review. For example, despite the green paper’s path to higher tuition fees, we have no idea how much money universities will have to teach because we do not know how much of the existing teaching grant will survive on 25 November.

Ninthly, look out for important non-legislative remarks and asides. For example, the 2011 higher education white paper led to many new universities through the reduction in the number of students necessary to secure university title. That was possible even without a parliamentary bill. Similarly, the changes proposed in the green paper in this area, such as the removal of any link between student numbers and university title, could happen without the need for new legislation.

Converting it all in to law will be hard. The journey from green paper to getting the Queen’s signature on a new Act is a long and bumpy one at the best of times. A Government that found it difficult to agree on a date for the publication of the green paper may not necessarily find it easy to agree on the finer details of an entire bill. Moreover, the Government does not have a majority in the House of Lords and sees some other issues as more important, such as the EU renegotiation.