National Assembly for Wales

If I may, Chair, as you know, as the designated Member previously, I worked very closely with the then Minister for education on developing of a large part of this Bill, but not everything contained within it. Thank you.

Good morning. I’m Efa Gruffudd Jones, I’m the Welsh Language Commissioner. In terms of developing the Bill, my officials and I have responded to the White Paper and we have held some discussions with Welsh Government officials during the process of developing the policy work.

Thank you very much. The first thing I'd like to say is that I very much welcome the fact that the Welsh Government are legislating in this area. I think it's an exciting development and a vital one. We know very well about the targets of the 'Cymraeg 2050' strategy, but if we look at how Welsh-medium education, for example, has developed over the last decade, we need to do something differently from now on if we really want to achieve the ambition of 'Cymraeg 2050'. So, I think it's very exciting. I think that there are very interesting things in the Bill—using a code for describing linguistic ability, and so forth, following good practice from other countries. Therefore, in general, I very much welcome this development, but, of course, as you would expect, perhaps, I do have some issues that I’d like to share with you today.

I welcome the fact that the Bill is going to place additional requirements on what is in the 2006 Act. I think that it is important symbolically that targets will be set on the face of the Bill in legislation. However, we know that there is a need to do more than just setting in legislation to achieve. However, I think it's very important, given the range of time, that our aspirations currently are not reduced or diluted as time progresses. So, I very much welcome the fact that the target intends to be set on the face of the Bill.

In terms of my work and my role, the main work that I'm responsible for is increasing the opportunities for people to use the Welsh language. I work with public bodies and set Welsh language standards so that they increase the opportunities available for people to use the Welsh language. So, it’s very important to me that attention is given in the Bill to the use of the language. There is also a link between my work and the legislation in terms of if we don't have more people coming through the education system speaking Welsh, there will be nobody available to use the services in due course.

There are areas within the scope of my influence, and that I have specific interest in, that align with what is being proposed in the legislation, for example developing Welsh in the workplace, and the fact that we hope that young people now and in the future will be able to use their Welsh in their work life after they've finished their time in school. So, in general, I do think that the legislation is relevant to my work, and that the outcomes should facilitate the work that I do in ensuring more opportunities for people to use the Welsh language in their everyday lives.

I was very interested to see that this had been suggested in the Bill. In my view, both reports are very different things. The requirement in the legislation is on Ministers to report on usage and education, whereas it's very clear to me that my report is an independent report that looks at a range of policy areas. I can cover health and care, broadcasting, business, charities, as well as education, whereas I see that the report in the Bill will naturally focus more on education and its influence. In my view, they are different things. I think it's important that I do have discussions with the Welsh Government to ensure that there is no duplication, but I don't see them as conflicting with each other in any way whatsoever. The more information we have on the situation of the Welsh language, the better. In my view, the Welsh Government has more capacity in terms of conducting research, and has more expertise than my office has, so I don't see any problem with having two kinds of reports.

I welcome the fact that section 1 of the Bill notes statutory targets on language use. Measuring the use of the language is more difficult than counting the numbers of speakers, but I welcome any attempt to seek to do that. It's easier to collect numbers, isn't it? We have the census results; we have other survey data available. In terms of language use, we have a language use survey at the moment, which has been held every five to six years, but I would welcome a firmer commitment to hold that more regularly, or that there should be a long-term agreement that it would be brought forward in a more systematic manner, and I would welcome being part of that work.

I am aware that the Welsh Government is undertaking a survey entitled Prosiect BRO at the moment. I think that kind of analytical work in terms of language usage will be important to all of us working in this area. So, I welcome the move to seek to focus on language usage. There are two targets, as we well know, in the strategy—one in terms of numbers, and one in terms of use. And we want to learn Welsh and speak Welsh in order to use it, don't we?

This is something that I welcome once again in terms of what is being proposed. As I explained at the beginning, I want people to use the Welsh language. I also welcome very much the fact that we are trying to ensure that legislation and measures relating to the Welsh language speak to each other. So I think it's very sensible that there are proposals in the legislation to look again at some of the standards that I will then be able to regulate.

In terms of the work that's being proposed, it aligns completely with the priorities that I have set in the last year or two, namely working on standards that relate to the workforce and workplaces and how people can speak more Welsh in workplaces. Considering a language code and language descriptions would be able to make those standards more effective.

In terms of standards relating to the promotion of Welsh, again, this is a priority area for me. There are standards in terms of promoting the Welsh language, but I would welcome those being strengthened. So from my part, the intention to develop those standards aligns with the priorities that I have already, and I'm looking forward to contributing to that work. 

Thank you. If I could come in on the back of that last question on language standards—and thank you for the evidence that you've submitted; it's very useful to us as a committee—do you see any way in which the influence of language standards, which do have legislative force, of course, could extend to individual schools? How could you as commissioner influence the language skills development of the workforce and also promote the use of the Welsh language outside the classroom too?

There were a number of questions there. I'll try and deal with them in turn. In terms of individual schools, I don't think it would be practical for us to set Welsh language standards on every governing body, for example, even though it would be technically possible. So I see that what's been proposed in the Bill in terms of delivery plans is more effective or more practical than placing standards on them. However, there are bodies relating to developing the workforce, registration and looking at workplaces, and standards could influence them.

In general, I see in my work that Welsh language standards do lead to more opportunities for people to use the Welsh language. Certainly in terms of children and young people outside the classroom, it's not simple. If we think of youth activities in county councils, for example, the standards do not mean that there is a need for that provision to be a Welsh-medium provision. However, I see an opportunity for us to strengthen the standards in terms of promotion so that more services for children and young people are available through the medium of Welsh, which, according to the letter of the standard at the moment, is not possible for us to enforce. 

This year, we intend to give specific attention to the promotion standard on local authorities and national parks. But that standard currently, in my view, doesn't provide enough powers for me to push as much as I would like, even though I'm very keen to work with these bodies to provide them with training and to encourage them to think holistically about the Welsh language, and not just to stick to the standard itself. But currently I have to do that through encouragement and persuasion rather than using legislation, which of course is an effective technique, but it's a way that I'd like my organisation to move towards, which is to encourage and support, but if the standard is as strong as it could be, then that would assist me. But I'm always looking at ways of using the standards and the powers that I have to develop more opportunities for people to use the language easily. 

I have a block of questions around the CEFR, the common European framework of reference. You've noted in your evidence some comments on that. Do you believe that the CEFR in general terms is appropriate for the situation here in Wales? Because it has been a part of the European education system for a while, but it's new for us.

Declaring an interest in terms of my previous role, where I worked for the National Centre for Learning Welsh, I am familiar with CEFR because the curriculum and the teaching resources in the area of Welsh for adults are based on the CEFR system, and have been so for years. So, I understand the concept and I do think that there would be a way of applying it to the education sector. I also know through my previous work that you can create resources and lovely materials that go with and facilitate and support the process of teaching, and that is currently true in Wales in the adult sector, but not in the school sector. So, the starting point is establishing the code of description, and I think that basing that on CEFR is a good idea. It's a method that's been accepted.

There is work to be done to ensure that it is suitable for Wales—. You can't just use it exactly as it is. I'm sure that work is going to happen to make it suitable and applicable to children and young people, but, in my view, I very much welcome the move to use the CEFR as a basis for describing the ability and a means of measuring the linguistic development of children and young people. 

As it happens, in last week's session the Cabinet Secretary responsible for the Welsh language said that almost everyone can speak some Welsh in Wales, unless they've just arrived here. So, do you think that the CEFR can reflect that broad range of people who have very, very little skill in the Welsh language to those who are entirely fluent and versed in the language?

Although I have said that I have previous experience, I'm not an expert in this area. What I would say is that, if memory serves me correctly, in English, for example, for young children there is Cambridge English and certain levels below the A1 for very young children. I think for the upper levels, we'll be fine, but perhaps we do need to look at levels below A1 for young children particularly. Now, of course, I agree that everyone in Wales can speak some Welsh, or will have at least seen the Welsh language around them, but what we want at the end of this process is not a million people able to say 'Bore da' or a million people on level A1. 

So, there is some merit, perhaps, in saying that people could be below A1—that's one category of people—but then there are people in the upper categories too. So, I don't know if A1 covers those people who can only say 'Bore da', but, simply, you could say that they aren't at A1 level, as a simple solution. But I think this needs to be worked out with specialists in terms of the code itself, and to consider the needs of young children, particularly. 

And the final question is: do you see a role for yourself as commissioner in terms of facilitating awareness of the CEFR if this became part of our education system? 

Right. To refer back to my previous comments on developing new standards in relation to the workforce, that's exactly where I would expect the CEFR descriptors to be incorporated in those standards, in order to make it clearer to the workforce and workplaces what the requirements and levels are for any particular role. So, in my view, it's important that the standards are reviewed in order to complete that circle. With luck, people will leave the education system knowing what level they're at on the CEFR. And when they see a job that states that you need B2, for example, in order to be able to answer the phone, but you need C2 in order to draft documents, people will have a better understanding of where they are on the continuum. 

The only other thing I'd say from previous experience too is that the level you get to on the CEFR doesn't necessarily reflect how confident you are in using the Welsh language skills that you have. So, we do need to be slightly careful in that regard, but I think that completing that CEFR circle with standards would be something that would make complete sense. 

And, of course, the CEFR measures a range of skills as well, not just the ability to speak—

No, the four skills.

—but also writing, listening, reading, and so forth. So, people could be at different levels on each of those different skills is the point. 

In theory, yes, but I do think that generally speaking you're looking for a single level that an individual would attain.

Thank you very much. Thank you.

Thank you, Chair. Good morning, Efa.

Good morning.

You noted in your written evidence that you had some concerns in terms of the level of detail in the Bill regarding the language categories that will be applied to schools. Can you expand on this, and explain whether you see it as a step forward or a step back in terms of the current arrangements set out in non-statutory guidance?

Thank you very much for that question. Certainly, I see this as a significant step forward. I welcome the clarity that can be provided to parents, and pupils, who aren't always clear on these issues at the moment. And I fully support the concept of having categories in place so that schools can strive for them, rather than trying to categorise on the basis of a huge range, which is currently the case. It is that broad range that reduces clarity for parents and pupils alike at the moment.

However, I would express some concern—and I understand why the details aren't in the Bill and that they will be set out in subordinate legislation—but something to be guarded of, possibly, and that is the broad range that could exist in the primarily Welsh language category, for example. At the moment, there are schools that are 100 per cent Welsh, 90 per cent Welsh, but, in that top category, you could be a school with 60 per cent of provision in Welsh for 70 per cent of the pupils, for example. So, there's a very broad range of what could be included in that primarily Welsh language category. I think that the communities commission referred to a possible category of 80 per cent as a minimum for a Welsh-medium school, as we would understand it. So, perhaps the Bill could be strengthened in terms of placing a minimum level for that category. But I do understand why, in practical terms, it's better to have that kind of information in subordinate legislation, but we must just guard against making the category so broad that we add again to the complexity that we're trying to avoid by creating these clear categories in the first place. So, that's something for your consideration perhaps, as you move forward.

I'm sorry, I can't—

No.

Thank you. You've spoken a little bit about this already, but I'll ask the question anyway. The Bill sets a minimum amount of Welsh language education provision, 10 per cent, that must be provided in primarily English language, partly Welsh schools, but there's no such minimum amount for dual language or primarily Welsh language schools. Are you concerned at all that the Bill focuses overly on English-medium schools at the lower end of the spectrum and not enough on ensuring pupils fully develop their Welsh language skills in Welsh-medium schools?

Thank you. I think I've already answered part of that question in my previous response. However, one point that I would like to highlight is that it is Welsh-medium schools that will produce the most confident Welsh speakers for the future. And whilst I happen to believe that it is, actually, a matter of social justice that every child in Wales should learn Welsh, however, it's Welsh-medium schools that will produce the most confident Welsh speakers. And evidence does demonstrate that it's confident speakers who are most likely to use the Welsh language in their daily lives and are most likely to transfer the language to their children, and that of course is hugely important. So, whilst I welcome what is suggested in terms of English-medium schools, I don't want that to be at the expense of the development of Welsh-medium education—and perhaps we will come on to talk about the workforce later—but we need to develop Welsh-medium education as a priority, as well as providing everyone in every school with the opportunity to learn Welsh better than is currently the case.

Thank you. How effectively do you anticipate schools' Welsh language education delivery plans working in practice? And do you have any views on the provision for primarily English, partly Welsh schools, to be able to apply for temporary exemptions from the requirement to provide 10 per cent of Welsh language education?

Well, this is another proposal that I warmly welcome. The legislation does provide a framework for planning, which has a high-level framework, it has the WESPs that then feed down into the local delivery plans, and therefore individual schools. So, I welcome the concept very much. That is a gap in the system at the moment, in terms of the responsibility on individual schools, so I certainly warmly welcome using this as a means to move schools along the linguistic continuum.

I understand why processes are being proposed for those temporary exceptions, and, if I've understood it correctly, the temporary exemptions could mean that there would be a delay of 10 years for some schools. Whilst we can perhaps understand the reasons for that, that does feel like a very long time, and even in a case of an exemption, we need to prepare now or we will just reach a point in seven years' time, and we will be saying, 'We've forgotten to think about that.' So, even in a position of an exemption, the planning should start now. But I welcome the concept and the method set out.

Thank you. And my final question: does the Bill, in your view, do enough in terms of ensuring the necessary education workforce is in place to deliver the increased amount of Welsh language education provision envisaged? If not, how could the Bill be strengthened?

Thank you very much for the question. That was one area that I did want to draw to your attention today. The difficulties in developing the workforce will come as no surprise to you as a committee. We are aware that the delivery of this whole Act will depend on having a qualified workforce. There is mention in the legislation about workforce development, but my view is that that could be further strengthened, perhaps by asking the framework to refer specifically to the development of a workforce plan. The athrofa provides a means to support teachers and to create resources, but I do think that it's the Welsh Government that has some of the high-level levers in terms of initial teacher training, and ensuring that everyone who qualifies as a teacher in Wales does receive support to develop their own language skills, for example.

There has been some work done in this regard in recent years. We do have a workforce development plan, but if you look at the figures, then there is still work to be done in this regard, certainly if we want to see this legislation succeeding as we would hope. So, anything that could be done to strengthen that requirement to plan and develop the workforce, I would welcome that.

If I could just come in on the last point: do you see value in placing specific targets for developing the workforce, so that that is an aim for the Government?

Well, setting targets can certainly focus the mind. There are around 1,000 people training to be teachers at the moment, if memory serves me correctly, and I don't know what the figures are in terms of how many are Welsh speakers or intend to learn the language, but if we are talking about developing schools and moving schools along the continuum, then it makes sense that we should be able to work out how many teachers we need that can speak Welsh. I have seen some figures in terms of the numbers of teachers due to retire over the next 10 years, and the body responsible for registering teachers does record teachers' language skills. So, there's a great deal of data being collected and, yes, why not set a specific target so that we know what we're seeking to deliver?

Yes. Thank you.

Lee, to be honest, I'm not hearing you very clearly, but I think I’ve understood what you were asking. If I’m not answering the question, will you come back to me? The points that you ask is the reason for this legislation, I think, namely that we want to increase and improve the teaching of Welsh to pupils in primarily English language schools. There is an emphasis, as regards the institute, on developing resources and materials to improve the teaching of Welsh in primarily English language schools, so I think that's an important piece of work that needs to be done.

It's difficult, isn't it? In an ideal world, we would have enough teachers tomorrow to do this work. But that's why steps have been put in place in the legislation, because we understand the situation, and that's why I'm of the view that we need the education workforce development plan to go with that legislation so that we improve capacity, that we support schools to move along the continuum, but also, at the same time, stay focused on increasing the number of Welsh-medium schools that are available. Welsh-medium education is not the easiest choice in many areas of Wales at the moment, and I do think that many more parents would choose Welsh-medium education for their children if it was the nearest school to them, for example. So, I am of the view that there is a need to keep a focus on developing Welsh-medium education, but, of course, I also want to see everybody in Wales having the opportunity to learn Welsh and that the way we teach pupils in English-medium schools improves. In order to do that, there is a need for better resources, better support for teachers, and more teachers who have been trained to teach the Welsh language and through the medium of Welsh.

You asked a question about my work and the organisation. As I explained at the beginning, my role relates more to offering opportunities for people to use their Welsh language in the workplace and to ensure that people, as they go about their everyday lives and when they engage with the public sector, can use their Welsh more easily. 

I'm not sure whether that has answered the question.

Thank you for the points that you make. In my view, and stemming from my experience in the field of teaching Welsh to adults, there would be a way, quite quickly, of developing better resources and better support to schools to teach Welsh as a subject. It doesn’t make any sense to me—and I declare an interest because of my previous work—that there’s been a vast investment in developing resources for adults but no corresponding investment on that scale for school pupils. So, there are quick wins that are possible in this process.

As I said at the beginning, legislating is the easiest part of this work, but I think that setting targets and setting a direction, taking people on a journey, and being clear in terms of the linguistic continuum, and the fact that we want schools to have that ambition, and that these things, with time can improve—. But there are some things that I feel that could be done quite swiftly to improve the experience of learning Welsh in primarily English language schools.

Yes, I warmly welcome that. I think that the concept of drawing up a national framework, which would sit below the national strategy, is a good idea. That’s what will set targets in terms of education, and will set the context for the WESPs at a local level and school plans. So, for me, it makes sense that one flows into another, and that there is a line of accountability between one and the other. And, in my view, it is far stronger than what has existed in the past. So, I welcome that.

Yes, I understand those concerns, and that’s why I think that the system of exemptions is included in the Bill. As I mentioned in response to a previous question, that could go on for 10 years, which, for me, feels slightly too long, but I do understand, because of the reasons that you’ve outlined, that that's why that flexibility exists within the Act.

I welcome the fact that it will be easier for schools to move along the continuum because of the provisions contained within the legislation, and I do think that the flexibility contained in the legislation in terms of exemptions is appropriate, for the exact reasons that you set out.

Thank you for the question. I do think that this is something for you to consider as a committee and is an element that I, myself, think needs to be strengthened. I'm not questioning the policy intention in the Bill, and the explanatory memorandum makes clear what the intention is, but sometimes in the Act there is mention of Welsh-medium education provision, and I think this could be explained more robustly. I have referred in my written evidence to examples where I am concerned about this. There is talk about increasing the provision of Welsh language education without it being clear if it's Welsh-medium education or teaching Welsh in primarily English language schools. As I said, I think the policy intention is clear, and that has been set out, but I think it's a matter of wording in some places in order to make that clearer, because I don't want to see that reduction or dilution of the idea of Welsh-medium education, and that needs to be clear.  

I'm happy in this case with what's proposed within the legislation. I don't think that the change of wording is significant. Local authorities have now welcomed and are implementing the WESPs, and the regime, as far as I can see, is starting to work well. But I do think that there has been a weakness in the national targets that are set. So, I think that this regime does allow for that to happen. So, I think that what is proposed is a positive development and provides more connection between the WESPs and the national vision and ambition. 

Yes, I do think it is possible, only if we do things such as legislate in this area and ensure that children leave the education system in Wales able to speak Welsh. Legislation such as this isn't the only thing that's required; Welsh Government has just had the Commission for Welsh-speaking Communities report and had a number of recommendations about how we can strengthen the Welsh language on a community level. There are things in terms of my work that we could develop around them. So, together, all these things provide a good opportunity for us to reach that target.

Therefore, certainly, I am optimistic that, together—even though we live in a country next door to one of the world's most influential cultures—we are doing our best as a language to ensure that future generations can enjoy using the richness of that language and ensure that people in the future have the gift of speaking Welsh and speaking more than one language.

Thank you very much.

Thank you very much. Very briefly, if I could return to your response on what you see as being problematic, namely that differential between Welsh language education and education through the medium of Welsh, what do you think could be the unintended consequences of that on the parental perception perhaps?

That's exactly what I think one of the unintended consequences is, if you are a parent who wants to make a choice for your child. That is, let us be clear: if you send your child to Welsh-medium education, that pupil will be bilingual. There is no guarantee that you will emerge from bilingual education, as it currently exists, as a speaker of Welsh and English with the same level of fluency and confidence. So, it's Welsh-medium education that creates bilingual speakers. And so—. Also, it relates to the fact that it would be very easy for us to say, 'Well, every school provides Welsh-medium education at some level', but, of course, that won't be the upshot of the legislation, and that's not what we want to see either. Certainly, I want to see Welsh-medium schools developing and nurtured further and also of course to see improved provision in primarily English language and bilingual schools.

Thank you.

Yes, I'm not sure about the second part of the question, if I've mentioned that. However, in terms of establishing the institute, the point I really wanted to make, really, was that, if we expect the institute to do the excellent work that we think the institute can do, it needs sufficient funding. The memorandum does mention a little that there's no way at the moment that the budget can be clear because of changes to the middle tier, for example, so, I understand the reasons for that, but the point I wanted to make was that, if we want the institute to do the work that I think it can do, we need to ensure that it receives adequate funding, realising the budgetary position that we are all in. However, if we want good things to happen, we do need to realise that we need to invest in it.

I'm not sure—. I don't think I've referred specifically to students leaving Wales, but—

It's okay. No problem, but, clearly, I don't want to see students leaving Wales either.

Thank you and best of luck with your work.

Shall I start? I'm Professor Enlli Thomas from Bangor University. I am a member of the Welsh language partnership council, so there has been a great deal of discussion on the Bill in those meetings, but, other than that, I've had no particular involvement with the Bill.

Good morning. I'm Gwenno Ffrancon. I am the director of Academi Hywel Teifi at Swansea University, and also deputy pro vice-chancellor for the Welsh language, heritage and culture, and, in terms of engagement with the Bill, I was part of the team that responded to the White Paper prepared for this Bill on behalf of Swansea University.

I'll go first, if that's okay, Gwenno. 

Thank you. Generally speaking, I think this is far-reaching and groundbreaking for the Welsh language in certain areas, in ensuring that there are favourable conditions, such as those mentioned in 'Cymraeg 2050', that will help to achieve the main aims and ambitions of that strategy. But, personally, I think providing those conditions on a statutory level in one of the most important areas for the success of the Welsh language, namely the education system, provides us with the best opportunity of delivering themes one and two in 'Cymraeg 2050', reaching a million speakers and increasing language use. If we get this right, then we have a golden opportunity here, I think, to ensure that the Welsh language prospers and is sustainable over coming years.

I'll come in to endorse exactly what Enlli has conveyed. Certainly, the Bill is something we welcome; it offers the promise of cross-sector working in education, and that would be very useful in promoting the Welsh language. There are areas where I feel that things could be strengthened in what's been outlined, and I'm sure we could get to that in due course, but, in general, there is a warm welcome for the Bill at this point.

If I could go first this time. I was listening to last week's session, and the Minister for the Welsh language, Mark Drakeford, set out clearly his view that having a target on the statute book protected that target and actually reinforced it within the remit of Welsh Ministers, and perhaps local authorities too, and gave further status to the Welsh language. I think that's accurate, and that having this on statute will allow that. It will be a means of ensuring that stakeholders in all parts of the compulsory education system commit to delivering, and it'll be a means of crystallising our thoughts in delivering the goal. It provides some assurances in terms of the objective, and it is key, therefore, that the framework for delivery is fit for purpose. That's where I perhaps would make some suggestions to strengthen that. I don't know if you want me to outline those at this point, or shall we come back to those?

I just feel that perhaps there is scope to strengthen some of the drivers for delivering all of the objectives. Perhaps they all haven't been identified effectively. We need to confirm the specific targets in the legislation within the sector and to tighten the timetable to ensure there's no slippage in delivering the aim, namely what will be a statutory target of a million Welsh speakers by 2050. Thank you.

I'll start here, then, Gwenno. Of course, how we measure and record speakers depends on what the purpose of that data is. Perhaps, for political purposes, recording use isn't going to show as much progress as recording the number, but if what we want to know is if there's been a sustainable increase that's a meaningful increase then it is key that we measure the use of the language. So, that's what provides us with that information. Use of a language gives us information about the viability of the language, and that helps us then to move the narrative away from the Welsh language as a minority language, as a language that's under threat and so on. That would then provide a much stronger status to the language. So, personally, I would say that we need to ensure that those indicators include what we're aiming for in step 1 and step 2 of the 2050 strategy.

If I could come in and agree with that, I think, yes, we need to record numbers, but it's language use, that's where we ensure [correction: where we need to ensure] that the language is viable and I think there is scope within the Bill to look at co-operation or how we identify and encapsulate this in—[Inaudible.]—[correction: in the Bill and ensure co-operation with the organisations] around the education system. So, education is at the core of this Bill, but there are so many organisations and institutions that support language acquisition that aren't directly educational establishments, but are there to support the development of the Welsh language and to transfer those skills into communities. I'm thinking of the canolfannau Cymraeg, mentrau iaith, Urdd Gobaith Cymru and the lifelong learning provision of the local authorities. So, there is scope to look at that within the Bill, I believe.

Good morning to you. I'm Cefin Campbell, Member of the Senedd. Thank you very much for the evidence that you have submitted; that is very useful. I want to ask a general question to start with on the CEFR, and then perhaps more detailed questions on that. It's clear that this framework is very familiar to people in European countries. Except for Welsh for adults, it's an unfamiliar concept for some. We are recommending introducing this as a framework for our education system in Wales. Do you welcome that in general? That's the first question I want to ask.

I can come in there, Gwenno. Certainly, one of the challenges that has faced the Welsh language and how we measured the success of the language in the past is the fact that we didn't have the CEFR. That has meant that our indicators have fallen—[Inaudible.]—of students studying GCSE Welsh first language, and how many study through the medium of the second language. But, of course, there is so much more to language than that, there is so much more in terms of the success, fluency and confidence of individuals in becoming involved with the language. So, the CEFR does provide those codes and those particular labels in terms of how one would describe oneself as a speaker, but there is additional flexibility, too, in the CEFR, because it is a continuum, and there's a narrative around how we can ensure that our speakers are on a continuum. And what's wonderful with a continuum is that one can always make progress. And I think that is of great assistance in terms of this concept of trying to support learners to be involved with and learn Welsh throughout their lives. So I do think that it feeds into that general concept far better than what we've been using in the past.

I would also agree with that, because not only does it enable us to identify attainment level within an education context, it also translates into the workplace, where there is a better understanding, then, of what an employer can expect in terms of skill level. And as an employer, at Swansea University, we are in the process of introducing this exact framework into our employment policies. So, as an organisation, we would welcome that.

Thank you very much. Specifically, in your experience of studying bilingualism at a European level and your understanding of the CEFR framework, is it realistic to expect a pupil who is in a primarily English school to reach the B2 level in spoken Welsh by the time they leave school?

I'll come in there. If I could just read a quote that I came across earlier this week. It's on social media from Li Wei, who is an expert in the area of multilingualism. What he says is this:

So, I feel it's very important, if we're to approve the use of the CEFR, that everyone is aware of what being on different levels of the linguistic journey means, and to what extent setting expectations that are far-reaching—. I think setting a far-reaching target is a good thing to do, because it's possible to reach that. If we set the target too low, then we’re not moving forward at all. I think it's key that people understand exactly what learning a language entails and what someone can expect from an individual.

As I said, with the CEFR, what's good about it is that it is multilayered, and therefore there are levels of CEFR where someone can have different descriptions that relate to their confidence in speaking, their written ability, their understanding of the language, and so forth. So, I think there is a way of being a little bit more flexible than just expecting that somebody has to reach a specific target and that somebody hasn’t succeeded if they don’t reach that target. So, I think the narrative around this needs to be developed a little bit further.

Sorry, I didn't know if Gwenno wanted to come in on that point.

No.

No problem. Dr Enlli particularly, in your evidence, you set out some doubts around children achieving C1 or C2 level in Welsh-medium schools. Can you expand a little on the basis for those comments?

I think that comment takes us to another point that is key in terms of the context of the Bill as a whole, which is the support that’s available for the Welsh-medium sector. I have a concern that there is some sort of mindset of the 1970s that Welsh-medium schools are natural immersion schools and that just dropping a child from a non-Welsh speaking background into that regime means that the child will then turn into a proficient and confident Welsh speaker. Of course, that is the sector that has the greatest success and the ability to turn speakers into confident and fluent speakers, because of the involvement with the Welsh language, but do we really understand how much involvement with the Welsh language is now happening at classroom level, given the range and variation of pupils from different linguistic abilities that are within the same class, and all being educated through a minority language?

So, I think we have to be realistic in terms of what is the assurance that some children who are from non-Welsh speaking backgrounds—who don't speak much Welsh outside the classroom, perhaps not using Welsh within the classroom either—in what way is setting that target of C1 or C2 for some of those pupils going to have a knock-on effect on their ability to be completely fluent and be very good B speakers. I think that that, for some pupils, is going to be a success for them. So, I think we just need to reconsider what the expectations are, given the linguistic experiences of some pupils in some schools in some areas of Wales.

Okay, thank you very much.

I think not only in this Bill but also in a number of other documents, when reference is made to children with additional learning needs, very often it’s a very brief reference, and I think it is difficult to understand exactly what support is necessary in that context. In the Welsh context, I think it would be quite fair to say that there is concern among parents about children with additional learning needs, and this issue has come up in Ireland with the issue of being able to opt out from the teaching of Irish in the sector there.

But the truth of the matter is that there is evidence that demonstrates that ensuring that the child develops bilingually and has bilingual experiences is crucial, but you need to look at it on a case-by-case basis, and to look at the individual child's needs. But there isn't much guidance for teachers here. And, of course, when we're talking about ALN, we are talking about a very broad range of children, some who perhaps don't cope well with written language, and then there are others who will have needs that are nothing to do with language. So, there's a broad range there, and I don't think there is—. Well, there's no reference to that in the Bill, anyway. 

I would like to see some reference to it in the Bill. In terms of the guidance, I'm sure that that could be better developed in other guidance that looks specifically at ALN.

Okay. Thank you.

Thank you very much. Good morning. What are your views on the language categories that will be applied to schools under the Bill? Do you believe this is a step forward from the current arrangements set out in non-statutory guidance?

I'll respond briefly by saying that it's a step forward in terms of the categories we have at the moment, and it should lead to progress—progress in terms of the schools within those categories, and progress in moving through those categories too, and that's what's crucial in this context. We have to put those schools on a language continuum, as Enlli mentioned, and to clearly map the steps to allow that progress to take place against the statutory targets. Perhaps I would argue that we shouldn't rely on Ministers varying the focus provided to those targets, and that those targets should be placed clearly in the Bill, and the support that will be available to deliver that. 

I agree with what Gwenno has said. The simplicity of the system that's being proposed I think is to be commended. Because I am aware that there are teachers in the education sector currently that aren't perfectly sure whether the school they're working in is a Welsh-medium school, a bilingual school or an English-medium school.

Thank you. The Bill sets a minimum amount of Welsh language education provision that must be provided in primarily English language, partly Welsh schools, but no such minimum amount for dual language or primarily Welsh language schools. Are you concerned at all that the Bill focuses overly on English-medium schools at the lower end of the spectrum, and not enough on ensuring pupils develop their Welsh language skills in Welsh-medium schools?

If I can come in there first, Gwenno. Because the focus is on increasing numbers, of course the focus naturally falls on the English-medium sector and the baseline set there. As I said earlier, I think there's been a misunderstanding of what exactly is happening in Welsh-medium schools in order to identify exactly what the baseline would be to allow those pupils to be entirely fluent in both languages. So, I would say, yes, there is a little more emphasis on the primarily English language schools in the Bill.

Thank you very much. Just on the back of the question from Tom, Dr Enlli, in your evidence, you have noted—and I'm just going to quote here—that the minimum 10 per cent requirement for primarily English, partly Welsh schools is vague and needs further thought. Would you be able to just explain what exactly you mean in terms of the fact that that 10 per cent is ambiguous?

Yes. Is it 10 per cent of the school day, 10 per cent of the school week, 10 per cent of subjects—what exactly is the concept there? Because my understanding is that the intention is to increase pupil engagement with the Welsh language, but, of course, there are all sorts of ways of doing that that could perhaps be more beneficial to pupils, if that engagement happened in the more social spheres within schools, for example.

Also, that 10 per cent does have to have some sort of input from teachers, and if the education workforce isn't fluent in Welsh in some of those schools, then there are different approaches again in terms of addressing that 10 per cent. We live in a digital world, so there are all sorts of ways of doing that. But I would have thought that if I were working in a primarily English language school, I wouldn't know exactly what would count towards that 10 per cent, and I think there's a way of ticking the box and saying on paper that 10 per cent is provided, but whether that 10 per cent is beneficial as regards delivering its ambition, I'm not entirely sure.

If I could just jump in on that point and add to what Enlli has just said, would that be okay, Chair?

Thank you. I agree that there is ambiguity around the categories in general, I feel, and in terms of that point with regard to the 10 per cent threshold in primarily English schools, what we would wish to see, after further clarity regarding what this means, is a measure within the Bill to identify over a period of time the moving of those schools to a level higher than 10 per cent. I wouldn't wish to see schools staying on that threshold, thinking they'd reached the target. The hope would be to increase what they provide as primarily English language schools.

If I could then just note the primarily Welsh language category, and your question regarding how the emphasis possibly is on the schools that aren't primarily Welsh language, I would, perhaps, wish to see the expectations in that primary Welsh language category defined more clearly within the Bill, clearly noting that it would be only Welsh-medium education delivered in that school, except for teaching English as a subject, and provide clarity and safeguard the opportunities for those pupils to develop fully their Welsh language skills. That's the specific challenge currently, I would say, in terms of the Welsh-medium sector, and, as Enlli mentioned, that presents challenges for our pupils if they don't have that completely Welsh environment in their education.

One element that influences us as universities is that, currently, there is no clarity around the need for schools to teach STEM subjects through the medium of Welsh. The expectation in public, possibly, is that those subjects are taught through the medium of Welsh in primarily Welsh language schools. That's not true across the board and across Wales, and that presents another challenge for higher education as it tries to train future doctors and scientists, and future teachers, and ensure that they can move forward to introduce these important subjects in their own schools.

Well, I don't think I fully understood from the Bill what exactly is at the heart of that proposal, but certainly I wouldn't support that concept unless there were very, very specific reasons for its use. As I say, I'm aware of the lengthy debate that there's been in terms of the Irish language and the ability to opt out, particularly in the context of children with ALN. But, again, I don't accept that argument in certain spheres either.

So, I don't think that any school should be exempt from the minimum, and I can't quite imagine, from what's in the Bill, what would actually lead to a school asking for that, unless the workforce wasn't in place to provide that 10 per cent. But, as I say, you don't have to have individuals who are fluent in order to introduce the Welsh language to pupils and to engage those pupils with the Welsh language, which is the purpose of increasing those hours in the first instance.  

I would also support that viewpoint, and would note that if the exemptions remained in the Bill, there would be a need to ensure very short periods for those exemptions so that the timetable for that specific school didn't slip, to ensure that they achieved the statutory aim. 

Thank you. Just to go back to those final points, given that the Welsh language is a compulsory subject in our schools, and some would argue that we're already providing about 10 per cent as regards teaching Welsh, is this 10 per cent sufficient in your view? And in particular, Dr Enlli, you mentioned the fact that it was ambiguous. Would you want to provide guidance to the committee in terms of what you would like to see that 10 per cent meaning? 

Yes, in putting it in those terms, that's a key point, isn't it, which just echoes what I said previously, because the concept is that the Bill ensures that something new happens, something that hasn't been happening in the past, because if we continue as we have been and use that 10 per cent just for what's already happening, which is teaching Welsh as a subject, then we're not going to increase the number of speakers at all, because we know that the status quo doesn't work. So, this is a golden opportunity to provide something new. So, I think there's a piece of work that could be done in order to identify what those opportunities could be. 

I'm sure that there are examples in European nations in terms of the kinds of things that happen there, and, for example, we have that concept of Cymraeg bob dydd, Welsh every day, from the Sioned Davies report years ago. But because that was not statutory and there was no guidance in place, that seems to have disappeared. And that was an attempt to ensure that every subject made some use of the Welsh language, even if the teachers simply opened the lesson in Welsh and it was then taught through the medium of English. There are strategies of that kind that could be adopted under the institute, for example, and that is something that could certainly help in that context.    

The answer from me is 'none'. I couldn't think what they could be, except for a situation where the workforce isn't available. But, as I say, there are ways around that. And perhaps, again, that's something where the institute could support and offer guidance and leadership to schools on how to do this while the workforce isn't there. 

I hope that I've interpreted the Bill correctly in that regard, but I had to read that section time and time again just get my head around what exactly it entailed, and to consider if I was right in terms of the same attainment being listed for different kinds of schools. I think we just need to be mindful in terms of knowing how some parents make decisions on schools, and so on, and parents' considerations. Of course, there are those parents who are very supportive of the Welsh language but want to ensure that their children have enough education through the medium of English too. So, if we say that, in sending a child to a primarily English school or a dual language school, their attainment through the medium of Welsh will be the same, whichever they choose, then I have some concern that many parents will opt for the primarily English school rather than for the dual language school. And if we don't have dual language schools, then we can't move those schools forward on the continuum to become Welsh-medium schools in future. And perhaps, as I say, I've misinterpreted that particular section—I did have to read it more than once.

Interesting. Thank you. And one question to end on: does the Bill, in your view, do enough in terms of ensuring the necessary education workforce is in place to deliver the increased amount of Welsh language education provision envisaged? If not, how could the Bill be strengthened?

If I could come in at that point, maybe, and note that there is scope to strengthen what is being outlined, I think. There is a lack of clarity perhaps in terms of where the training for those skills lies and who is responsible for that training. There are so many organisations who are eager to contribute and to help with that aim—the centre for learning Welsh, the coleg Cymraeg, the Education Workforce Council, local authorities, and us as universities. There are different interventions of course that can be introduced in terms of a teacher's career, to learn or to strengthen their language skills, for example—[Inaudible.]—or [correction: for example, while undertaking] the higher education course to train to become a teacher, and also there's training in the workplace. So, it would be interesting to know, in the Bill, where exactly does the responsibility and funding for that lie.

I would also think that more stakeholders could be included in this element. The universities are relatively invisible within the Bill. There is no talk of consultation directly with universities, and specifically schools of education in universities, where teacher training happens. So, I would suggest that that is one thing that could be considered. And in our response as a university to the White Paper originally, we proposed that there was scope to consider including a specific period in order to introduce the language, or improve language skills, within the initial teacher training course—that this should happen before they're out in the workplace, where there is huge pressure on them to deliver other things in their day-to-day responsibilities—and so that there's an opportunity for us to look further at the training that we could be providing in linguistic terms during their initial teacher training processes.

Thank you very much.

Do you want to go first, Gwenno?

Yes. This was an area that's beyond my field of expertise, in a way, but I could see that there was an intention to tie in the element of schools and governing bodies—I think including governing bodies is essential—and also local authorities, and then the Welsh Government. On the issue of who then should be part of the consultation on the national framework, I felt that there were stakeholders that were missing specifically from this—universities. Currently, we are part of the WESP committees in local authorities—that's the role, certainly, of Swansea University—so that we can look across the whole education continuum. We also feel that we can contribute to other elements of what's happening within the education sector—for example, lifelong learning. And currently, that consultation doesn't include universities, and neither does it include the Coleg Cymraeg Cenedlaethol. So, I saw that, perhaps, as something that should be included within this process, but the accountability line is reasonable, just who are the stakeholders that are to be consulted on needs further attention perhaps.

Like Gwenno, I don't think that I'm particularly expert in this part of the work, and I'm not particularly familiar with the current system, but what's contained within the Bill looks sensible to me, as Gwenno's outlined.

If I can come in first, particularly on the name. I would suggest that 'WESP' has taken root now, since being introduced some years ago. There is an understanding of what it is and perhaps it encompasses the objectives of the Bill more effectively, namely Welsh within the education curriculum, but also Welsh as a medium for education. So, the title, for me, as it currently exists, works.

In terms of those plans and target setting, yes, it's reasonable, but I would say that perhaps the best way of achieving targets is to collaborate to identify those targets in the first instance, so I would say that there is perhaps scope to have dialogue between local authorities and Government, because the local authorities do have an understanding of the challenges that they face locally, their local ambitions, and then the role of Government would be to challenge that specifically.

No, I agree, and I think that the Government setting targets is crucial, because that then allows the Government to have an overview of the situation across the country too, and to monitor progress. So, I agree with Gwenno's comments.

Again, I don't think I have particular expertise in this area, but five years is a long time, isn't it, and it can be a pupil's whole experience in the secondary sector, for example, so, if something doesn't work for five years, then we've lost a number of speakers. So, I think that ensuring that these plans are challenged relatively regularly would make sense to me, certainly.

I would agree with that, yes. We need a way of identifying underattainment in terms of the target quickly enough to ensure that time doesn't pass without progress being made. But also, of course, you need to balance having enough time to implement and to see the impact of changes or interventions that are introduced. So, perhaps we need to look further at that timetable to ensure that it is appropriate, balancing those two elements.

Thank you very much.

I think, particularly as the framework mentions a national framework for Welsh language education and learning Welsh, I think the athrofa or the institute would focus far more on learning Welsh rather than the Welsh language education element. And I think that this is something that needs to be developed further. I am aware, of course, that there are major changes in the pipeline in terms of professional learning for teachers across Wales and that steps are being taken in order to put that on a national level, and, of course, training for teachers in the Welsh-medium sector and so on, and those who teach through the medium of Welsh—that will be part of that offer, I assume. But I don't know how much attention will be given to that in that particular case, and so we have an institute that contributes to this national framework but doesn't seem, to me, to be pursuing that element of teaching through the medium of Welsh. Teaching through the medium of Welsh is very different to teaching Welsh. Teaching Welsh, you're teaching a subject, essentially. It provides a skill to individuals.

Now, we could provide excellent Welsh language skills for many teachers, but do those teachers then know how to use the Welsh language to teach children in other subjects? And in the context of the Welsh language, as I said earlier, when one teaches through the medium of Welsh, it's a very different situation to teaching through the medium of English. It doesn't matter how many children in front of you speak those languages as a first language, there are far more challenges in the context of teaching through the medium of Welsh. And I have said publicly in a presentation some years ago, that, personally, I feel that teachers who teach through the medium of Welsh are specialist teachers, and it requires a level of specialism that isn't required if one is teaching through the medium of English, and I'm not entirely sure where that training is going to fall now. Because one might assume that the institute would prepare that training, but then the institute might assume that the training would be provided through professional learning, and that it will happen there. So, I'm a little fearful that that training will fall by the wayside.

Can I come in?

Maybe so, but, as I say, I don't know where the discussions are in terms of where support for teachers in the Welsh-medium sector sits. Perhaps those discussions are happening in relation to professional development across Wales, but I simply don't know. But, as I say, I wanted to raise the fact that it could be lost.

Thank you. To follow up on that point, yes, I think this is where the main ambiguity within the Bill lies. We're not sure where aspects of workforce training fall. Neither are we clear why there's a specific gap in the Bill in terms of further and higher education. There is discussion of statutory education and then lifelong learning, but that middle part is very ambiguous, and that’s where the key to delivery of some of those skills lies, and we need those skills within this particular sector. So, I would recommend that we need particular consultations with universities and the schools of education within universities, and also with the Coleg Cymraeg Cenedlaethol on that point, where the expertise and guidance has come from to date, in terms of providing training through the medium of Welsh [correction: training for teachers through the medium of Welsh].

I think there's a need for clarity so that the responsibilities are clearly set out and the expectations of the different sectors are set out, but perhaps the minutiae are discussed further in other fora that are abstruse to me because I don’t frequent those particular circles.

Angharad Morgan, policy manager for Mudiad Meithrin, and I've been responsible for drafting Mudiad's responses to the original White Paper, and also the consultation on the Bill. 

Hello, how are you? I’m Dr Gwenllian Lansdown Davies, chief executive of Mudiad Meithrin, and, like Angharad, have assisted in the work of responding to the consultation on the original White Paper, and responding to the consultation on the Bill as drafted.

Hello, Gwennan Schiavone, chief executive, CYDAG. Now, I haven’t been directly involved at all with the Bill in terms of any aspect of it, but I will be co-ordinating the written response that we will be providing within a fortnight, as part of the consultation, on the basis of consultation with all the members of CYDAG, which is Welsh-medium and bilingual schools.  

I think we as an organisation would describe our response as a ‘guarded welcome’ in terms of the Bill. We are passionately in favour of the target of a million Welsh speakers by the year 2050, and doubling the use of the Welsh language, and we’re eager to emphasise the importance of the work in early years, childcare and play in terms of contributing to that target, because we know that progression rates from the early years into statutory education are particularly important and influential. Those rates are around 88 to 89 per cent at the moment—that’s the percentage of children leaving the cylchoedd meithrin that go on to receive Welsh-medium education. And around 80 per cent of children who come to cylchoedd meithrin are from homes where English, or a language other than Welsh, is the language spoken at home. So, you have to recognise the importance of the early years for this Bill, although we do, of course, appreciate that it’s not the non-maintained sector or the early years sector that is the main focus of the Bill. And we’re pleased to see more recognition for the childcare sector and to working with parents in the draft Bill, as compared to what was included in the original White Paper.

So, we believe that there’s a great deal of work still to be done, that you have to recognise just how challenging the planning and implementation and the strategic planning will be when it comes to the growth of Welsh-medium education, and how fragile some aspects of the life of cylchoedd meithrin and day nurseries are, just as things are very fragile for English-medium playgroups and nurseries too.

So, our main interest is recognising that you can’t divorce the early years sector from what then happens within the statutory education sector. So, with that in mind, what’s included in the Bill is important and very significant for us as an organisation. And we believe that what is described has the potential to be transformational in terms of the objective that all learners leave compulsory education at 16 years of age having reached a certain level of language skill at B1 or B2.

Yes, well, certainly, I think we welcome the Bill, and the force that statute gives to targets and the aim, and, clearly, there are great strengths in the Bill in terms of doing that. I think the important thing from our perspective is the action that comes as a result of the implementation of the Bill, and to ensure that the details are correct in the legislation as published in order to allow that implementation to happen, and to drive change and that everything is strong enough to enable that to happen.

At the end of the day, I think we can all say that it's education that will create Welsh speakers. That's where the great leap will happen in terms of Welsh speakers in the future. So, this is a crucial area and it needs the investment, the energy, the effort, resources and time, and clearly having legislation to underpin this will allow that to happen. The fact that it provides lines of accountability is crucial, and it makes it more robust, and so certainly we welcome it, but there are elements within the Bill that we would be eager to discuss further.

Well, certainly the draft we currently have is an improvement on the original wording in the White Paper, because there is recognition of the importance of early years and also the importance of working with parents. That work of promotion is important, but I think that we as an organisation would also argue that, where parents have a choice between Welsh-medium education and English-medium education, on occasion parents will make the choice for Welsh-medium education, but on occasion it will be easier for them to choose English-medium education for reasons of convenience, because of transport arrangements, and so on and so forth. So, any strategic planning and practical planning does have to take into account those issues that are beyond considerations of language planning—those very practical things relating to convenience. That's also true in early years provision.

We understand that the nature of our sector is that we are non-maintained, so this Bill cannot encompass Mudiad Meithrin sites within the non-statutory sector. But the joint planning that happens with schools and the fact that many cylchoedd meithrin are on school sites, are hosted by primary and secondary schools, is important to recognise and to consider in terms of planning. What I would also say is that, when there are plans to open new Welsh-medium schools and there is a cylch meithrin to be included on the site—and that's important—we have to be included in that discussion, because there are requirements by Care Inspectorate Wales that are very specific in terms of ensuring that the cylchoedd meithrin can meet the required national standards in terms of childcare, and on occasion, that isn't taken into account. So, we're talking about very prosaic things related to the number of sinks, the number of toilets, the floor space, access to open-air spaces. These aren't necessarily considerations that architects and planners think about in planning a school space. So, there are practical aspects such as those that we see that can occasionally be challenging in our work, because we get to a school site with a new cylch meithrin and those considerations haven't been taken into account. I don't know if you'd like to expand on that, Angharad. 

I'd agree with that. One of the other things that needs to be considered is that the work in terms of promoting Welsh-medium education happens from the cradle, and that parents start to make those decisions way before they get to the school selection form provided by local authorities. So, we need to ensure that any work in terms of promoting and developing the Welsh-medium education sector happens alongside all of those services and areas, such as the cylchoedd Ti a Fi, Cymraeg i Blant groups, and the cylchoedd meithrin, which have that earliest possible contact with family life. And then that means that there is a need for co-operation across departments of Welsh Government, because many of the professionals coming into contact with parents in the early years of a child are [correction: are not] captured under the education authority, they are health visitors, they come from the health sector, they come from the child play sector, they come from information for families services. And in terms of promoting and developing Welsh-medium education through the promotion work that's undertaken, we must ensure consistency in that promotion work and the messaging on Welsh-medium education that goes out across all those sectors, too.

I think it is fair to say that there isn't sufficient recognition of Welsh-medium schools and their contribution in the Bill as it currently stands, and there is perhaps a feeling that it's taken for granted, and perhaps, on that, there is a need to emphasise that the Welsh-medium sector isn't without its challenges either and does need support.

In terms of the contribution of the Welsh-medium school sector, again, returning to an earlier point, that's where the Welsh speakers, the users, and those at the highest level of attainment will be created—they are going to be the basis for the use of the language as they continue in education, in the workplace, in raising a family, and in transferring the language and so on. So, clearly, the importance of that sector, even if it is taken for granted, should be reflected more strongly, I feel, in the Bill. Without that, there is a risk, I think, because of issues that we might cover later, in terms of the categories and so on.

In terms of immersive education, we know—evidence shows—that language immersion is what secures fluency. Of course, the aim, we all hope, is that all schools in future will enable children to develop total fluency by having that immersive experience. But initially, however, it is the Welsh-medium schools that can provide that, and it's our job, beyond safeguarding and strengthening that sector, to ensure that other schools then are able to move along the continuum towards that ambition.

What's the value of any statute? What's the value of any legislation? That's a rhetorical question, of course. There is symbolic value, I would argue, to the fact that the target has been included on a statutory basis, but one always understands that there are limitations to the influence of any piece of legislation and that there are other considerations in terms of policy, in terms of planning, in terms of funding and investment, particularly in this area.

But we, as an organisation, have certainly seen more momentum since the adoption of the Cymraeg 2050 slogan, and as a target. It has made our work easier. The WESPs have also been adapted as a result of the review by the late Aled Roberts, so that outcome 1 includes the early years, and therefore, our hope is that having that objective on a statutory basis will strengthen our work further and will make it easier to be around the table as a partner, discussing and jointly planning with local authorities and the other relevant regulatory bodies.

I also think that the Set up and Succeed programme by the Mudiad, which works to the targets in the strategic plans at the moment, in terms of looking at areas where there are gaps in terms of early years Welsh-medium childcare provision, so that we can target those areas of greatest need and with the greatest need of more growth on the ground, so that we can prioritise those areas, which have those gaps at a local level for parents—. I think that is a programme that shows that that collaboration and those discussions are happening across the various levels, between ourselves, the local authorities and Welsh Government centrally, and that the value of that is huge in terms of growing the market on the ground.

I think what I would say is in terms of that is the importance of that statutory basis for any target. It gives it a higher status; it reduces the arguing about it; and one would hope that it would actually increase the responsibility in terms of delivery, and that that then would—. We all hope that there is goodwill, we all hope for encouragement and support and so on, but there is another element of course, where you need that robustness that comes from having a target and an objective that is placed on a statutory basis. And obviously, what we would then hope is that that responsibility would extend across Government and wouldn't simply fall on one department, under one Minister. So, that is what one would hope, namely that that basis just takes it up a step in terms of the aims and objectives and ambitions too.

Thank you very much, and thank you for your evidence and for the evidence that you'll provide, I'm sure, later.

In this set of questions, I'm just going to focus on the CEFR framework. It's a new concept for us in Wales, of course, outside Welsh for adults. Just generally speaking, what's your view on the introduction of a framework like this one, and what do you see as the benefits, and are there any disadvantages or challenges? If you could just give us some general comments first of all.

We are supportive of the framework. We are supportive of the principle that a standard framework that is recognised globally and internationally should be used, and there is no reason why that framework couldn't be used in order to have a set of standards, if you like, or expectations in terms of what it means to speak Welsh, just as is the case with any other language.

We have some experience of using a language checker in the past, and it was an interesting experience, but we would argue that there is value in having a framework that is standardised across different sectors, so that we are all working to the same expectations and same standards.

There is an undertone in this debate on occasion, I feel, that there is something that is fundamentally different about learning Welsh as opposed to learning any other language. Well, we would argue to the contrary, that the experience of learning Welsh is exactly the same as learning any language, and therefore, if this framework works for organisations across the world, why couldn't it also work here in Wales? And Angharad has done some research on the raw titles—A1, A2, B1 and so on. Of course, there are over 1,000 descriptors available to us that sit below those general raw categories, so it is as detailed as you want it to be, in reality. But I think our view as an organisation is that the CEFR is a good way of standardising or having a system that is recognised and that we can all work within.

I would agree. I think one of the benefits of using a recognised framework such as the CEFR is that it does provide us with a structure to work within. The fact that the C1, C2 is described as proficient users of the Welsh language is another step that is an important step forward in moving away from this element of using 'confident' and 'fluent' as descriptors, because defining fluency is more difficult, to an extent, than defining a confident user of the Welsh language. And what does 'fluency' mean? Because I can sit here and speak in Welsh about the Bill, about anything related to education, children, language planning, and so on, but if you were to ask me to give a presentation on a scientific subject, I wouldn't know where to start, because it's not my area of expertise, and I don't have the vocabulary in that area to do that in any language. So, it's easier to define proficiency rather than fluency, as the CEFR actually does.

Personally, I have no specific view on the CEFR as a framework. One would assume that detailed research has been done to come to the view that this would be the most appropriate framework. Clearly, adopting a common standardised model that has been accepted and trialled internationally, and so on, clearly there is a basis for making that decision. I think what I would say is that, clearly it's important that whichever framework is used means something, is fit for purpose, and is used to achieve an end, so the way I would see it, the purpose of a framework is to enable someone to set objectives in developing language skills and in educating, rather than how individuals define themselves. In looking at individuals defining themselves, I think that our aim is that there would be no need for someone to decide on their level and where they are; it's whether they can speak Welsh and use the Welsh language. What I wouldn't want to see is that any framework would be considered as any sort of cap on a level of attainment, and that the target is to reach a certain level. The aim is to secure Welsh speakers and users of the Welsh language. That's what the ambition should be. But, from an educational perspective and in terms of placing requirements for certain posts, then clearly there is a benefit and a scope for placing standards that are widely recognised and understood. So, the importance is that whatever use we make of these, we must ensure that people understand them, that they are fit for purpose so that they are understood and recognised in that regard.

On that final point then—a question for CYDAG, but I'd be happy to hear from you too—how much of a challenge will this be for our schools and for teachers, particularly, who will have to assess children according to an entirely new framework?

I think that's a question that would have to be asked in the context of other things such as qualifications in terms of GCSE and A-level, and we have to look at how these things map against each other. As with any new initiative introduced in schools, there is detailed work of discussion and consultation with schools as to how they are going to implement that and not just assuming that introducing something new that has a rational basis will necessarily work within the school context. So, I think that's where there should be real consultation with the profession and with the sector.

As I said, we do have to look at the qualifications that one gains at different points in their educational career, and in mapping up to that point, then, clearly, CEFR or any other framework would have to take into account what the aims and ambitions are, ultimately. And then that has to be be part of setting progress against any steps within the curriculum.

Thank you.

To add to that, what I would say is that we have a language immersion programme called Croesi'r Bont, Crossing the Bridge, which we've been implementing and refining for many years. So, we're confident that we do have specialist information based on experience of introducing a language to children who speak English or other languages in the home, and that we're therefore eager and willing to share that expertise with the education workforce more broadly, and that we are all on a language continuum, if truth be told, and that there are changes happening around us in terms of the best ways or the ideal ways of introducing a language to children, based on local and international research. As Gwennan has already said, what's important is that the workforce, be that the education workforce or the early years care workforce, does has that framework and support in place to help them, through training, to provide that in a way that feels appropriate.

So, what you're saying is that there needs to be investment in training in childcare, but also in the education workforce.

Certainly. I don't know if we'll touch on the workforce later, but the whole success of the Bill is entirely reliant on significant investment in the workforce in that aspect and other aspects too.

I agree. A final question from me, if I may, on the CEFR, and it's interesting to hear that you, Angharad, have done some research specifically on this. In the draft Bill, there are benchmarks in terms of attainment levels. We're talking about B2 for all children leaving compulsory education, and we're talking about perhaps C1 or C2 for those pupils who have been in Welsh-medium education. In your experience and given your expertise, is that realistic in terms of having 10 per cent of Welsh language education in primarily English language schools and reaching at least B2?

From my experience internationally too, I think we would need to increase that figure to truly achieve B1 or B2. In order to ensure, in the longer term, that all of our young learners in schools in Wales reach the B1, B2 standard, there would need to be significant investment in the education workforce first of all, in order to ensure that there was sufficient number of teachers and staff to support the development of pupils' skills. Because it's one thing to say that pupils will leave school at that level, but it's the workforce that's important in delivering that, and I think, in order to increase engagement with the Welsh language, we need greater ability within the workforce—the new workforce being trained, but also the workforce already in place. They need that support from the early years all the way through one's education journey. And I think one of the greatest challenges in that regard is to ensure that those targets are put in place in order to ensure that all of our learners across Wales, whatever the school category, ultimately do reach that B1 and B2 standard in the medium term and certainly by 2050 at the latest.

And I think the greatest challenge for us is how we can support the workforce and also how we share that information with families and the learners themselves in terms of the increased contact with the Welsh language that will be part of their education, and to calm some concerns that might arise as that increase starts to come through the system where English is the primary language, in order to ensure that those pupils do have more social contact, more usage of the Welsh language in subjects that aren't necessarily Welsh as a subject. Because, in reality, that 10 per cent is just the formal Welsh lessons that currently take place, and if it stays only in those formal Welsh lessons, then it's going to be very difficult to ensure that those learners can reach those B1 and B2 levels.

Thank you. I think we'll return to the workforce in due course. Thank you.

I think that they are a step forward. There are clear definitions of the three language categories. One challenge in that regard is that there is no definition on the face of the Bill in terms of the expected percentage in terms of what the primarily Welsh category would be. I think, at the moment, we need to look at at least the minimums in the current non-statutory guidance. But, I also think that we need to ensure that the use of these new categories doesn't undermine what is already in place in terms of Welsh-medium education in schools, and the expectation is that 90 per cent in a designated Welsh-medium school should be taught through the medium of Welsh, and that at least 70 per cent in schools that aren't designated Welsh-medium schools.

I think there is a huge challenge with that middle category, which is dual language, in those new categories, in terms of ensuring how 'dual language' or a 'bilingual school' is defined. Because, in the non-statutory guidance currently used—having reviewed them again recently—the concern that I would have is that there is a possibility to load that contact time with the Welsh language, particularly in the primary sector, in the early years of one's educational journey, and that's according to the definition in the current non-statutory guidance. We need to ensure that primarily Welsh and dual language mean that there should be a minimum percentage across a pupil's journey through education, not just in specific school years. All international research shows that it is regular contact over a long period of time that develops one's confidence to use the language on a daily basis, not just intensive contact in the short term.

Also, in terms of this issue of categories, an opportunity arises as a result of this Bill to look at language categories within the non-statutory or non-maintained sector. Therefore, I would be very eager to see the Government directing Care Inspectorate Wales, along with Social Care Wales and the other regulatory bodies, to think about having a standard set of language categories for all non-maintained settings too across the language spectrum, so that there is an element of progression and continuum starting from the cradle, to all intents and purposes, and so that we don't end up with a different set of categories for the non-maintained sector, whilst acknowledging, of course, that the challenge in that regard is that we are non-statutory. But, I do think that there is a desire across the spectrum, and among Cwlwm partners, for example, to adopt language categories within the childcare, early years and play sector too.

In terms of the categories, I think I would say that they are a step forward in the sense that the terminology has been simplified and that the labels are more easily understood, on the face of it. Behind that, I don't think that they are, or perhaps they're oversimplified and aren’t transparent enough in terms of exactly what will be provided.

In terms of the current three categories, I would say that there's one missing. I think, if we are going to place Welsh-medium schools in this context in the primarily Welsh language category, I would have a very real concern about that in terms of where it leaves Welsh-medium schools. Does it allow some slippage backwards? One would hope not, but it certainly opens the door to that.

But also, it doesn't do justice to what designated Welsh-medium schools are at the moment, which can provide almost 100 per cent of the education through the medium of Welsh, apart from teaching English as a subject. So, I think any slippage in that regard, by using the term 'primarily Welsh language' without any percentages put in place, could mean anything, as long as it is the primary language. I would have concerns about that and I would suggest that there is room for an additional category there.

I also think it's crucial that there should be a clear minimum in terms of the percentage of education provided through the medium of Welsh for every one of those categories. I welcome the fact that, in the primarily English language category, the 10 per cent relates to classroom education and not other elements of school life that can be provided through the medium of Welsh. But I would say that that is needed for all categories. Clearly, the hope is that, within all school level plans, there would be aims and ambitions to move higher in terms of those percentages.

So, as I said, I would welcome simple and understandable categories that do exactly what they say on the tin, particularly in terms of promoting that provision. But we do have to be entirely transparent in terms of what exactly we mean and be sufficiently ambitious in terms of our expectations within those particular categories.

Thank you. Just so the committee can be clear on this point, and to summarise what you've said about the primarily Welsh category, there is no minimum set out for that category, and the point that you made, Gwennan, at the very end there is that there is a risk—although it’s unlikely, perhaps, but there is a risk—that there could be some slippage in that regard. So, what specifically would you want the committee to do to strengthen that particular element of the categorisation in the Bill as it currently stands?

I would say that, in terms of the primarily Welsh category, there is a risk in terms of that slippage that you described. That is one risk. There is also a risk in terms of schools misrepresent what they are by saying that they are primarily Welsh. On a percentage basis, on paper, they may well be, but that could be very, very far from being a Welsh-medium school that is fully immersive and provides education wholly through the medium of Welsh, ensuring that all pupils leave as fluent Welsh speakers, proficient to discuss all the subjects that they’ve learnt through the medium of Welsh, having also had a strong Welsh ethos within school life.

So, I would say that there are a number of risks there in terms of planning, but also in terms of how a school defines itself and can place itself within that category. So, personally, I would say that there is scope to ask the question or at least to ensure that there is an additional category for Welsh-medium schools. I would say that that should be the ambition down the line, for all schools to get to that point. Clearly, that's going to happen over a very long period of time. But, without that ambition, then we will necessarily be taking retrograde steps—because we have those schools now—if we don't include that category. Maybe this is unintended in the sense that Welsh-medium education isn’t given due attention in the Bill because it already exists and has developed, but, if we don’t do that, then I would say that there would be risks and challenges that could emerge over time.

There is an additional category in the non-statutory guidance. So, what you're suggesting is that that should perhaps be adopted in the Bill.

Yes, I think there should certainly be a fourth category. Because Welsh isn't the primary language in a Welsh-medium school: Welsh is the language of teaching in those schools. And if there is teaching through the medium of English, then it's a very small percentage of that teaching, for English as a subject, or some schools continue to provide certain subjects or elements of assessment through the medium of English, for different reasons, but they are Welsh-medium schools in essence, and that secures that fluency across the subjects taught within the school, and all school life. It's not just the education in the classroom; the whole ethos of that school would have that Welsh-medium ethos.

Thank you.

You go first.

I do have concerns, because who decides that a school should be exempt, and for how long? I think that we need to consider how we transition schools that are, at present, unable to provide that minimum 10 per cent in the early implementation of the legislation. But I also think that we need to ensure that it wouldn't be possible for any school that's in that primarily English category to have a permanent exemption, and that, in having an exemption, that would have to be for the shortest possible time period, with a specific action plan put in place by the school and the local authority, and in collaboration with nearby schools, or in other ways, in order to ensure that we don't fail those children in the longer term who attend that school. Because, essentially, by providing an exemption to the school from providing that minimum 10 per cent Welsh language, it's the children who attend that school and are educated at that school who miss out on the opportunities to develop and nurture their Welsh-language skills as their peers would be doing who attend other schools.

Just to add to that, I think the question here is whether 10 per cent of learner time in school enables that learner to reach a level of proficiency at B1 and B2 by the time that they are 16. I would argue that it wouldn't; I would say that it's quite unlikely that that would be case. So, I agree entirely with that ambition of reaching levels B1 or B2, but I do question whether that minimum of 10 per cent is sufficient to do that.

I also agree with everything that Angharad said in that there shouldn't be categories of schools that exempt themselves permanently from this, and that there is a risk of that happening. And also, just to reflect on the fact that—. I am chief executive of Mudiad Meithrin, and have been for over a decade now, and I know about some schools, some primary schools, that have been on a continuum during that period and still haven't reached that status of providing education through the medium of Welsh, although that has been the ambition for a decade or more. So, that's problematic, in my view, in terms of the fact that we are allowing schools to be in a linguistic limbo for such long periods of time. So, I welcome the fact that a school can't move backwards in terms of category according to the Bill, but I am also slightly concerned, on the basis of experience, that we can't currently cope with schools that claim to be on a continuum, but never deliver that aspiration of becoming a Welsh-medium school.

To start, I would say that 10 per cent is a very low percentage in terms of a pupil’s experience within school, and I would say that that isn't ambitious enough, given our ultimate target and goal. So, that's the first point I would make in that regard.

In terms of these exemptions, I think the exemptions should be exemptions rather than options, and that's where one is concerned: in allowing schools to seek exemptions for a particular set of reasons, are we actually providing it as an option to them to be exempted? And that means that one would have to ensure that schools are held to account.

Clearly, the Government must ensure that local authorities are held to account in that regard too, but I would emphasise that our view would be that the exemptions shouldn't be the norm—it shouldn't be an option available to schools, but a process that can be put in place to recognise the existing position of the school, for whatever set of reasons, but with a robust plan in place then to ensure that there is a specific timetable to take them out of that exemption period, and certainly not to go into a second exemption, never mind going beyond that.

But I do think that we must be very guarded here that we don't publish legislation saying, ‘Well, it's fine, you could be exempt for three years, and a further three years after that’, because, given the number of schools that we have, and the practical ability to create plans for all of those schools, I think there is a very real risk that those exemptions will become more common than anyone would want, given the ambition.

I have to admit I've never given that any thought, because the annual data of the Mudiad that we gather from all cylch meithrin settings, and then interpret and share with local authorities and the Government, does demonstrate that very few children leave the cylchoedd meithrin non-maintained sector to go to private education, even in areas of Wales where there is no choice. If you take Gwynedd as an example, or Anglesey, the percentage of children who go from the cylch meithrin to receiving their statutory education in a private school is a very, very low percentage. So, I've never considered that issue.

I'm not sure either whether we should be planning our education and care systems on the basis of what parents may decide to do, because, for me, every child deserves the gift of becoming a Welsh speaker, and every family can cogitate on the fact that they have lost the language, including members of my own family. So, I think it is possible that what you describe is an unintended consequence of the legislation, but I think that we should be planning on the basis that the children of Wales deserve to become Welsh speakers, and speakers of multiple languages, if truth be told. So, I will give your question further thought and come back to you later, if I may, having had an opportunity to give it greater thought.

I think that there's a major responsibility here in terms of how we discuss and talk about Welsh language education, and that we don't create a bugbear of something that isn't one. Securing an opportunity for every child in Wales to develop a new skill—that's what we're doing here, something that they can adopt without having tried, if the circumstances around them allow them to do that. We're offering something additional. This whole idea of forcing something on a school or a community is dangerous ground. We know that from previous experience, and I think there's a responsibility on everyone across Government and beyond to be very careful in the way that we discuss Welsh language education and increasing the provision of Welsh language education at a local and national level. And what we're doing here, of course, is encouraging and securing support. That's where the emphasis should be: it's not enforcement for enforcement's sake, but introducing something that should be a right and an opportunity for every child and individual in our country. 

But, alongside that, by introducing legislation and robust plans, hopefully, to underpin that, what we're doing will, hopefully, secure favourable conditions for that to prosper in a supportive, encouraging environment. I think that's where one would welcome seeing that those exemptions should be a way of expressing that positive message of understanding that circumstances sometimes mean that the ambition is not deliverable and that there is work to be done within that school, in discussion with the governors and the local authority and so on. But that's a spirit of collaboration; the objective remains the same. 

So, I do think that, as I say, we need to—. In adopting legislation of this kind, what is key is that everyone takes ownership of it and speaks responsibly of Welsh language education as something that's valuable and that provides opportunities, rather than being a burden or something that's forced upon people. 

It's an interesting question, because the concept of language choice is so loaded and something that needs to be unpacked. And I think we're only beginning to understand the psychological behaviours and influencing in a positive way. I do accept that the glory of our movement is that we work with parents, bearing in mind, as I said earlier, that the vast majority—80 per cent—are parents who don't speak Welsh. So, they are making that choice and they are opting in, and I think it's important for us to work with those parents, as we do with programmes such as Cymraeg i Blant, and the cylchoedd Ti a Fi, and how the cylchoedd meithrin also work. 

I think often that parents don't always opt out of the Welsh-medium sector, but there's no cylch meithrin available to them conveniently, there's no Welsh-medium school available, there's no transport to take their children to Welsh-medium education conveniently. So, I think convenience trumps rights in that regard, because it's a minority of parents who will exercise their right to Welsh-medium education, but very many parents will take advantage of that provision if it's available conveniently. 

So, I fully understand the importance of inclusion and working with parents, bearing in mind that that's at the heart of our movement: it was parents who couldn't speak Welsh that provided that momentum to establish cylch meithrin provision and nursery provision through the medium of Welsh. Research by Arad does demonstrate that almost 20 per cent of parents can't access their choice of Welsh-medium care. And also, working in partnership with what we call the English sector, with Cwlwm, for example, is important, because every child, if they go to a cylch meithrin, or a nursery, or a playgroup, deserves to have that time to become a confident Welsh speaker. And that is why I see that there are merits to this Bill. Because we as an organisation don't own the Welsh language—it belongs to all children and all individuals in Wales. And therefore, we have to do more to support those people who want their children to become Welsh speakers. And that's what I see as the possible transformational element that is within this Bill.

If I could start on that one. I would say that, no, it doesn't go far enough. It sets out that there is a challenge here, and that there is work to be done, and, clearly, the whole principle of establishing the institute and the responsibility that would fall on the institute go part of the way in demonstrating the kinds of support structures that may be in place in terms of planning for the future, and also providing language training, and so on, for the future, but I would say that, beyond that, there isn't nearly enough recognition of the scale of the challenge in ensuring the scale of the workforce required to deliver the ambition in this context. And I think that we need a recognition of that, in terms of its magnitude, but also the costs attached to this.

So, I would say that there's a need for far more detailed attention given to this—while recognising that there are other programmes in place to develop the Welsh language workforce—but that we do need other plans to work alongside the introduction of the Bill that set out clearly how this whole agenda, and this whole ambition of developing Welsh-medium education, acknowledges that challenge and responds to the challenge by setting targets and setting out how the Government will deliver against those targets in terms of upskilling the current workforce, whilst, simultaneously, and more importantly, perhaps, creating the future workforce.

What we have to acknowledge with the current workforce is that there is potential there, yes, but you are talking here about teachers who are under incredible pressure already, and don't have gaps in their timetables, with all of the new initiatives being introduced in terms of the curriculum, qualifications, and so on. We have to recognise that there is a potential in that workforce, and we need to support them and secure programmes of support that are fit for purpose and work within those contexts, certainly, and you need a range of programmes for them, but we really have to do something about bringing more people into the profession who can teach through the medium of Welsh. We do have to create new teachers through initial teacher training programmes that ensure that everyone who qualifies to teach in Wales in the future would, hopefully, have the ability to teach through the medium of Welsh. So, I think it's two different challenges, which isn't given full recognition, in my view, within the Bill as it currently stands. 

I think we also need to consider the unintended consequences of investing the amount that will need to be invested in increasing the education workforce. The education workforce is linked to the early years workforce and the post-statutory education workforce too. There is a flow of professional staff between those sectors, and we need to ensure that increasing our ability to provide Welsh-medium education, or to teach through the medium of Welsh, in the statutory sector doesn't have a negative impact on the ability of the early years and post-statutory sector to continue with the work that is currently ongoing there.

I think that one of the things that needs consideration is that there are courses that have already been developed jointly with the National Centre for Learning Welsh, which are purpose-built for the early years workforce, under the Camau banner, and I think that there is scope to develop and expand that kind of provision, jointly with the canolfan and the athrofa, as it will be, to support those staff who are already in post and as a way of taking those first steps to developing the Welsh language skills of those who are newly qualified.

But we need to ensure that Welsh language skills and the requirements of the statutory sector are considered alongside the needs of the early years sector, and the needs of the FE colleges and HE colleges too, because one of the things that could arise as a result of this is that we lose staff in the sectors at both sides of the statutory sector, in order to fill the language skills gaps that arise within the statutory sector.

I welcome the fact that there will be far more target setting and reference provided by the Welsh Government. We are working within the WESPs regime at the moment, and there is momentum at times, but there is a great deal of bureaucracy, there is a sluggishness in terms of progress, there are schools that take years to be opened or to transfer into the Welsh-medium sector. But the fact that we do have the WESPs does improve the previous system, where we didn't have such a regime in place. But I do think that the principle that the Government should direct and set targets is far better than the current regime.

I think the contribution of the institute will be important in sharing expertise, as we've already heard, and our hope is that we as an organisation will continue to be part of the planning and discussion that happens within the WESPs in local authorities, and that the necessary investment in terms of capital and revenue will continue to be planned in a way that promotes Welsh-medium childcare and early years education, in the way that it has previously, because losing that opportunity would be a grave error, in my view.

I would say that the lines of accountability are quite clear within the Bill as it currently stands, in terms of the expectation on the school-level plan to be accountable to the local authority, and the local authority accountable to Government. Of course, this is all reliant on those plans themselves and everyone within the system being held to account in terms of implementation, but also in terms of the transparency in what's in the plans. So, I think the framework is clear, but it's about how that is implemented, and we have to ensure that the accountability is robust enough and that there is challenge where challenge is required.

It's an interesting question. I don't know. I think there's an element of splitting hairs as to whether we call it an action plan or a strategic plan. What's important is that there is momentum and that things do happen, and that the provision is planned, and that there are challenging targets and ambitious targets. So, I am less concerned about the exact terminology used. I'm more concerned about ensuring that the right people are around the table within that discussion space with the local authority so that decisions can be made in a proactive and constructive way. In our experience, local authorities need more direction from Government, and that’s why we welcome that element, because it also links to that national target of 1 million Welsh speakers by 2050.

I believe that school transport is crucially important. I think there needs to be more recognition of the importance of that issue to families across Wales. Affordable transport for families is hugely important to them. The children, to all intents and purposes, are attending education settings from three to 18 years of age, so there are 15 years of travel to education for all children, as well as the care that they receive before school age.

We need to ensure that that element of school transport is not only available for children in the statutory sector, between five and 16. As financial cuts begin to take effect in local authorities, we are seeing anecdotal evidence that local authorities are saying, 'Well, you can get the bus to the local sixth-form setting'—which perhaps doesn't have provision through the medium of Welsh—'but we're not willing to pay for that child to study the same subject through the medium of Welsh and to travel by bus to the local Welsh school, which is a little further away.'

I think the same is true in terms of the children in receipt of part-time education at three years of age. There is no school transport available for them. So, for those parents who perhaps don't live at a location that is easily accessible, and can't walk to that setting, they have to use the local provision rather than the one that they would choose in terms of the medium of language, for those reasons. There was a report by the culture committee, I believe, which talked about the need to carry out some sort of audit in this area. In light of the Bill, I think we really do need to look again at that recommendation, and to look at containing it within the Bill itself.

I would certainly argue that we need to ensure that access to Welsh-medium education should be available free of charge to the nearest school to any pupil, between three and 18 years of age. I think it's important that we include the meithrin but also the sixth form, and that isn't currently the case in all local authorities. So, I would make the case that transport is crucial. Parents have to make decisions on the basis of convenience and geographical factors that shouldn't be considered where the medium of one's education is concerned. So, certainly, giving more focus to transport with the intention of providing free access to education, and Welsh-medium education particularly, in all cases should be a priority.  

I don't quite understand the question, but I do think, to expand—

I’m not sure if that was our intention, if that’s what we have said in our evidence. I think it’s important to recognise the constructive relationship that exists between ourselves as an organisation and the National Centre for Learning Welsh, and the athrofa in due course. So, continuing with that intensive joint planning is very important, because we want to recognise the expertise in the athrofa, when it comes to lifelong learning, but also, to recognise that we work in a very constructive way on a number of plans, as Angharad has already mentioned—Cymraeg Gwaith, Camau, the innovative programme for parents, Clwb Cwtsh, for example. So, whatever the reality around the arrangements for the institute, what we’re saying is that the National Centre for Learning Welsh has actually established itself, has facilitated our way of working in terms of learning Welsh, and that we want to see recognition of the importance of that within the newly established institute.

I would also say that one of the things that’s noted is that the institute will have the ability to commission people to provide courses on the ground, and I think one of the things that needs to be considered in that regard is that the current centre for learning Welsh has very good working partnerships, which are innovative, with a number of partners who have developed various courses that are now being provided across Wales, rather than in pockets as was the case before the establishment of the centre itself some decade ago.

In terms of what happens over the next few years, we need to ensure that those partnerships and that co-operation does continue, and that whatever happens in establishing the institute shouldn’t undermine the constructive work that’s happened over that past decade, so that we have that consistency that we have at the moment in the area of Welsh for adults across Wales, and the kinds of courses that we can offer to our early years workforce across Wales, and also to any adult who wants to learn Welsh within that sector.

Sorry, could you repeat that? I'm sorry, I didn't hear.

Thank you very much. I'm Heini Gruffudd. I'm chair of Dyfodol i'r Iaith. We've responded in writing to the Bill, but prior to the drafting of the Bill, we did speak to some Senedd Members regarding its content. 

I'm Myfanwy Jones, director of Mentrau Iaith Cymru. We, too, have responded in writing during the consultation process, but that's all. 

Toni Schiavone, chair of Cymdeithas yr Iaith's education group. We have drawn up our own bill, and we have also done some research on the implications of any education Bill in terms of growth within local authorities, and have held meetings with Ministers and officials within the Welsh Government. 

Osian Rhys, member of the Cymdeithas yr Iaith education group. Toni has mentioned some of the things, but it might be worth adding that Cymdeithas yr Iaith, I think, was the first to call for a Welsh language education Act in 2015, so we have campaigned for such legislation for quite some time—perhaps not exactly the legislation we're looking at today, but I do think it's pertinent. 

If I could welcome the opportunity to appear before you. I very much appreciate the opportunity. I also appreciate the intention of the Bill, namely to promote and facilitate the use of the Welsh language and to increase use of the Welsh language. And I do think that we need to bear in mind that the true intention of the Bill is to create confident Welsh speakers, particularly where pupils have to achieve that where they don't have an opportunity to speak the language at home. In terms of the Bill itself and reaching 1 million Welsh speakers, there is a problem in terms of which figures we're going to use as a baseline. Is it the 10-year census, or is it figures from other surveys? I would suggest that, rather than talking about 1 million, we take any baseline that we have today and double that by 2050. I think that was the original intention, to double the numbers in the census in 2021. But if you take another baseline figure, we should still double that. 

In terms of the Bill and any unintended consequences, I do have some fear that the definition of Welsh language education in the Bill is going to mislead parents in terms of what's possible for their children—it changes the definition of Welsh language education from what has existed within the Government for 20 years. And I would like to ask perhaps why, and who has made that change and what is the purpose of saying that teaching Welsh as a subject is the same as Welsh language education. Every document that the Government has to date has dealt with Welsh language education as education delivered through the medium of Welsh or Welsh language schools, and that's where the slippage could happen in relation to this Bill. If parents believe that they are getting a Welsh language education in English language schools and expect their children to be confident Welsh speakers when they leave, that won't happen any more than it happens today, I fear.

In terms Mentrau Iaith Cymru, we do welcome the Bill, certainly. We're very pleased to see the 'Cymraeg 2050' targets placed on a statutory basis, and we welcome the clear lines of accountability from the national frameworks through the WESPs to the school plans. With some amendments, we are hopeful that it could increase the number of Welsh speakers, but we are slightly concerned that it won't move us towards increasing the use of the Welsh language, so, it won't lead to people who will use the Welsh language, just people who are able to speak it. A very negative unintended consequence would be reaching a situation such as in Ireland, where many people would say that they were Welsh speakers, but they didn't use the language on a practical, daily basis. So, I would like to see the Bill being a little more ambitious in terms of language use within education and outside the school gates. I think the Bill could be strengthened in that regard, without doubt.

In terms of Cymdeithas yr Iaith Gymraeg, we welcome the Bill and we appreciate the fact that officials have worked hard to bring this Bill forward. We appreciate that work very much. However, we don't believe that the Bill will be transformational unless there are significant changes made to it.

Our starting point is that 80 per cent of young people in Wales are deprived of the Welsh language, and that indicates our failure in Wales to change the system as it currently exists. In our view, the only education that will ensure progress is Welsh-medium education, and the aim, therefore, is that every school should be a Welsh-medium school by 2050. It is those schools that ensure that all children leave school as fluent Welsh speakers as well as English speakers.

To achieve that ambition, we suggest that there should be a statutory target of every school being a Welsh-medium school, and that we create a continuum by scrapping the idea of schools being frozen into categories: a starting point of the school today and where it will be in five, 10, 15 years, moving along that continuum to become Welsh-medium schools.

Thirdly, we must ensure that a learning and assessment continuum is in place. It's very sad that, although the recommendations made in 2013 said that second-language Welsh should be scrapped, young people today, who follow the second-language curriculum, don't even achieve the lowest level in terms of first-language Welsh speakers. So, we need to establish a learning and assessment continuum with one qualification. We argue that every school should reach a minimum of 30 per cent of its education through the medium of Welsh within five years and that we would need an investment of £20 million per annum in the workforce to ensure that they are able to deliver that ambition.

To add to Toni's comments, I think one major concern we have is that so much in the Bill depends on regulation. A great deal depends on decisions taken by Ministers and civil servants in the future and there is very little in the Bill that will ensure that anything truly changes as compared to the current system. We're calling for statutory targets on the face of the Bill. A statutory basis in the Bill to create targets in regulations is very different.

Our aim, as Toni said, is for 100 per cent of schools to teach through the medium of Welsh by 2050. The Bill doesn't set any targets; there is no percentage in that regard. We think that 100 per cent should be the target, but the Bill is entirely vague and ambiguous. There are no targets in terms of increasing how much Welsh-medium education is to be provided, how much Welsh-medium provision is to be provided in schools that teach through the medium of English at the moment. So, whatever the intention of Government, I think that needs to be clear on the face of the Bill, rather than the situation that we currently have, whereby there is a feeling that we're hoping for the best, and perhaps the Bill might be okay and we can put faith in everything working out okay. But, for us, we start with the children; as Toni said, 80 per cent of children in Wales leave school without being able to speak Welsh.

Government reports, the Sioned Davies report in 2013, have made it entirely clear that teaching Welsh as a subject doesn't create confident Welsh speakers. That's why we are calling for an increase in Welsh-medium provision in English schools, turning schools into bilingual schools first of all, and then into Welsh-medium schools over a period of time, so that the generation of our children and grandchildren do learn Welsh. There's nothing we can do about the children leaving school now. And for the next years, even the next decades, the majority of children will leave school without being able to speak Welsh, and our feeling is that there's nothing in the Bill that's going to change that.

I think I mentioned the possibility of setting a target of doubling the numbers in terms of the baseline that we're at today, or the census that was taken in 2021, or we could be in a situation of thinking that we've reached a million very easily without having taken real meaningful steps on the ground.

But I would think too that it is important or would be important not only to count the numbers—. According to the census, there are 0.5 million speaking the language, but, in terms of those using the language every day, the number is far less; some 200,000 regularly use the language, perhaps, and I do think that we need to measure how many people in Wales use the language in their daily lives, either on a weekly basis or a daily basis, and that we need a combination of statistics there in terms of the numbers using the language, and the numbers who actually identify as speakers. And I think that is crucial if we want to create the bilingual society that we're seeking.

There is one thing that's worth mentioning here, namely, in the Basque Country, there's been a huge increase in Basque schools, but there's also an expectation from the Basque Government that every official within Government, every teacher in the country, should reach level C1. Now, that's another way of measuring: do we want to measure not only the number of speakers, but also at what level they are?

Now, if I could just move on, we could argue about how relevant that is to many schools, primary schools and so on, but I would like to think that we could somehow measure how confident pupils are according to their age and their ability, and that gives you some sort of continuum from the primary sector up to the end of secondary.

Could I could echo Heini’s comments there? The mentrau iaith do see great value in the census in terms of providing us with an opportunity to cross-reference the number of Welsh speakers with other characteristics, and then enables us to plan on that basis. But I would like to agree entirely that we need a means of measuring language use, a consistent, comprehensive measure. There has been a language use survey run between the commissioner and the Government on a five-yearly basis, but it hasn't been consistent enough or comprehensive enough, and it does need to measure at a national level and a ward level, like the census, so that we can see the reality of the situation on the ground in terms of language use, rather than just the numbers. 

If I could return to the experiences of children, I would say that the most important measure is children's attainment at the end of education. For example, if you look at the most recent statistics, 22.5 per cent of Welsh primary school children are fluent in Welsh following Welsh-medium education. But, by the end of key stage 4, that falls to 13.5 per cent. If you look at the post-16 sector, it falls again, to less than 5 per cent. So, having an increase of 10 per cent, using those figures in terms of measuring progress, is crucial, but that in and of itself shows the deficiencies of the current system. Those statistics have come from you, from information gathered by the Welsh Government.

So that's our starting point always: what is the experience of children? To what extent does the education system at the moment provide for them, and to what extent are they being deprived of the ability to be fluent in Welsh, including, by the way, the education Minister, who's had second language education, who studied GCSE and A-level, but hasn't developed the confidence to become a speaker and user of the Welsh language. Again, in 2013, this failure was set out, and one continuum of learning and assessment was requested, but I'm afraid we've failed to deliver that, and there is a responsibility on us and you to ensure that the next generation of young people don't have those same experiences.

I think, essentially—. It was Cymdeithas yr Iaith that called for the million in the first instance, and parties placed it in their manifestos, including the Labour Party, and so it's become part of Government policy—that's a million Welsh speakers. What we're seeing in this Bill, I would argue, is an effort by the civil service to make that happen without doing what's necessary in order to double the numbers of Welsh speakers in reality. Now, we didn't call for a million speakers just so that somebody could find a way of ticking that box. The purpose of that, essentially, was to show that we need a step change in public policy in relation to the Welsh language; we need to do far more. But, rather than doing that, what we have now is putting it on the face of the Bill, but allowing Ministers to then decide how that million will be counted, rather than following the figures of the census, which I think everyone would accept was what the million meant initially, because that target was set in the context of the census.

For us, the million isn't relevant to education in Wales. We don't want to provide Welsh language education to children to deliver this target. We want children to acquire the Welsh language in their own right, because children have the right to acquire the Welsh language; whatever their background, wherever in Wales they live, whenever they came to Wales to live, everyone should have that right to the Welsh language. We know that the second language system isn't working. The only way, therefore, of addressing this issue is by increasing Welsh-medium provision in all educational settings, and it has nothing to do with the million. It's about the right of all children to acquire the Welsh language, and linking it to the million in the way that this Bill does, in our view as Cymdeithas yr Iaith, isn't useful in any sense whatsoever.

Thank you very much to you all for your evidence, to begin with. It's been useful work, and it will be when we draw up our report and recommendations in due course. I'm just, in this part of questioning, going to focus on the CEFR framework. It's interesting, if I could turn to Dyfodol yr Iaith, who've expressed doubts about how that framework can be used in the statutory provision or regime in education. A question for Cymdeithas yr Iaith as a result of Osian and Toni's comments with regard to getting rid of teaching Welsh as a second language, which has been an aspiration for a number of years that has failed: do you see this framework as a way of getting rid of first language and second language and that we can measure language skills along a continuum, accepting the point you make that improving those language skills depends on more education through the medium of Welsh rather than teaching Welsh as a subject? Myfanwy is welcome to give us comments on CEFR, as well. So, shall we start, perhaps, with the doubts, perhaps, that you've noted?

Well, the CEFR system is widely used across Europe, mainly in the context of adults learning a language as a second language, and, to that end, it works very effectively, and we in Wales need to adopt it. One part of it, as I mentioned earlier with the Basque country, is that every Government official, every teacher and so on, every professional official is expected to have reached level C1.

Now, I don't think that this is particularly relevant to children's education. You will have children in rural areas speaking Welsh entirely confidently and perhaps they wouldn't get close to C1. We have to measure children's language ability according to their age and according to their inherent ability, and I do think that we need a different system of measuring attainment and ability in terms of schoolchildren, particularly in the primary sector. You can argue in the secondary sector, that all's well and we should aim towards that, but that places all of the English-medium schools in Wales in great difficulty, because they could never achieve the levels that are possible for those attending Welsh-medium schools. Is a continuum the solution? Perhaps it is. But, essentially, we have to think of a system that's realistic and that is appropriate for children and schools so that every child and every pupil in a school is confident in terms of using what language they have. In terms of English-medium schools, it would be far more useful to place an emphasis on spoken Welsh, rather than on the professional levels that would be required to reach C1 standard, and they could achieve that later, perhaps. But we have to aim towards the kind of language that pupils could use realistically in their daily life. I maybe reached C1 in French 50 years ago, but I had no confidence in using the language. We need levels that are appropriate for pupils and fit for purpose in daily life, and that, in the English-medium sector, mainly has to focus on spoken Welsh; in the Welsh-medium sector, you have far more freedom. So, I would be a little suspicious of accepting CEFR as a framework, or the only framework, that is mentioned in the Bill.

Thank you.

In terms of CEFR itself, I think it offers a solution from the point of identifying language levels in a meaningful way, but I would also add that there is a need to adapt it, clearly, to the situation of the Welsh language, and that element of measuring confidence and willingness to use the language is important within the framework. That is, I have seen situations where people are in a workplace that uses a framework measure, although not CEFR, and they reach level 3—in theory, they reach level 3 in terms of ability—but have no intention whatsoever of using the language that they've acquired at that level. Therefore, I think there's an element of measuring, not willingness in terms of anything emotional, but confidence in terms of using the Welsh language within the framework, if it's possible to build that in. And for it to be one continuum, it would have to be mapped against whatever the assessment methods are in schools. I don't suggest that I know how that could be done, but, clearly, it would need to map to correspond with the way that schools assess language currently, language attainment along the range from English language to Welsh language education.

Okay. Thank you very much.

I'm going to quote one of the questions. CEFR has been planned specifically for the acquisition of foreign languages and second languages. How appropriate is it to apply this to the Welsh language? Well, it's not. It isn't appropriate. It's a diversion. Back in 2013, the report on second language suggested that there should be a literacy framework for the Welsh language, which we already have. In our schools, we have descriptions of attainment levels in Welsh at the end of key stage 1, key stage 2, key stage 3 and key stage 4. So, why don't we use that? We have our own Welsh approaches in measuring progress, which have existed and are well understood. Every parent in every school gets a report on the attainment of their children through these descriptions of levels. So, why are we moving towards a framework that, with all respect, is foreign? It's a diversion.

I would echo that. If somebody who's in an English-medium school at the moment says they can't speak Welsh, under this framework, they'd be able to say they're on level A1. Are they better off because of that? I don't think they are. It feels as though, with this Bill, rather than addressing the essence of the problem, namely that the education system is failing our children, we're diverting the focus, or just playing around with things that, in reality, aren't going to make much of a difference. It feels as if the Bill is trying to do many things, and everything but providing assurance that Welsh-medium education over time is going to be something that every child receives in Wales.

What's important is that parents have grown accustomed to the curriculum and to the descriptions of attainment. So, why don't we use that system for measuring progress in the Welsh language, whilst simultaneously scrapping this idea that there is one level of attainment for second language, and another for first language? At the moment, with second-language children and young people, you are building a bridge that stops halfway across the river. That's irresponsible, and something has to be done about that.

Do you think this framework provides a way of differentiating between the first language and second language path, because everybody would be measured on the same framework?

People should be measured on the same framework.

But not CEFR, in your view. 

CEFR is designed for learning modern foreign languages and second languages. Why are we looking for something else when we have the experience in Wales of developing our own ways of measuring attainment? We have the ability in Wales to create our own framework, using and building upon what we already have. We have the literacy framework, and the descriptions of attainment level is the other.

I'd like to add one point, please: it's fine, whatever method we use to measure, but the measuring method needs to be done correctly. Currently, in schools in Wales, Welsh is the only subject where you can fall in your ability and skills in moving from the primary sector to the secondary sector. About 20 per cent or 25 per cent of pupils in Wales who've been in  first language schools transfer to second language in the secondary sector, especially in Gwynedd and some counties in the west. So, there needs to be something in the Bill that makes it necessary, whatever your level is in terms of language, that you progress through the system, not fall back, as is happening today.

Thank you for your question. From our perspective, we want this Bill to be comprehensive and to include everybody, and I don't think that discussing exemptions is of assistance in that regard at all. I would be very concerned about any suggestion of doing that. We want to get every school and every child to feel that they are part of the same system of ensuring that the Welsh language becomes part of their lives. Some will be able to acquire it very quickly; others will take time to do so. But it is dangerous to provide exemptions, in our view, and it's contrary to our principles of incorporating and including everyone in Wales, whatever their linguistic background, whatever the situation is at home. I come from a mixed-language family; others come from households that are first language Welsh, or English first language. We need to get rid of those ideas and ensure that everyone is on the same continuum towards fluency in Welsh.

If I could add to that, I think as part of the question as well, Tom, you mentioned the minimum 10 per cent of Welsh language education. I watched the evidence of the Minister last week, and the official with the Minister confirmed that that 10 per cent represented the status quo, namely what we know already, and that confirmation raises even more questions, because if this Bill provides that children who are in English-medium schools are going to have 10 per cent, which is exactly what they have now, how on earth is that going to mean any progress at all? Why on earth would you give an exemption to schools not to provide something they’re supposed to be providing already? We also had confirmation from the lawyer present that it didn't even mean 10 per cent for every child, which is enough to confuse anybody.

Essentially, we know that that 10 per cent does not create confident speakers. The Bill seems to pretend that it's going to. So, as well as the exemption, that 10 per cent just in itself does not move anything forward. I think in our written evidence we've spoken about a target of 30 per cent for every school in Wales, so that about a day and a half, perhaps, of the provision of every school is through the medium of Welsh. If you're aiming at something like that, which is an improvement on the current situation, I think it is fair to give schools some time to do so, and I think we suggest five years in our paper.

The only thing I also wanted to say about the exemption is that it looks to us as if it's possible—taking that that 10 per cent is going to increase over time to something higher than that, which is a possibility in the Bill—that a school could apply for an exemption from the 10 per cent, which is six years, then if they increase to 15 per cent they could have a further exemption, and in the end those children would lose out for generations to come. So I think that is something the committee could look at and ask the Minister if this exemption can happen every time that that increase happens.

I wouldn't disagree with the concept of providing exemptions in order to make the Bill operationally possible, but I would suggest that the exemption should be at 10 per cent. I don't see, as Osian mentioned, it would be possible for someone to exempt themselves from a situation that they should be in at present. Ten per cent is the minimum currently, and that's not working in creating Welsh speakers, so it would be possible to provide exemptions in very exceptional circumstances not to increase from that level immediately, but to do so more slowly. But I can't see any benefit at all in providing an exemption for people from having to provide that minimum 10 per cent. We know that 10 per cent in and of itself doesn't get them to that lowest benchmark in terms of using the Welsh language, and that's ultimately what we're looking for. So, I would recommend that we increase that benchmark from 10 per cent or that we place the 10 per cent as the exemption.

The Welsh language has been a statutory language in Wales since 1988. How is it that some schools are talking about that 10 per cent—where's the progress? We should be talking about increasing that baseline and including everybody, every school, in that process.

I've listened to some of the discussions in the committee, and I understand that some schools on the border that don't have suitable teachers or teachers who can speak Welsh would be in trouble, unless there's an exemption, even with goodwill. I would wish to see therefore in the Bill that there is a specific reference to increasing the number of staff who can teach Welsh or through the medium of Welsh.

In ‘Cymraeg 2050’, the Government recommended that there was a need for 5,400 additional teachers for the Welsh-medium sector, and also 700 additional Welsh teachers by 2050. I'm not sure how many of those teachers have been appointed, how many we have, how much of an increase there's been, but now is the time, I think, to get into the Bill specific targets regarding the number of necessary staff in the Welsh-medium sector and the English-medium sector. That could include new staff, it could also include language training for staff, but this has to be at the core of the Bill if the Bill is to reach the other targets. And in doing so, perhaps there would be no need for an exemption in the future, but at the moment I would imagine that some schools find it very difficult.  

We do need national targets, most certainly, but as with the rest of the Welsh language education system, there are national targets and then the Government provides targets for the individual counties to deliver, and then the local authorities in their WESPs do develop specific targets. So, I assume that the Government needs to provide guidance and to tell every local authority what their target should be, and then they adapt those targets accordingly for the schools that they have. But you need that central support at a national level in terms of funding teacher training courses for that system. 

There is another point on students that I'd like to come to later, if that's okay. 

That's an important point. The targets need to differentiate according to the current situation of the authorities, and that's why we've drawn up a document like this that states the situation in every authority. There's a need to adapt the target according to each authority's starting point.

But just to be positive, let's remind ourselves that 31.4 per cent of our workforce are already fluent in Welsh; 7.7 per cent of the workforce are nearly fluent in Welsh. So, we're talking about 40 per cent of our workforce already being able to present, partially or fully, through the medium of Welsh. Under that, a possible 25 per cent of teachers have some grasp of Welsh, but they haven't had the opportunity to develop the language in the workplace and in their lifelong learning. Nearly everyone in the education system has had some amount of Welsh language education in their own education. 

So, we can build on a much stronger basis than is being suggested. And as I said to the education Minister yesterday, there's the same problem in terms of workforce among science and mathematics teachers. It's not an excuse for not introducing those subjects. Our job is to ensure that the teachers are in post and that those coming into this work are developing their language skills while they're in the workplace, in the schools, as well as before they get there. 

It comes back to the lack of educational targets in the Bill, because if there was a target for Welsh language education by some date, you could place a duty on Welsh Ministers to ensure that that training is provided in order to deliver the objectives of the Bill. I think the Government have said that they have been trying, but I think the efforts being made at present by Government in terms of providing Welsh language skills in the workforce are pitiful, if I'm honest, even for the current demand, never mind if there is to be progress in this area, so whether it's in the Bill or somewhere else, then certainly the Government needs to look again at its plans in terms of training a workforce that can teach through the medium of Welsh, and even the most conservative voices that you've heard from have suggested that the current situation is inadequate in that regard, I think.

The workforce should include the assistants. There are 26,000 teachers in our schools, but there are 31,000 assistants working in the education system. Many of those fall outside the usual arrangements in terms of training at a national level and at a local authority level. So, any plan regarding the development of the workforce needs to include everybody. And, out of those 31,000 assistants, there are probably thousands that, with the right support, encouragement and guidance, could teach through the medium of Welsh, but there is a need for a plan and a strategy for the workforce as a whole. It's an important question.

If I could start. Yes, we welcome the clear line for planning and we welcome that there are targets set and that there is a national framework that works its way down to the counties, and this new idea of giving the plans to schools. The only thing—. Well, there are a number of things that concern me, but the main thing that I'm not sure about is who's going to be responsible for measuring whether schools are succeeding in reaching the language attainment within their category—I don't fully understand, from the Bill. Language attainment by pupils is clearly set out for each category, but I can't see who's going to be responsible for ensuring that that's achieved. And neither do I see enough emphasis on ensuring that schools, in their school plans, are planning for progress; that is, rather than just remaining within their category, that they are planning to move from one category to the next. That would have to be clearer, I think, for it to work properly.

And the other element in terms of the three levels of planning that I'm not quite sure about is that there is reference to the school plans in terms of creating a Welsh ethos and increasing the use of the Welsh language among pupils, and that is less clear in the WESPs, and even less clear in the national framework. And we know about the importance of creating opportunities and providing opportunities for people to use the Welsh language, not just to learn it in the classroom, and I think that that is missing in terms of creating Welsh language users. There's not enough emphasis on that element of what happens outside the classroom in terms of creating a Welsh ethos, an awareness of the language, and generating usage.

For us, I think the accountability that causes us the greatest concern is the accountability of the Government. Because so much of the Bill transfers everything over to the regulations, essentially, that means that Ministers could set a target and then if they feel, 'Oh, perhaps that was too ambitious', they could adapt the target. If there were statutory targets for Welsh language education in the Bill, I think we'd be less concerned about that accountability. Perhaps we're repeating ourselves in talking about this lack of targets, but, essentially, the only way of getting proper accountability is if there's something in the Bill that there's no way for Ministers and civil servants to adapt, and at the moment, we're not seeing that.

If I could follow up on that: if you think of the system at a national level, this Bill places a responsibility on the Welsh Government to establish the strategy. It's then up to local authorities to draw up the implementation plans to implement that strategy on the ground. It’s then up to schools, through their own school plans, to show how the objectives and the strategy at the local authority level are being implemented within that school. Now, those tiers are very useful, but the question is: who is best placed to ensure that those plans are operational to the extent that they're having a real impact? Well, it’s clear, from the perspective of the local authorities, that you need a body above the local authorities to look in detail at those plans. The Welsh Government—Welsh Government officials—have been doing that, but I question whether they have the capacity, and, with all due respect, the ability, to do that in an effective way. And may I suggest that the decade of Welsh in education strategic plans, which haven't provided us with the expected growth, suggests that the capacity isn’t there? So, we suggest that, as an integral part of the work of Estyn, they should be responsible for reviewing and inspecting the strategic plans and the implementation plans at the local authority level.

In terms of the schools themselves, it’s the responsibility of local authorities, as a starting point, to look at those plans, and to see to what extent those plans are delivering the objectives of, and responding to, the local authority's implementation plans. So, one can identify a line of accountability, but it has to be clearly set out in the Bill. At the moment, it’s a little too ambiguous, and I think that having something objective—a body such as Estyn—looking at it, certainly at a local authority level, and noting this as one of their responsibilities, not happening by accident—. They have the right to do that now, but it’s not happening at the moment. We say it should be happening regularly as an integral part of their work.