National Assembly for Wales

Can I just declare my normal interest, that I chair the Public and Commercial Services Union group in the Senedd?

Diolch yn fawr. Great, okay, so that's that.

We've got some papers to note. I'll ask if we can note them, unless somebody has anything—. I think there are some things that will come up later on in public and in private, so we'll cover those off.

So, we move on to item No. 3, and this morning we've got the Public Services Ombudsman for Wales, and it's a scrutiny session on the annual report and accounts. As you're aware, this session's being broadcast live on Senedd.tv, so hello to everybody at home, but there will be a transcript available for you after this session. But would you be able to introduce yourselves and your roles for the record, please?

Bore da. Good morning. Michelle Morris. I'm the public services ombudsman.

Diolch yn fawr. Chris.

Bore da. Good morning. I'm Chris Vinestock. I'm the chief operating officer and the director of improvement.

Diolch yn fawr.

Bore da. I'm Katrin Shaw, chief legal adviser and director of investigations.

A warm welcome to you. So, we've got quite a bit of ground to cover, and we're going to be looking first at your report, and then we'll be looking at your budget as well. I'd like to start by looking at some of your key performance indicators, and you've said that you met or exceeded your target in three of the eight KPIs relating to complaints. In terms of deciding whether to investigate and starting an investigation into public service complaints, you have a target of 80 per cent within six weeks, but delivered only 37 per cent, and that's down from 69 per cent a year earlier. It's a similar situation for your indicator relating to cases closed within 12 months. Can you explain these targets and why they've been missed? But maybe if you want to set the scene first and then go into that question, you're more than welcome to.

Okay, thank you very much. So, just to set the scene first, and I think you made reference to it there, overall performance last year across the office was strong and we continued to see an increase in case load, and I think that's very important in terms of setting the context for what we're going to answer your question on.

We did see a small number of KPIs that weren't achieved, and, really, we experienced some big case loads—that didn't help us. When I spoke to committee last year, I did highlight the risk that we faced at that time. We'd seen year-on-year increasing case loads, and we anticipated that that would continue, and we knew that, if we weren't able to increase our staff resources, there was a risk that that would impact on service levels. And I suppose, in reality, that's what we have seen happen, and that is some of the reason that we're seeing that poor performance on those indicators that you've just referenced.

So, the overall picture last year was that we experienced a 3 per cent uplift in cases and a 2 per cent uplift in complaints, so that's in addition to uplifts in case load we've seen in previous years. And the difference between a case and a complaint is: a case is someone contacting us and saying, 'I want you to look at this.' A complaint is when we say, 'Actually, that's properly, duly made. It's in jurisdiction', and we then take it forward. But every contact we have requires work and requires resource to deal with it.

So, last year, we dealt with and closed over 3,000 complaints, and that's more than we've dealt with and closed in any other year, so, in terms of productivity, in terms of what we've dealt with, we have increased our activity. Ninety per cent of those complaints were closed at the assessment to initial investigation stage, and I think that's important as well, and that's in line with our KPI targets. And 75 per cent of those complaints were resolved early, through early resolution, and that is something we try to do for more simple, more straightforward complaints. It's better for the complainant and the public bodies that we can do that early. However, there was a smaller number of complaints, around 200, where they were more complex complaints—we do need to take those to a detailed investigation. And that is where we've had challenges in terms of hitting our targets, and, unfortunately, the majority of those investigations last year did go over the 12-month period, which is not what we would want and it's not the level of service that we are seeking to offer, but that is where we've seen the challenge and the pressure coming through on that case load. 

In terms of the current year—I know we're looking back at last year, but I think it's just important to say that we're continuing to see an increase in the current year again, on top of those increases we had last year. And so, for the first two quarters of this year, there's no indication that the pressure on workload and case load is reducing—that seems to be increasing.

So, really, it's about an increasing case load, our resources not increasing, and having a real challenge around that 8 per cent of our complaints that we take to a detailed investigation, and that's where pressure is shown in terms of our performance over the last year. And, obviously, it's not where we want to be or where we should be and we're doing a lot of work to try and improve on that situation. And if I may, Chair, perhaps I could hand over to Katrin to talk a bit about some of those things that we're doing to deal with that pressure and to turn our performance around.

Yes, it'll be interesting to understand how the decisions you're making, so going for early intervention or closing things down early—what effect is that having on the individuals concerned and the public bodies? And maybe a comment around whether or not you're a victim of your own success in the fact that you're getting more complaints, so, therefore, it means that people know you're there and are actually raising things with you—so, maybe some commentary around that.

Thank you, Chair. Yes, our approach has been to take a proportionate approach to our casework. As you say, the majority of the cases are dealt with at an early stage. It's always in everybody's interest to resolve matters as early as possible rather than go through a very lengthy investigation, particularly bearing in mind that we are at the end of the complaints process and often people have been going through that complaints journey for a while before approaching us.

This proportionate approach really means that we are focusing our resources on the most significant complaints, so where we can achieve more than has been achieved through local resolution and through local investigation, and where, when we look at and assess the complaints, there appear to have been systemic failings. That's where our investigations are focusing—the detailed investigation work—and also where we see that other potential service users are affected, possibly by any failings that we see.

So, when we introduced this, we updated our guidance for staff, also prepared a fact sheet for complainants so that they understand where our threshold is for what we can assist with—as you say, the complaints are up and this year is no different so far this year—and to be more efficient and ensure consistency. Two members of our staff have been undertaking our investigation start decisions, where we really drill down and look at where we can add value here in terms of our investigations. That's also had the benefit of, rather than those cases going through to our investigation teams, giving them time to reduce their very heavy case loads that they've been holding, to give them that balance so that they're able to progress cases, on all cases, rather than being bogged down with very heavy case loads. And it means that, whenever we start investigations in terms of the detailed work we do—which is where our KPIs have been missed last year—each head of complaint is assessed thoroughly and we take forward the ones where they do need to have a proportionality test. And by moving those decisions, we freed up our investigators and the investigation time of the investigation team to give them more time to deal with those matters.

Other steps we've introduced to try and reduce their case holdings: we've engaged bank caseworkers to assist on casework tasks. Rather than them owning cases, they're assisting our investigators. So, for example, where we have had some vacancies, we've obviously filled them as quickly as we possibly could, and we have filled posts with good-calibre candidates. But where there is that period where a post is unfilled, we've been backfilling that with our bank caseworkers. And that has been quite effective and something we will take forward if we do have that situation arising again. 

Sorry to disturb you, I think—. Peter, did you want to come in on something just along there?

I was just conscious of the increased workload, and I can only imagine—. I'm sure you're getting an increased amount around health. And of course, each one is important and an individual, but do you find you're duplicating your work many times because of the similar nature of complaints? And how do you then reconcile that with somebody—where you know what the answer is before you start. You're having to go over the same ground all the time, and that's resource intensive, I'm sure.

It is, and we always try and settle a complaint if we can. If we see from looking at the complaint in the first instance that a matter can be resolved, that's our first priority: let's deliver the outcome the complainant needs and wants. But, Michelle and the office, we issued a thematic report, where we tried, particularly in health—'Groundhog Day 2: An opportunity for cultural change in complaint handling?'—we really try to take the learning from those repeated failures that we see, where there isn't robust local investigation, where there's a lack of objectivity. We issued that thematic report with that aim to, as well as deliver to complainants who really need our help when they approach us, try and improve that learning on a greater scale across Wales. 

In those instances where you've got similar—I think there's a case coming through now and we'll be publishing a report later this autumn. We can group complaints and cases together with the same lead investigator, because you get some slight economies of scale, I guess, because of dealing with the similar issues, the same public body. So, if we see themes like that, our managers are very good at picking them up and making sure it's not done in a fragmented way. And our own-initiative work, which I'm sure we'll go on to talk about, helps us to do some of that as well. 

Rhianon. 

A very, very simple quick question: in terms of thematic reports—and you've touched upon interest reports, your own—where do they actually go to in terms of changing public policy? Obviously, we have a role here, but in terms of getting that fed back in terms of Welsh Government, in terms of what could be very big themes, what happens?

So, we would issue—that thematic report, which was the first one I've done, was issued to and made available to all Members of the Senedd. But, in particular, I met with the Minister for health to talk about that and to talk about not only, actually, that report but what we've been seeing over the last year through our case load in respect of health, because as you said, it's a very big part of our work. And I was very pleased to have the opportunity to meet with her, and we've agreed that we'll meet on a regular basis just to talk about the themes that we're seeing and the things that are coming out. And the thematic report, obviously, was a major focus on complaint handling. So, we try and do that and make sure that the relevant Chairs of committees are sighted on it, and if they want to, we talk about it further. So, we do try to get it in front of the right people, and that's part of the reason for doing the thematic reports.

So, as part of this—you say you've launched the new service quality process; is that what you're explaining here, or is that something different as well?

That's something slightly different. 

Slightly different. Okay.

But we can talk about that as well if you want. 

I know we cut across you, Katrin, there; was there anything else that you wanted to add before we move on?

I think the last main point and a key strand of work that we've taken, really, to deal with the high case load, is really to have really clear communication with our complainants and also with our main advocacy body, Llais. It's really important that everybody understands what we can help with, and we've been doing a lot of work on that front to support, to allow our advocacy bodies who approach us to use our service to best effect and to make our process as efficient as we possibly can. I think we've also listened to staff in terms of what would help them in terms of our case management system. We're making improvements there so that they have absolute visibility on the priority of their cases and to assist them in updating complainants.

We recognise that things are taking longer than we want them to, and we want to improve that, so there are a number of strands of work that we're pushing forward to improve the position.

Thank you. Before we move on to the new service standards—you touched on it there—how are your staff feeling at the moment? A big part of your budget and a big part of your organisation is your staff. Can you talk us through what conversations you've been having, or any staff surveys? I believe your staff surveys happen every two years, so you're probably in between at the moment, but what's the feedback they're giving you? How are you engaging with your staff to make sure that—? They're under pressure because you're talking about larger numbers. What are you doing to manage that?

You're absolutely right. Our staff are feeling the pressure of those increased case loads and seeing some of those key performance indicators going in the wrong direction. We do do a staff survey every two years, so we'll have the results of that survey. The next one will be early next spring. But we do do staff engagement in between. Earlier in the summer, we did staff engagement events, to talk to staff, really, about how they were feeling about those pressures, how that was manifesting itself for them, and what we could do collectively to try and ease some of that. So, those were good engagement events, but they did highlight to us and to me that satisfaction levels with us as a place to work, satisfaction levels with having reasonable case loads, have continued to decrease. That's the feedback we were getting from staff, and that's probably not surprising when you look at the figures that we're looking at. So, I think the things they cited as being of greatest concern for them were the continued workload pressures, limited additional resources to help them do that, although the bank workers has been one of the initiatives that has helped somewhat in that respect. But there was also an issue about staff needing to feel perhaps a bit more connected with their teams and with the organisation, as we now operate in a very flexible working way.

Those were the three key themes that came back from staff and we talked to them about, and we've spent some time as a management team since then thinking about how we can respond to that, how we can support staff, through making sure our flexible working arrangements support that connection and that better connection that they went; how we can support staff well-being and take any further actions on top of what we're already doing; and also about the role of our managers in making sure that when they're with staff, through regular one-to-ones and interactions, they are talking about well-being and they are checking in with people about how they're feeling, and they are trying to support them in that, if they need some adjustments or assistance with some of the things that they're struggling with. So, we're doing all of that, and we'll keep in contact with staff, and I think some of the—. The measures that Katrin's relayed to you, particularly around our detailed investigation and the investigation teams, hopefully that is now starting to see an impact in terms of reducing case loads that everyone is carrying, so that we can improve productivity going forward.

Thank you. Rhianon.

When you came to this committee at the last point in the year, you mentioned your concerns in terms of workloads and the impacts on well-being for staff. One of your mitigations, which you say is helping in terms of the investigatory teams, is the increase in your bank staffing. I can understand absolutely why that's on the cards, on the table, but is there any knock-on impact in terms of other staff thinking that there may be a two-tier workforce or there may be issues in terms of other sectors, where you've brought in outside staffing to complement the core workforce? Is there then any knock-on impact in terms of well-being?

Sorry, just to add to that. And, obviously, bank work costs more money, probably, than—

That's what I'm getting at.

Sorry, yes—

I was hoping that would come out. [Laughter.] Thank you, Chair.

Use of bank workers is a short-term measure to cover when we have gaps due to vacancies. So, obviously, people leave, they give notice, they leave, and we recruit back into those posts, but there is a period of time, usually, while people are giving notice. There's definitely a period of time when we have to train people and they get up to speed before they can start taking on a reasonable case load. So, during that lag, which happens whenever you change staff, we're using the bank workers to plug that gap, and that's all we're using them for. And I do think it's been seen positively by staff, because, otherwise, what happens when there's a gap is others have to fill in, or things just don't get done. So, the bank workers are only used to plug that gap. I think we're very quick off the mark, when we get resignations, in recruiting, and we are fortunate at the moment that, up until now, we've been able to recruit good-quality staff into the roles that we go out for. So, that's positive.

And in regard, then, to the final part of this question, it is more expensive, and you're saying that that's being esteemed by your core staff, as part of the plan and helpful, but as far as your costs are concerned, is it best usage of your money in terms of salaried staff?

I would say 'yes', because we're only plugging the gap. We are getting the posts filled as soon as we can, and as soon as we get people in and fully trained, we stop using the bank workers. So, it's only for that period of time that we're using it.

And the bank staff, are you using the same people, so it's people who have either retired or gone on to do something else, but they're able to come in and fill that gap, so you don't need to retrain them all the time?

No, that's right. 

Right. That's correct. 

It's the same—. It's a small pool. One, for example, works for another ombudsman scheme in the UK and does a few extra hours for us, so it is limited and plugs that gap. And, as I said before, the investigators retain ownership of their cases, but it's a help in terms of moving the case onto the next step, for example, doing a clinical advice request or an initial draft for that investigator's consideration. So, the investigator is still very much in control of that case and manages that case.

Okay. Thank you. So, if we could briefly just go on to the service quality process that you've put in place. And, obviously, the amount of complaints that were referred to the external review service tripled compared to the previous year. Is that a concern? And if you could talk briefly about the new service quality process, and maybe some commentary around that, and then I'll go on to Mike Hedges.

Yes, I'll ask Chris to take that one.

Chris, there we are.

Thank you. I think there are a few different things going on here. What you referred to there, Chair, was around complaints about our service, where we have had an increase in the number of people approaching our external reviewer of complaints about our service. We're keen to have that sort of independent scrutiny of our service. I think what has come from those cases, though, are some areas where we could do better, but not a pattern of real underlying issues or recurring themes—they're specific things we could have done better. 

To move on to the service quality—and I think you touched on that earlier—we spoke last year about introducing a new approach to service quality. We recognise that the quality of our service is really important. People put their trust in us to handle their complaints fairly, so that we're making the right decisions; that's important. But also, the service we provide in considering complaints is also important. So, there are those two strands: the decisions and the service. 

And, on the decisions, we've got a long-established process of allowing people to ask for a review of their casework decision if they've got new evidence, or they think we've not properly considered the evidence they've provided. That is continuing. What we've changed is the focus on service quality, which is really based on our service standards, our published service standards, so that the complainants know what they can expect from us in terms of accessibility and communication, professionalism, fairness and transparency.

So, our service quality work has changed. We've got a new service quality officer, who is part time, but who is a specialist, rather than somebody who's just doing it on top of other duties. We've now rolled out the new approach to service quality. I think one of the key changes is rather than wait until we get to the end, and looking at closed cases, the service quality work actually looks at live cases that are still open and still being worked on. And that means there's a much quicker identification of anything that's not quite right, but it also gives us an opportunity to put things right while the case is live rather than afterwards.

I think 2022-23 was a bit of transition year; we're now working under the service quality regime for real. I think what it's identified are some of the things we've probably already talked about, with the challenges of high case loads and cases taking longer as a result. And, obviously, service quality work can't make it easier to move cases more quickly, but what we are having a real focus on is making sure that our staff communicate well with complainants, to make sure they understand what is happening, what delays there might be, why those delays might be, and what they can expect. And I think—to be open with you—one of the things that's come out of the service quality work so far is that that's something we need to work on. We need to be better at communicating and keeping our complainants up to date with where their complaint is. And that's work in progress. That's very much a feature of the service quality work.

And then, just perhaps to conclude, we see the service quality work as really important. We see the accuracy and appropriateness of our decisions as really important. Both of those things, then, feature in our key performance indicators, so that we've got a close eye on those during the year.

Thank you very much. Mike, I'll move on to you.

We've spent a lot of time in the past, before you took over, Michelle, talking about own-initiative investigations. Your predecessor was very keen on it and eventually you've got that capacity. But what capacity do you have to conduct own-initiative investigations, considering your financial constraints?

Well, what we have in our structure is one lead officer, who leads our work on own-initiative investigations. So, it's not a huge resource, but it's a very important resource for us, and for me, in terms of making sure that we use that power properly and appropriately and to the benefit of the wider public sector in Wales. So, specifically, we're linking the use of our own initiative and the work of that officer to the communities in Wales where we know that they are not accessing our services. And I've talked to the committee before about accessibility; that's now one of our key strategic aims, as part of our new strategic plan. So, we're using own-initiative investigations to try and target those sectors of the community where we know they don't tend to bring complaints to us, so therefore we might be missing issues, for whatever reason. So, the current—and this'll be my first own-initiative investigation—the current one that we are under way with is with regards to unpaid carers in Wales, and looking at, really, their lived experience of the support that they get, and need, to help them with the important role they have in caring for loved ones. So, that work's under way and we'll be reporting on that early next year.

So, we also use the power to do extended investigations; we reported on that in our annual report. So, that's important as well, because—back to your point about where we see things that are similar or common themes—it allows me—and we've used this a number of times last year—to extend investigations, which I couldn't have, previous to the 2019 Act. So, you might be able to extend investigations, so you look at issues for a wider group of people who've perhaps never brought a complaint to us, they weren't aware there was an issue, but there is an impact there for them. Or it might allow me to bring in another public body into scope, and that's something we did last year as well. Because you recognise, particularly with health, there are complexities where people might move between health boards for services, because of regional specialisms, so the power is used in that respect as well. So, it's not just the big own-initiative investigation, it's used for the extended work as well.

So, you were saying about moving, I've actually been dealing with somebody who was in London, has now moved to Wales, and now wants to complain about London, but that is outside your scope. Are people able to complain about individual GP practices?

Yes.

Because that does not appear to be well enough known. And I'm going to do my bit for you; I'm going to—

Thank you.

Add to your case load. [Laughter.]

I'm going to put that out, because there are some that are a serious problem, and I think that the health boards are finding it difficult to deal with them. Maybe you might have a better handle on it.

The annual report says you have reviewed the governance arrangements of the audit and risk assurance committee and advisory panel. What changes have you made?

Yes, we've done that review, and I think we talked about that when I came to talk to the committee last year. Since we last spoke, I've made further appointments to both the panel and the committee—one additional member joined the ARAC, and three new members joined our advisory panel. That was about extending the diversity on those groups, but also the expertise from different sectors that we could draw in to help me with my work. I'm really pleased with those recent appointments. We had a good response to the recruitment, and we've made some good appointments, got some really enthusiastic members now on those committees.

This does now mean that the majority of members on both the panel and the committee are independent, i.e. they don't sit on both committees, and I think that's been a concern for Members of the Senedd in the past. We have one member who sits on both, but when his term of office ends, that will fall away. So, I think it is in a much stronger position in terms of that independence than it probably was a few years ago. And both bodies are really important and really helpful to me in undertaking my role and making sure there's proper scrutiny and overview of the work that we're doing.

Thank you. I think that is a positive way forward.

You outline two risks with a high level of risk—the number of complaints and staff resource, and the other around budget. I'm sure anybody else we had in here or at any other committee would be identifying exactly the same risks. How are you mitigating those?

If I could ask Katrin to pick up the risk around the number of complaints, and then Chris will deal with the second risk.

Some of the steps I mentioned earlier have been designed to mitigate and futureproof us for dealing with the increase in complaints. The proportionate decision making is designed, really, for us to be able to adapt, depending on what we receive and where that threshold is in terms of where we devote our resources to the significant and serious cases. There's also that piece of work around communication with complainants and our main advocacy body, Llais, to ensure that, as far as possible, everyone understands what complaints we can take forward and we avoid receiving the complaints that are not a matter for us, and that's about clear communication.

We are looking very closely in our management team at where the blocks are in our system, which cases can be progressed, to get rid of those cases in terms of the ones we are not able to see through to a conclusion, and really focus then on those detailed investigation and aged cases. And the improvements that I outlined earlier in terms of our internal processes—for example, our clinical advice process—are really designed to equip us to avoid any future delays wherever possible and try and mitigate those risks, should our caseload continue to rise, as it is already this year.

Also, our ARA committee regularly looks at the risk around the number of complaints. We have put reports to our advisory panel members to get that challenge and scrutiny in terms of are we taking the right steps from their objective, independent perspective. A number of those issues are all designed, really, first of all to equip us to improve performance at the moment, but also make sure that we work flexibly across our teams, both assessment and investigation, so that we can adapt and deal with the complaints that come to us, which are out of our control, of course, but we need to be able to handle when we do receive them.

If I can just pick up on the risk around the adequacy of the budget. Obviously, we can't control the demands on what's a front-line service, and we don't control directly our costs, in the sense that we don't control staff pay awards, which, as you know, is one of the key drivers of our costs. And I guess, like others, we also face the difficulty and the challenges of setting a budget now, trying to estimate what's going to happen in the course of the next 17 months, until the end of the year that we are budgeting for. As you'd probably expect, this is a risk that we've discussed in some detail with our audit and risk assurance committee, and that's been one of the subjects for an in-depth consideration of risk.

In managing the risks, I guess there are no easy solutions that solve all of the budgetary problems and concerns for the future, but what we've got a real focus on is making good use of our resources, continuing to work to improve the efficiency of our systems and our processes. As Katrin mentioned, we're being very careful to be proportionate in our approach to casework, so that we're looking at the right cases and the right aspects of the right cases. We're working on service improvement. I know we talked last year about our intentions in terms of service improvement, and, in particular, improving our website so that it gives more people the information they need so that they don't necessarily need to contact us, and hopefully they won't contact us if it's something that we cannot look at. Obviously, we will always want to be as helpful as we can, but if we can't look at things, it just takes up their time and ours. So, the website, hopefully, will help address that.

And we're also—again, we talked about this last year—working on our office accommodation. We've reduced the office accommodation that we need, so we've vacated significant areas of our office accommodation that is now being marketed, and we want to deliver savings through that so that we can reinvest those in service improvement. But ultimately, we don't control the demands on our service or some of the costs that we face, so I guess that's why it is a high risk. This estimate and the adequacy of this budget that we're talking about later on will be key to that risk, now and in the future. 

Thank you. I'm just conscious of the time. If we could keep our answers a little bit briefer going forward just for the rest of the session. It hopefully means that we can cover more ground. Mike, you've got—

My last question. Your accounts show that computers, equipment, furniture and fittings were reclassified as surplus during the year. I understand the value is about £137,000, and that may or may not be correct. They were fully depreciated. What's happened to them? Have you just scrapped them or have you kept them? Have you replaced them? So, is there somewhere in there £137,000 of fixtures, fittings and IT equipment to make up for what's been written off? 

That very closely links to the accommodation project I was just talking about. The furniture and equipment was surplus, and we haven't replaced it. We've just reduced what we have. The slight distinction in the accounts was that some of the equipment and furniture we disposed of by 31 March, so that was a disposal. Some of it was earmarked for disposal but still physically in the office, so the auditors wanted that shown as reclassified. But we're not replacing those assets—they've gone. Where we could, we donated those to charities like the British Heart Foundation. There's quite a lot of spare office furniture around at the moment, and also old IT equipment is probably not particularly valuable, so the stuff that we can't find other homes for is being disposed of. 

Thank you. 

Just on your accounts for last year, you've got £1,000 cash left to return to the consolidated fund. How comfortable are you that you've managed the budget to that extent, and how did you ensure that you didn't exceed the cash limits?

I think we're comfortable with the way the budget was managed. It took a lot of very close management, particularly in that last three months, as you'll all recognise, to make sure that we came in the right side of the budget. But there was some very good work done by the team, so I'm comfortable with that, yes. 

Thank you. We'll move on to Peter. Diolch. 

A quick remark first, and I'll try to compensate by amalgamating questions. I've always been puzzled, as an ex-council leader, why standards and your function are the way they are, where you do your investigation into standards. It would be useful if standards could do a lot more in local authorities to do more local resolutions to save you having to bother with them, and then sending them back to standards. I just think it's back to front in many ways, and we could be making more use of a function there to relieve pressure off you, and resource. However, that—

There's a whole conversation we could have about that another day.

It's for some different place, I know. But I had to say it, because I've been wanting to say it for a long time. 

So, moving on to look at the estimate now, and trying to understand some of the issues that are influencing the development of that, we know—it’s very topical at the moment—how tight settlements are going to be, and next year the Minister is saying how tight it’s going to be, and we’ve got a set of principles we need to work toward and be satisfied that we’ve met. Your estimates are coming in at around an 8.4 per cent increase, so I just want to understand whether you're content you’ve applied those principles, and this is the best you can do from that perspective.

And then my second question on that. Your strategic plan going forward for 2023-26 is a considerable plan; to what degree does that plan move forward based on this estimate? If this estimate didn’t get agreed, how does that affect your plan?

Perhaps the first part, then. Yes, we obviously try hard to work to the principles that you expect us to work to. We do understand the wider pressure that there is on public sector funding—as you said, very topical this week in particular. The factors that sit under our estimate I am comfortable with. Firstly, it's the new strategic plan—so, that sets the context, as you've already identified. And I think the committee knows, because we've discussed this before, the way we have to manage our budget is that all our funding comes through this route, through the Welsh consolidated fund. Our legislation doesn't allow us to make any charges for the work that we do, and that's probably quite correct, and we're not able to hold contingencies or reserves, so we're not able to manage budgets over multiple years. So that makes it all the more challenging, and we take that into account as well.

In terms of what's driving, or what's sitting under that 8.4 per cent, I think for us, with a relatively small budget, the percentages don’t help because it sounds like a big percentage, but the increase we’re looking at is £490,000. And 7.4 per cent—most of that—is just to stand still, really, and that’s driven by two key things. First, it’s the cost of pay—and again, we’ve discussed that before. Our staff are on local government terms and conditions, so we await the outcome of those pay negotiations and then that’s what we apply. In terms of this estimate, we’ve had to make a call on that quite a long way in advance. We’re in a situation where the local government settlement for this year hasn’t been agreed yet, and we’re trying to look ahead to next year already. We’ve estimated that at 5 per cent, but to be honest, it could be that that is slightly on the high side, and it could be that looking at something more reasonable like a 3 per cent uplift would obviously bring what we’re asking for down, and bring it, certainly, below 7 per cent. And you manage the risk around that, then. So, that is very much an estimate, and a long way in advance of when we’ll have certainty on that.

The other key thing then is the cost pressures, and we have put in a pressure around price inflation. This doesn’t reflect all of the additional costs we’ll have through price inflation. We realise we’ve got to manage some of that ourselves. We’ve based it around the consumer prices index for August at 6.7 per cent. We know from today that’s staying at that level. But for us, technology is an important and quite a big part of our budget, because of the way we work, and the increase in our IT costs has gone up ahead of that inflation figure that we’ve allowed for, so we’ve had to absorb those.

So those are the sort of elements that make up the budget. I’m perhaps going on a bit too long—apologies, Chair. But just to make the point that those are things that—. And I appreciate that, for all of the public sector, it’s outside of our control.

But your strategic plan isn't undermined. If this estimate didn't happen, your plan still goes ahead—you just might have to alter the nature of it. 

I think in terms of the plan, our focus this year is around our two strategic aims. The first one is around dealing with complaints, our core service, and we've talked to you about the pressures there, so it's right that that's our focus. And the other area would be around supporting staff and well-being as well. Because we recognise the pressures that staff are under and we want to protect that front-line service. So, I think, for us, if we're able to bring in more funding we could do more next year. What we've done is phased our ambition, if I could put it that way; the ambition's still in the plan but we're phasing that. So, for example, we recognise that we need to invest in technology to make sure we're up to date, to make sure we're secure and resilient, but we're not looking to do that next year. We're pushing that back, because we hope we can use property savings in future years to fund that. So, we're trying to phase our ambition, if you like, and the focus very much for next year would be around that core service delivery and supporting our staff. 

Okay. Well, thanks, Michelle, for that. So, just recognising that your estimate is projecting an about 28 per cent increase in cases and an increase in code of conduct cases, and we talked a bit about that pressure coming forward, how have you—? Can you help us understand how you've assessed that, that you've built the estimate, obviously, based on a lot of that? 

Yes, could you just cover that, Chris?

Yes, it's always quite a difficult act—art—trying to project future workload. This is probably quite a simple answer, hopefully a short answer. Yes, the projected 28 per cent increase in the current year is based on actual case load received up til the end of August and we've just projected that through to the year end. So, we've not—. We haven't made any new assumptions, we've assumed that it will continue at the current level that we're experiencing this year. 

Okay. Great, that makes sense. My final question: so, you’re estimating an increase of between 5 per cent and 12 per cent in cases for 2024-25 but this is based on calculations used for the Public Services Ombudsman (Wales) Act 2019 and the regulatory impact assessment for the—sorry— the legislation—I'll get there in a minute, Chair—the regulatory impact assessment for that legislation—why won't my thing move—only estimated costs to the 2022-23 year. Why is it still appropriate to use those assumptions for your planning and have you considered any other factors when preparing the estimates? Sorry about that. 

That's fine. The regulatory impact assessment did run as far as 2022-23 but that was based on the legislation coming into force, so commencement, on 1 April 2018. The Act actually came into force in the summer of 2019, so I guess there's an argument that you roll everything forward. I think it is a sensible and fair question, and, obviously, as you reach the end of that regulatory impact assessment period it's sensible to look at how else we might project. I think it's perhaps repeating what I said, but it is really difficult to predict and project complaint numbers, because they do fluctuate wildly. The trend is always up, unfortunately, but the fluctuations from year to year are quite significant. It's something we will look at again as we do future projections. What I would say is that, looking at the longer period, the projection of between 5 per cent and 12 per cent, actually, if you look back over the last few years, is broadly sensible as an average. But there are significant fluctuations within that. 

Okay. Thank you. 

Rhianon. 

Thank you, Chair. Just very briefly, you touched upon the areas that don't complain, or possibly you collect data around that—I know, obviously, Lottery targets those areas that they know they don't get applications from, mostly within high-level Welsh index of multiple deprivation areas. So, in terms of that as an issue for future technology—you talked about website development and access from vulnerable groups and the carers et cetera, what data do you actually collect? Is there a quick answer that you can give me on that? And how are you actually targeting those groups? Is it just geographical, or is it—?

The answer is: our case load management system has a huge amount of data in it. It has data about the people who come to us, though, so there is a wider piece of work that our policy and comms team do around understanding the characteristics—the demographics, sorry; that's a better word—of those. What we look at is who comes to us—. Sorry, I'll get my answer straight here. We know who comes to us, so, therefore, we know who doesn't.

Yes, by default.

Yes. So, you can look at—you know, the representation of that community across Wales, we hardly see anyone, so you know that's out of kilter.

So, in terms of technological development, all that sort of forward-facing work now is on the back burner, would you say, or is there still work going on on that sort of thing?

Well, part of the inclusion in our—. The small bit of growth that we have above a standstill budget within our estimate this year is around a data analytics officer.

Okay.

And that is exactly the gap that we're trying to plug. So, we've got a lot of data, what we don't have is the capacity and expertise to mine and extract that data in a way that would really help us prioritise and understand, particularly our accessibility work, but also to help us prioritise and perhaps manage better some of our complaint case load work as well. So, we know there's a lot of opportunity there, but we're not taking that opportunity at the moment, and that's why we have made that point within the estimate this year, and that is something we would like to do next year.

Okay, thank you. You've answered the first of my questions in relation to your projection around the 5 per cent pay award and the potential, you know, it could be above the 3 per cent, and also in terms of where we currently sit in terms of that pay award for 2023. So, I'm going to move onto my second question in terms of the inflationary pressures of the £235,000 figure in the non-staff expenditure. So, you've suggested that some of those in-year price increases relate, I think, in part to information and communications technology contracts being higher than you've anticipated. What were your expectations, briefly, around those costs going into 2024-25? And you've also highlighted a £58,000 cost associated with retendering the case management system. The question there, if I back-to-back them, is: is that an ongoing cost of that exercise?

So, the case management system I think is something, again, we spoke to the committee about last year. So, it's coming to the end of the contract and we need to retender, and we're mid way in doing that now. Based on our experience of what's happened with the costs associated with other information technology contracts this year, they are going up—sometimes more than once a year, and definitely in double figures. So, that is an estimate. We don't expect to go out and reprocure a contract that's, what, five years old and have it for the same cost; we anticipate it's going to cost more. So, that is an estimate, based on what we've seen with other ICT contracts, of what it's going to cost.

I think for us, as we've said, technology is such an important part of what we do. We've reduced our office space, and there will be benefits flowing from that. We're working in an agile way and we can do that very effectively as an organisation, but the technology is what holds us all together, and it's absolutely important we're up to date. We're currently putting the finishing touches to an ICT and digital strategy, which will set out what we need to be doing over the next few years to make sure that we can deliver our business. So, that will, I think, for future estimates, give us a much clearer picture of what we need, and we'll be able to talk to that. But, for this year, we're really looking at the contracts that we have in place and the fact that the costs are going up year on year. They're all index linked.

Fine. Thank you for that. That was interesting.

So, you've talked about efficiencies already and you talked about your reduction around office costs just a moment ago, but the estimate does request an additional £71,000 for premises and facility costs and £16,000 for office costs—although it does indicate that that's going to be offset by savings. So, just an explanation as to why that's in there in that way after your comments, and whether you anticipate making cost savings in the longer term in your accommodation. Because we can see that you're trying to do that.

Yes. At the moment, we're contractually committed to the accommodation we've got; so we still need to meet the lease costs and the non-domestic rates. There are some reductions in energy usage, but, unfortunately, not reductions in energy costs. So, the £71,000 increase is made up of energy and non-domestic rate increases primarily, which is about £38,000. The other bit—and I hope you don't ask too many detailed questions about this, because it's about—

Well, this is very detailed—£16,000, I've got in here.

International financial reporting standards 16—

I've never seen that before.

IFRS 16 accounting changes mean that there's a change in the treatment of value added tax on the lease. So, £33,000 of that increase is a bit of a notional increase; it's the VAT and it actually comes out in the IFRS reductions elsewhere. So, the £71,000 figure is correct in accounting terms; it's a little bit misleading, because the £33,000 is the difference between cash and resource, and it's adjusted in one of the lines below. So, the real increase is £38,000.

Okay, thank you. The wider question, then, is: do you anticipate making cost savings on accommodation in the longer term? Obviously, the inflationary pressures are there. 

Yes, as Chris has indicated, we now accommodate—. We're all on the ground floor; so, the upper floors that we previously occupied are being marketed. If we can get out of our lease early, that's what we're trying to do. If we can't, that lease comes to a natural end in 2025 and we won't renew it. So, that will release funding within our budget and, as indicated earlier, we would hope, then, to be able to use that to reinvest in technology infrastructure for the future.

So, you're not planning on a massive office move somewhere nice and shiny, then.

No, we're very happy where we are.

[Laughter.] Fine. Right, I'm coming to my last questions, Chair. The request also includes funding for one investigation officer and one data analyst—you've already outlined that. Just to outline why those roles are needed, very briefly—you've already done some of that.

I've covered the data analytics officer, so hopefully that was clear and I won't cover that again. The other one is quite straightforward; it's an additional officer to support some of those casework pressures that we're experiencing. It won't meet them all—we would need about five officers to do that, but we didn't feel that was a reasonable thing to ask.

Okay, so, you've underestimated, in a sense, what you could do with.

Yes, because of the current financial position, we feel that that wouldn't be reasonable, but I think this would send a very important message to our staff that we can provide some additional resource to help the teams with the case loads they're facing.

Excellent. My final question: funding for those two posts is going to be partially offset by efficiencies in non-pay budgets, so can you briefly outline how these efficiencies are generated, or potentially generated, given the increases that we've identified everywhere else?

Yes. Did you have those, Chris?

Yes. There are a number of small efficiencies, rather than one big efficiency, but what we're looking to do constantly is, for example, to rationalise our use of IT. At the moment, we use quite a lot of different software packages. What we're looking to do, as part of our case management system, is to try and incorporate as many of those as we can within the system so that we don't need to have the bolt-on software. We're looking at managing our professional fees—so, that's primarily the clinical advice that we get on our casework—to make sure, and it ties in with some of the things that Katrin was talking about earlier, that our requests for clinical advice are very focused and very specific and very tightly managed so that we're reducing the amount of time and the cost of those pieces of advice.

We're making changes—we touched on some of them—around premises. We're using less energy, we're producing less waste, we're trying to reduce the amount of paper we use; there are things like that. No huge single figures, but lots of small changes there. We're providing training using Teams or online facilities rather than travel, so that we're not travelling around Wales as much.

So, it's a suite of measures.

It's a whole range of small things. There's no single, big saving, but it's trying to make small savings across every budget, if we can.

Okay, thank you very much, Chair.

Thank you. Finally from me, you've talked in the estimate about the impact if additional funding is not approved. Can you provide further detail on how you'd manage if part or all of the estimate was not approved, particularly in terms of staff pay and well-being?

Yes. In terms of staff pay, as I said, the two big issues here for us are the increased costs we face in increased pay. I think we've set out in the estimate that if there were a significant reduction in our funding—if we weren't getting the funding set out—we'd have to look at reducing staff, unfortunately. Eighty per cent of our costs are staff based, so we would have to look again at that and see if there were some way we could reduce that. That could be quite a few members of staff, though, given our size, and it could lead to redundancies. So, that's the only thing that I'd flag up, that there would then be a risk of having to come back with supplementary oncosts around redundancy. It's not what we want to do, because I don't think that that would have a positive impact on staff morale either. They would feel that they're between a rock and a hard place. So, this budget estimate is very much focused on trying, next year, to support our staff and focus on our core business of handling those increases in complaints.

So, you're confident that what you've asked for here is what you need to maintain your service standards and to give you that robustness, going forward. So, there's nothing in here that's frivolous or anything that would just be nice to have.

No. There's nothing in here that's frivolous. As I said in answer to your question, actually, if you were looking at the caseload increase and matching the staff requirements to that, it would be more like five full-time equivalents. We don't think that that's reasonable in the current climate, but I think it's important that we can at least put some additional resource in. And the data analytics work I think will help us be far more intelligent about how we manage our caseload and do our work in future, and so it's got longer term, more transformational benefits for us as well. But, Chair, no, there's nothing frivolous in here at all.

No. Thank you very much.

Diolch.

We'll now take a short break to reset the room and to get our next witnesses in. Thank you for your time. Obviously, a transcript will be sent to you so that you can check its accuracy. I think we've covered all the questions, but if something does come up in conversation after this session, we might write to you, but we've asked all the questions that we wanted to at this point. Thank you very much. Diolch yn fawr.

Can we go into private for a quarter of an hour or so?

Welcome to Mick Antoniw, the Counsel General, and his officials. Would you just introduce yourself and your officials for the record?

I'm Mick Antoniw, the Counsel General in Welsh Government and Minister for the Constitution. I'll perhaps ask my officials to introduce themselves.

Emma Alexander, head of Senedd reform delivery in the Welsh Government.

And Will Whiteley, deputy director for Senedd reform in the Welsh Government.

Thank you very much. Diolch yn fawr. Croeso cynnes. As you're aware, this is broadcast live and there'll be a transcript available for you at the end. We've got quite a lot of ground to cover, so if I could ask for brevity, that would be great, but we'll crack on. We've obviously had the RIA, and you've introduced this Bill on behalf of the Senedd. The Bill is estimated to cost between £99.7 million and £119.6 million over an eight-year appraisal period. How confident are you in these costs and how do you assess its value for money?

That's over the eight-year period. I'm confident that what we've done is to engage, for example, with the Senedd Commission and other relevant bodies in order to do the best you can to do an evaluation and an estimate of all those costings. Obviously, the bulk of them relate to the Senedd costs themselves, and some of them are very empirical, insofar as you know how many additional Senedd Members are, you know what the cost is, you know what the support costs are, you multiply that by 36, and those figures are there.

The engagement we've had with the Senedd Commission over this has been, certainly, a process that's gone backwards and forwards. It has scrutinised figures, and figures have been challenged on a mutual basis. But what we actually have then, I think, are what are the best estimates that we can arrive at in terms of the banding of costs, bearing in mind we have a certain number of unpredictables. For example, the classic one is we don't know how many Ministers there might be, or the status of those Ministers, whether they're Ministers or Deputy Ministers and so on. But, basically, I think they are the best estimates for the impact assessment.

I suppose it's fair to say that this is an ongoing work in progress, and that, as time goes on, if there are opportunities to review, to examine, et cetera, then that is something that will be under way. But for the purpose of this legislation and the obligation to actually provide the best costing that's available, I think that's where we are. I don't know if there's anything that you can add to that.

Yes. It's just that I think these are the best estimates. They provide robust assessment of the costs that we've been able to quantify and set out in the impact assessment.

We heard from the finance Minister yesterday about pressures on the budget and that sort of thing. Obviously, the budget for this will come out of the block grant before it's allocated out. On the extra 12-point-something million pounds a year, is that good value for money to come out, and what impact might that have on Government spending, because it'll come out of the block grant before you allocate the rest of the money to spend on public services?

I think this comes back to the very essence of the legislation in the first place. It's an investment, I think, in democracy. Also, I suppose, if I just take that a little bit further, I think it's value for money not only because, overall, it will deliver better governance, better scrutiny, better legislation, better use of all the public resources that the Senedd has and the role of the Welsh Government, but, in the short to medium term, it also becomes something that actually pays for itself. This is legislation that is essentially self-funding and, in actual fact, should result in net benefit over a period of time.

I'll just refer that, as I was reading through and preparing things, there was interesting correspondence a while back with the auditor general, who looked at this issue. This was a letter of 15 May that he wrote to the Committee on Senedd Electoral Reform, where this issue was considered. He said then, as it's the auditor general who basically oversees the ethics of some of these issues:

'The costs and implications of policy and spending decisions taken by the Welsh Government and Senedd are significant...it is important to recognise that a 0.17% annual saving, or improvement in value, in Welsh Government spending'—

at the time it was £17.5 billion, and in 2017, I think, this letter would have been written—

'would pay for 30 extra members (at £10 million a year in total, including support costs).'

What we’re saying is that these costs basically amount to 0.07 per cent of the Welsh Government’s budget, so half that. So, if that 0.07 per cent improvement in the utilisation of money and resources and governance is achieved, then this legislation pays for itself. If we do any better than that, then that will ultimately result in net benefit to the Welsh Government as a whole. So, when I say it's an investment in democracy, it is an investment in democracy, but it's also an investment in getting the best use out of the resources that the Senedd overall, the Welsh Parliament overall, has.

Thank you very much. I'd like to look at how you've developed the regulatory impact assessment, and looking at the cost estimates from stakeholders that you've included. Can you or your officials talk us through how the process was undertaken, and how did you ensure that stakeholders were satisfied with your approach in presenting these cost estimates?

Of course. The first thing to say is, of course that this issue and this type of reform has been looked at in general through many different commissions and so on, so there has been engagement over many, many years with various bodies and so on. But the key ones, obviously, that we're concerned with now are the engagement with the Senedd Commission, the Electoral Commission, local authorities, the Welsh Local Government Association, the local democracy and boundary commission—where there's obviously a relevance—the independent remuneration body. Obviously, the big bulk of it is with the Senedd Commission. So, they have been engaged, they've been consulted with, they've been asked to put their own forward their own assessments, figures, evaluations. There's been, I think, a backwards and forwards process on that. So, that's how that has happened. Perhaps it might be best if I go over to Will, just to give a bit more, since he's been involved in those discussions.

Yes, of course, Counsel General. So, on the Senedd Commission in particular, the First Minister wrote to the Llywydd in December of last year asking for work to be done to provide best estimates of costs, and they then embarked on an internal process involving both the Business Committee and the independent remuneration board to develop those costs, which, as you’ll see in the RIA, cover a wide range and are the lion’s share of the costs over the appraisal period. Those estimates were then provided to the Welsh Government in March of this year, and then, I think, from that point through to around August, a good four months of dialogue was had—and constructive dialogue, I have to say—between the Welsh Government and the Commission at an official level just to best understand the costs that were being brought forward, to understand what lay behind them and how they'd been calculated so that we could present them faithfully within the regulatory impact assessment.

And there were a number of changes that were made as a consequence of that, as, I think, the Commission may have told you at your session last week—for example, a reprofiling of costs as a consequence of the proposed change to four-year terms. There were some other aspects, mainly just to ensure that the presentation of costs were consistent with the Welsh Government's approach to regulatory impact assessments—so, for example, staff costs and how they're presented. And that resulted in the First Minister confirming the costs that would be presented within the regulatory impact assessment.

And then we shared the section of the RIA with Commission officials just for confirmation and factual accuracy, ahead of then introducing the Bill in September. I go into that in a bit more detail because that was the lion’s share of the costs. We’ve had a similar approach with the other bodies, working closely with the local democracy and boundary commission, for them to assess their likely costs as a consequence of the two different boundary reviews that are provided within the appraisal period, understanding the implications for them and, again, understanding the costings and being confident in them.

Probably the one to mention is the local authority costs. The approach that we took on that was through the Welsh Local Government Association. We established a working group, which included representation from the electoral community across a number of local authorities that we felt was representative of Wales as a whole, both geographically but also rural and urban local authorities. So, that group included current and former regional returning officers as well as electoral administrators, and they identified where there would be cost implications that could be identified and quantified as a consequence of the reforms, and then they’ve provided us with a percentage change in those, either a saving or an additional cost.

And then we undertook a piece of work flowing from that to reconcile those percentage changes with the costs that were incurred at the 2021 election. So, that election was used as a basis and then obviously uprating those costs to the 2022-23 baseline that we were doing. Similarly, we shared the section of the regulatory impact assessment with that group for just confirmation of factual accuracy ahead of publication.

I could probably talk a bit about the Welsh Government one, but that was obviously, as you’d expect, more of an internal exercise, working with colleagues across the organisation to determine the costs associated.

Okay. Thank you very much. The expert panel report recommended that an appropriate size for the new Senedd would be between 80 and 90. Why have you only provided one costed option for 96?

Basically because the way I’ve seen my role in this is to basically—. There is a bit of semantics as to whether it’s a Senedd Bill or a Government Bill; I think this is actually a Senedd Bill, but it’s been put together, constructed, on behalf of the Senedd. And I think that’s as it should be, but obviously we have to follow the framework in which we actually operate in terms of the preparation of legislation and the style of legislation and all the supporting impact assessments, and so on, that have to be complied with.

The special purpose committee came with a recommendation and I don’t think it’s appropriate for my role to actually then go behind that policy side. That discussion has taken place within the Senedd structure itself, so the purpose of this legislation is to implement what’s been recommended to us, not for us to go behind that or to try to second-guess it. So, the costings are based really on the proposal that’s come from the special purpose committee.

And because that recommendation was 96, that's why it's been—

That's right.

Okay. And the RIA then notes that the Welsh Government could incur ongoing costs of between £8.3 million and £10.3 million per year. How would you intend to fund these additional costs?

It's interesting, in the terminology of this, of course, the terminology of opportunity costs comes in and I’ve had to think very carefully about what that actually means. Basically, I think what we’re talking about is that none of this is related to increasing the actual responsibilities of the Welsh Government—we know what those responsibilities are. Changes in the future, if there were additional responsibilities, those would have additional implications at that particular stage. So, what we’re looking at really is the resources that we currently have, but with that change—with potentially an increased size of Government—there would have to be a system, I think, of refocusing, reprioritisation, reorganisation of the resources to actually service that. So, we’re not talking about the creation of additional resources being required to do that because we have the resources that provide that bulk of responsibilities already, but it means that they have to be refocused on; they have to reprioritised; we have to look at what the most important areas are that require those resources. So, basically, it is just a reutilisation—the reallocation of those resources in accordance with what the new structure of Government might be.

Thank you very much. I'll move on to Mike Hedges.

Diolch, Cadeirydd. The Bill estimates savings of £751,000 over the eight-year appraisal period. You mentioned that further savings may result once more information is available. What is the potential significance of these savings? Have you got a range for those savings?

Yes. The savings, essentially, the bulk of them, relate to—. Firstly, in terms of the operation of the elections themselves, there will be only one ballot paper, so we're saving—. The bulk, if I remember correctly—and this is over the eight-year period, so it covers two sets of elections for 2026 and 2030—of the savings there, I think, are essentially around £350,000 or so per election, purely in terms of the fact that you've only got the one ballot paper and the one process in terms of assessing the election.

There are certain other savings that exist by virtue of the fact that there will only be, potentially, 16 central counting centres. There are certain imponderables in terms of costs, in terms of knowing precisely once a pairing is complete—we don't know what that pairing might ultimately amount to, but there are certain savings that are there as well. There will be, obviously, savings in terms of potential by-election costs as well. So, averaged over that period, £750,000. There are certain additional costs, and so on, that have to be added in, and there may be some more work for the 16 returning officers and so on, but overall, doing the best you can in terms of the estimate, over that eight-year period there would be a reduction in costs of approximately £0.75 million. Perhaps I could just—I'm not sure who might be best to add to that.

The £751,000 is across the two elections. So, as the Counsel General said, I think it works out at approximately a £375,500 saving per election. But there are a number of unknowns. The working group that I mentioned with the WLGA identified that there may be other savings and also other costs that were impossible to quantify until the constituencies were known, and that involves the counts and the count venue, but also the location of polling stations, and so on, which may need to be reviewed in light of the boundary review having been completed. But, as the CG said, it's based largely on the savings on ballot papers and then on the net effect of savings and additional costs around returning officers.

On polling stations, something I've spent a lot of time taking an interest in, much as we dislike it here and much as we're not happy with it, turnout for a general election is at least 50 per cent higher than that for a Senedd election. So, surely, when a general election gets the polling stations and the numbers, if it works for them, can you see any reason why it wouldn't work for us?

I can't see any reason why there would be any change in that. This begins to overlap a little bit, doesn't it, also, into the other piece of legislation coming through, which will be on elections reform, automatic registration and so on, and the issue or concern about broader democratic health. So, obviously, those are things that returning officers will consider and, of course, there will be a new electoral management board that will be established that will actually manage elections and so on. So, all of those things will go into that. But I think the underlying principle is that we want our elections to be as accessible to people as possible, accessible to communities, but also an opportunity to embrace the opportunities of new technology, and so on, and potentially the benefits of what will probably be an increased electorate, certainly on the electoral register.

It'll be interesting to go into that with you when you come back to this committee to talk about that Bill. So, we'll wait with bated breath to hear what you have to say about the finances of that. Excellent. Sorry, Mike.

I'm very pleased to see that Bill going forward, and I spoke in favour of it in the Senedd, but I don't think that the reason that a lot of people don't vote is because they haven't got around to registering. I think, unfortunately for all of us who are politicians, an awful lot of people don't want to vote for any of us, and I think that's a problem we all need to address.

But moving on, the RIA notes the main areas of uncertainty relate to the possible pairing of constituencies; ministerial changes and decisions on the number of Welsh Ministers, and with ministerial changes, will they need more civil servants to support additional Ministers; and the organisation of the Senedd. In the worlds of Donald Rumsfeld, we've got a lot of known unknowns here, haven't we? The question is: is it your intention to refine your cost estimates as these become more certain?

Well, I think the answer is 'yes'. I think this is work in progress. This isn't a static assessment, because as more becomes known, then obviously—. I mean, this is a best estimate now, but as more information becomes known, when we know about the pairing, then those things will need to be refined, because budgets have to be as transparent and as accurate as is possible. So, yes, it's a work in progress. Is there anything to add to that?

Well, I suppose only to make the obvious point that some of those things will not be known until after the passage of the Bill, but obviously, as part of the budget-setting processes, it'll no doubt continue—

And some won't be known until after 2026—so, for example, the number of Ministers that there might or might not be and so on.

The other thing would be a commitment from you to bring forward an updated RIA after the Stage 2 into Stage 3, as is normal, and I'm assuming you'll be doing a revision once you've seen some of the amendments that come through.

If there are any significant or substantial changes that need to be made in terms of the best estimates that we have at the moment, then of course those need to be done. Those need to be before the Senedd. So, that will obviously happen.

Just carrying on from that, I assume you or your successor will be reporting to this committee, or its successor, the outturn after the election.

Yes. Yes, of course. And of course, not only that; there is of course the review that is going to be set up as a result of this legislation. In fact, two reviews: one on the job-sharing issue, but the one in terms of the operation of the Bill generally. It would be difficult to see how that could happen without actually looking at how the costings of all of that have worked as well.

Okay, thank you.

Thank you. Okay. Peter.

Yes, thank you, Chair. We note that the majority of the costs to Welsh Government are going to be opportunity costs resulting from redeploying staff. Have you made some assessment of what impact that's going to have on the Welsh Government? How are you planning to maintain adequate resourcing across those departments?

In some ways, there is always a process going on of having to look at emerging priorities and changes that are taking place, just in the very nature of governmental work and indeed Senedd work. So, for example, the ongoing legislative programme, not only of the Welsh Government but of what's happening in terms of the UK Government, and of course we've had two major examples where there has been this form of reprioritisation of resources. One is Brexit, which is of course still carrying on to this day, and the intense amount of work in terms of changes because of the withdrawal Act, then in terms of the retained EU law, the Northern Ireland protocol and so on. The second one was in terms of COVID. That resulted in very immediate resourcing. Now, those are particular events that have occurred, but I think in terms of policy issues that are developing, then of course that will be an ongoing process in terms of looking at where resources are best being used and where they're best being focused.

Yes, thanks. And a supplementary, then, to that. Given there is going to be an increase in Members, and it's designed to reflect the expansion of our legislative competence, why do you assume that there are no additional Welsh Government staff needed to support that extra work that is going to flow?

There are certain areas where, obviously, you're looking at it in terms of the demands that would be for the future, whether it be things like security, whether it be the IT support, and so on. But on the basis that the resources we have currently provide for all the existing responsibilities we have, the only circumstances where additional resource would, I think, actually be needed would be, for example, if there were additional devolved responsibilities. You know, of course, of Welsh Government's interest on the issues of youth justice, probation and so on. Well, if those were to come—well, of course, those would be as a result of negotiations with the UK Government, not only in terms of the transfer of those responsibilities, but also in terms of the costs that flow with them. So, those are things that would be incorporated separately, would need to be assessed by the Senedd separately, while on the basis of the existing responsibilities we have, and existing resources, it really is a question of the maximisation of the way in which they are used, the most efficient way and the most prioritised way, and the most focused way. 

Yes—

Sorry, Peter—just on those resource elements, you talked a little bit earlier about reconfiguring, potentially, ministerial roles and the resourcing involved in that. What models have you gone through to account for possible reconfiguration of ministerial portfolios?

Well, I think the things you're looking at, really, are, if there are additional Ministers, there will be, potentially, in the Senedd, more committees. So, there's attendance at committees, there's the support for Ministers in terms of the briefings for those particular committees, potentially more questions that have to be responded to, and there might be more engagements and so on that have to be accommodated. Now, all those are accommodated with a certain number of Ministers at the moment. The issue there, of course, is, in order to have better scrutiny, there needs to be more time allocated to it. But I think the actual work that's done—the briefings, the policy work, the support work—is work that takes place anyway. I think all that happens is that that becomes the subject of much greater focus, and ministerial time is actually greater to enable the Minister to actually be able to, not only specialise in those areas, but, then, to respond to them as well.

So, I think the position in terms of the utilisation of the existing resources remains there, and it's how they are actually used. But the additional ministerial capacity is something that I think is quite significant in terms of having the ability to absorb those briefings, absorb that policy work, and then to be able to explain it and be able to account for it in the committee structure. 

Does that give a knock-on effect, meaning that you'd need more officials, so, therefore—? Or would you resource your offices from within the current pool that you've got?

Well, I think what it means is that, on the basis that that work is already there, officials are doing that work—it's the way in which that work is then able to be utilised by both the Senedd and by the Ministers themselves. So, you will have greater capacity in the Senedd to actually explore that policy work that is actually taking place, and there would be greater capacity for the Minister to actually have time, in terms of additional committee time and so on, for that to actually be explored. And that, I think, begins to lead into better decision-making processes, and, I think, better accounting of the budgets that go with that, and the utilisation of those budgets. And I think that's where I've come back almost to square one, to the first point you made, that if you're doing all those things properly, and you're improving the utilisation, not only of policy, legislation, but also the utilisation of the finance, this legislation becomes self-funding and, in fact, a net benefit to the Senedd as a whole.

Okay. Sorry, Peter. 

Thank you, Chair. You made an allocation of £1.2 million for 2024-25 to prepare and implement the new subordinate legislation arising directly from the Bill. How are these costs being treated in your financial accounts to ensure that there is transparency?

Well, those figures are there—. That figure is there at the moment and, of course, there's a larger figure there for the previous year that already has been allocated in terms of preparation for this legislation, as is normal. The areas that we need to really provide for are probably going to be the boundary reviews—the regulations relating to boundary reviews—regulations relating to the conduct Order, regulations relating to the gender quotas issue. So, really, that's the provision that's made to actually provide for that. It's in the budget, it's transparent and that's what its purpose is for.

Okay. Thank you for that. You highlighted the indirect financial implications resulting from the Bill, with related costs to Welsh Government being unknown or discretionary. Could you explain why you have not modelled possible scenarios to provide cost ranges and what significance could these implications have on the total cost of the Bill?

Well, I think it takes us back to what I said earlier, that this is work in progress, and it's far better to bring figures forward when that further information is actually known and can be properly assessed. I think that's the main reason, and because we'll be coming forward before the committee and during the Senedd process with that updated information. Because otherwise, what we'd be doing is, we could produce all sorts of models, all sorts of speculation as to—. To be honest, I'm not sure it means very much. I don't think it helps the committee or helps the scrutiny side, but as long as the process is—. And I've given that commitment that this is work in progress, it's ongoing, as more detail is available to us, and then those figures are updated and available for scrutiny—that's what would happen.

I understand that. And my last question is: the RIA notes there would be benefits such as a scrutinising policy and legislation in greater detail but doesn't quantify these. Could you explain why you have not quantified the potential impact of these benefits, using the experience from other Parliaments or from international studies?

Yes. I think because each Parliament and each country—its circumstances, the facts relate to those individual countries internationally. I suppose, really, what we do know is good governance leads to better outcomes, and that's why, as I said earlier, the comments from the auditor general were, I think, very clear. I have also had reflections by other bodies, for example, such as the Electoral Reform Society, and others as well. So, I think it's almost like a common standard that if you improve the quality of governance, you improve the quality of scrutiny, you get better outcomes and you get better utilisation of the resources that you apply to that. And I think the same principles, actually—. You said the Senedd is actually a business, and if you had to come along and say, 'How do you actually improve the business?', one of the things you do is you look at the quality of the work that's going on, you look at the expertise you have, you look at what you need to invest to actually deliver better outcomes. For a business, it would be, 'How do you make it more profitable?' Well, in some way, we're almost saying that with the Senedd as well, aren't we, that the outcome of this should be that the Senedd becomes more profitable. By profitable, it means the better use of resources, which means those resources can be used to better improve the services that are delivered.

You mentioned the auditor general a couple of times and what his analysis and assessments might be. It'd be really useful to understand how he arrived at that, because perhaps we haven't articulated that, the benefits of this, well enough, to justify this invest-to-save case, because it sounds like that's quite powerful, if we understood it.

Well, you raise, I think, a very important point. I'll perhaps go to Will in a minute on this. But during the various considerations, the special purpose committees and so on, in terms of seeking evidence and views from specialist areas, one of the natural ones to go to is obviously the auditor general, who I think has a real interest, a statutory interest, in the utilisation of public resources, and that was his view—his view that to appoint a 1.7 per cent annual saving would actually be paying for itself. And we're in a position where, actually, several years on, we're talking about a 0.07 per cent saving. But in terms of engagement with that, perhaps if I defer to Will on this.

Yes. The letter the Counsel General was referring to was to the Committee on Senedd Electoral Reform back in 2020. The basis, I think, for the auditor general's statement around the savings was an analysis of the Public Audit (Wales) Act 2013 and the extent to which—. The sense from him and his office was that, had there been a greater degree of scrutiny and perhaps rigour around that Act in particular, then it may not have resulted in some of the costs that had arisen as a consequence of managing the implications of that and the unintended consequences, I suppose, of that. So, it's an extrapolation I think of that analysis that led him to that, but we could certainly provide the letter to the—. It's a public record, but we can forward it for your information.

It's important analysis, because if you want to show cost benefits, if you've got the evidence to demonstrate it, that's one that ought to be recorded.

We're absolutely happy to make that available. I just really came across it as we were reading through the various documents and the various reports. So, somewhere or other, it is in those various things—it's just bringing these things to light. And, of course, that adds on to what is the democratic benefit that is a more effective, more efficient, better working and more representative Parliament. So, it is a win-win in both elements, I think.

Thank you.

Thank you, Peter. Rhianon.

Thank you very much, Chair. It's difficult for us as a Finance Committee dealing with known unknowns, and obviously we will try our very best in terms of digging in to those assumptions. My questions are really pertaining to those uncertainties. But I think you've well articulated the points or the benefits around increased scrutiny, increased quality and quantity in legislation, and those overall benefits democratically to Wales. That's not why we're here, though. So, my question really is around the explanatory memorandum, which anticipates that a closed list proportional system will facilitate the introduction of statutory integrated gender quotas. In terms of assumptions, what have you used as the model in terms of the increase in the proportion of female Members when estimating those specific costs?

Well, when you think about that, it's an interesting question. I can't see any circumstances where it should be more expensive to have women Members as opposed to male Members—

That's a very good answer.

So, I don't envisage that there is any cost implication to that.

Okay. Thank you. I'm going to move on. The Bill also relates to job sharing—that's something that's been contentious in the past—for particular offices in the Senedd and the Welsh Government. The Bill does not introduce any provisions that would establish job sharing. What consideration was given to modelling around those costs in particular?

The view I take is that it's not appropriate to have any modelling or to actually address that because the Bill, the legislation, won't change by any stretch the issue of job sharing. What it does is facilitate a debate. It ensures that, by the tabling of a motion by the Llywydd, there will be a discussion of that. Where that discussion goes, how far it goes, will be a matter for the next Senedd. So, I don't think it's appropriate, then, on the basis that there is no proposal for the implementation of that, to do any modelling or to do any costing on it.

Okay. It makes sense.

Rhianon, before you go on, I think Mike wanted to just come in on a point there.

Going through it in terms of ease, the easiest job share to have would be Chairs of committee, the second easiest would be Ministers. The more difficult one would be Members. But do you see any reason why any of those should actually cost any more?

Well, I think it would be difficult to justify, if that were the case. I would have thought that the whole concept of job sharing is to look at better ways of ensuring that people can participate within representative democracy, but also can share responsibilities and joint functions. So, there's no reason necessarily why it should. But those are all the things that would be explored if the next Senedd starts looking at the issue of that—it would have to look at all of those. And you're right, there are different levels of it, aren't there? There is the issue, for example, of committee Chairs job sharing. Well, that might be easier than certain other areas. For example, the independent commission we established has co-chairs. Now, that's a slightly different thing—joint chairing—to job sharing, but you'd have to define what you actually mean by job sharing. But that would be a matter for the Senedd, it won't be a matter for me.

When you get to the democratic issues, then that is the nature of representative democracy, where people are elected, their names are on a ballot paper, and how that might actually work and still maintain democratic accountability. So, those are all issues that would have to be explored. One of the reasons why it was not feasible to take that further was because it is an incredibly complex area and has significant legal and constitutional issues that need to be considered very, very carefully in considerable detail. 

I have one thing to follow up, before I go back to Rhianon. With things like new Members to come in and participate fully, and also just for Senedd staff and Commission staff, things like childcare onsite and that sort of thing—. With regard the closed lists with gender quotas, it could be a barrier to some people not to be able to, because of childcare or care for an elderly parent or something, which tends to land more with women than with men. But is that something that's been looked at, or to look at that sort of costing involved to make sure that we get as many people participating in democracy as possible? 

You raise all the rationales as to why this is an issue broadly in industry, as well as within Parliaments. I think the point is, though, that that's really a matter now for the next Senedd to explore. What we are doing via this legislation is just ensuring that that debate will actually happen. But it will be completely up to that next Senedd to decide what the terms of reference are, how far it wants to take it and how far it wants to explore it, and then what it considers can actually be done. 

Thank you. Back to you, Rhianon. 

I'm glad that we've raised those issues, even though it's, in a sense, not part of where we are in this Bill. I think these are really important issues for the next Senedd moving forward—hugely important. Going back to my questions, in terms of uncertainty relating to local authority costs and the consequences of stakeholders exceeding, potentially, cost estimates in the regulatory impact assessment, it states within that there are currently large degrees of uncertainty, and we've talked about known unknowns, we've talked about the iterative process around the costs to local authorities, with the potential for additional costs and savings to be identified. So, how would you encapsulate those uncertainties being managed going forward? And would you expect costs incurred by local authorities to be offset by the savings identified?  

The first thing is that the costs borne by local authorities in respect of elections are borne by the Welsh Government, so they are paid for. We do have the figures in respect of previous elections, and so on. The uncertainties predominantly flow from the boundary pairings, and so on. And as I've said earlier, this is work in progress, and as things are known, then better costings and evaluations will be done of that. So, that's probably the maximum I can really say on that that's helpful. I don't know if there's anything that you can add or wish to add.  

Not really.

That's fine.

They are operational matters, I think, in terms of the actual operation of the election itself. 

Okay. The majority of costs, as you've inferred, incurred by the Electoral Commission and the Local Democracy and Boundary Commission for Wales are considered opportunity costs. What would happen if future resource requirements relating to Senedd reform exceeded cost estimates presented in the RIA? One more go.  

Obviously, they have to be addressed. Hopefully, that isn't something that will occur, because we think we have the best estimates. But, obviously, we engage with all those bodies that are engaged in the electoral process that we're responsible for to ensure that they're doing their work efficiently, they're doing it, et cetera, with the best support that's available. So, those things will have to be examined at that moment in time.  

On the local democracy and boundary commission, the estimates that have been identified in the RIA, certainly for the next financial year, are feeding into that budget-setting process, and you'd expect the best estimates at this stage to be the starting point for those discussions. 

Thank you very much. Thank you, Chair. 

You've made, obviously, assumptions within this, and we're probably looking at Will more than the Minister on this. What's the biggest assumption that you've made, and how have you explained it to the Minister to say, 'Well, this is the assumption we've made, and this is why we're comfortable with it'?

I suppose I would probably say that assumption may differ depending on the organisation that we've assessed in the RIA. As we were just talking about, on the election costs, the running of the election itself, I think probably in terms of the savings there’s an underlying assumption on the ballot paper, for example, that the new ballot paper would be the equivalent of one of the existing ballot papers, and therefore we’ve assumed a 50 per cent saving. Within the broader scope of costs, I think the conversations that we had with the local authority representatives were that a number of these things act against each other, so the larger count venues may be more expensive, but then you would have fewer of them, for example, and you may therefore have some additional savings that are offset by others. So because there were a number of things interplaying, it was just impossible to quantify it. So probably the main assumption, I would say, in terms of local authority costs, would be around that ballot paper, but I think it’s a reasonable assumption to make for Welsh Government costs, as the Counsel General said. 

You talk about that one ballot paper; obviously, as a regional Member, I'm well aware of how the D'Hondt method works, and it's the way I was elected, so I would hope that I sort of understood it, so that would be a good idea. It's not widely understood in the general population, and going back to what we were saying earlier, are there costs there that can be incurred to help with some of the Bill that you're coming forward with, and coming back to us on 15 November to talk to us about that? But is there an interplay there that means that any costs associated with this Bill—? Or will it be associated with that Bill, when it comes to educating the public as to how our democracy works?

I think there are inevitably costs that relate to when the 2026 election comes in terms of how it is communicated, and of course, referring to the other Bill, we're looking at a platform of information and so on. So, those are the costs that actually relate to the elections Bill itself, which is a separate piece of legislation. And of course, with automatic registration, and so on, there’s a need for people to understand that—to understand that, in Welsh elections, you don’t need to have ID cards, and so on. So all those are things where some lessons have already been learnt, but obviously there will have to be preparation to ensure that that is communicated and that is understood. But I think those things really arise from the actual conduct and the management of the election itself.

In terms of the D’Hondt system, I think there are probably quite a lot of people who, if you had to ask them now, ‘Please explain to me in five simple minutes how the D’Hondt system is actually calculated’, you’d have to look back very carefully through the actual regulations themselves on it. So I’m very impressed, Chair, that you’re—

Well, it's the way I was elected, so I should know how it works. 

I don't know if that helps. I don't know if—.

There is a reflection, I think, around training costs, for example, for local authority electoral managers. It’s relatively limited and that is in part because the D’Hondt system is known to returning officers and—

And before I bring Rhianon in, the question then is—. You've talked about the single transferrable vote. I'm in favour of STV. I like that model. Was there a cost question around running STV as opposed to D'Hondt, or was it more of a policy decision that it was—?

It was purely that that was the recommendation of the special purpose committee, so therefore that is what we have worked on and translated into the legislation. And you're also right, aren't you, on the fact that, of course, what we're doing is basically extending the existing regional list system structure to, basically, the whole of the election.

Rhianon.

In regard, then, to the mandate of this committee and our scrutiny of where we're at at the moment, as you're all very well aware, the financing and the cost of this Bill itself, and the cost of the reform itself, is already a political hot potato. So, my question is: at what point will we be doing a repeat of this in terms of our analysis of where we're at? Because there's a lot of known unknowns, aren't there?

Sorry—could you just say the last bit? At what point—?

At what point are you going to be coming back to this committee to do a rerun of where we're at?

I think the appropriate stage for that will obviously be during the stages of the legislation if there are further changes that we know about that we can then evaluate and add further information to. It may be that, for example, some of the imponderables, particularly the boundary pairing and so on, won't be known until the new boundary commission has been not only legislated for, but also carried out its work, so bringing it closer to the actual election itself. But, of course, the whole purpose of this legislation and others is that it has to be completed and in place quite a period of time ahead of the elections themselves, for the conduct Order and then compliance with the Gould convention as well. 

Thank you. You've talked about percentage savings. If you make a small change, then, obviously, it'll pay for itself. Might the way to model that saving be better looking over the twenty-odd years since we've been here and the cost of judicial reviews? Is that something that's factored into your modelling at all?

What's interesting is that the Bill provides for a review, but a very early review, and that would be probably more to do with how the elections operated, the systems that were in place, the electoral system and so on. But certainly, as time goes on—and it will be a number of years—you want to begin to look back and try to evaluate broadly the improvement to governance of the Senedd. And I think it's from that that you can begin to extrapolate—.

I think it may be difficult to ever say, 'This decision was taken and this resulted in that particular amount'. But that is exactly the same, for example, with businesses. You look at the improvement in terms of the democratic process, the accountability, the scrutiny and so on. You do assessments of those, how those have worked, but you also look and do an extrapolation as to how you think that has improved the utilisation of public funding. And I think from that you'll be able to make certain assumptions in terms of, 'We think this has resulted, actually, in an improvement of this type'.

But it is very much a retrospective one, isn't it, it's looking back over—. And it might well be that it's something that will start being done before the 2030 elections, and again between the elections after that. So, it's something that I think all parliaments should be doing in any event, but I think the changes actually provide a basis for that to happen, and to expect it to happen. 

That's fair enough. There are two parts to the next question. We've talked about potentially new ministers and we've also talked about the boundary commission and we've talked about new commissioners there. In your modelling there, have the costs for additional secretariat been involved in that? I suppose the read-across then would be for Ministers. Minister, you've got two officials with you today. Would there be an increase in that support staff that you might have, and secretariat staff that you might need to discharge your duties, other than the expertise of the rest of the civil service, if you like?

The boundary commission, obviously, is a body that operates completely independently of Government. Within the assessment there are obviously transitional costs of £42,000 that are there, and there is, obviously, the cost of the boundary reviews that will be taking place—so, the work that goes on, of course, in terms of the pairing, but then the subsequent boundary reviews that are incorporated within that. 

The RIA does include, for the local democracy and boundary commission, the cost of additional commissioners, but also the cost of additional staff—or rather the staff required to deliver on the boundary review—some of which, as you said, Chair, are opportunity costs and some are actually requirements for additional staff.

Okay. Peter.

I think it's quite difficult for a lot of people to understand where the costs are for the boundary review, with the pairing side of things, because the boundary commission have already done their work on creating parliamentary—. So, I'm struggling to understand why that will be 2025 and why it incurs a huge amount of cost. Now, I can see there will be more to do the permanent, for the following election, but I don't think it's very helpful for the process to wait until 2025.

It's obviously not going to be reviewing the boundaries per se, it's the pairing, isn't it, that they will be doing. Because for this, for 2026, we're using the parliamentary boundaries that are now established. The election after that—. Sorry, eight years—. Sorry, the election after that, for 2030, it would be a review, which allows some review of the boundaries within, I think, a 10 per cent margin. So, that would be, obviously, substantially more work. But, over to you, Will, on that.

Yes, and, just to say, I think the difference is for the—. The review ahead of the 2026 election is a streamlined review, but it is undertaken in a much shorter time frame, whereas, the full review that would follow the 2026 election, the annual costs are lower, but, actually, it's over a three-year period as opposed to over a single-year period. The Bill obviously requires the boundary commission to undertake certain steps, including public consultation, and so the costs are associated with that step as well as obviously the work to actually pair for 2026, and then, obviously, a much more detailed exercise.

It's just that a lot of us are struggling to understand where the complexity is on the pairing element—it could happen relatively quick; I could do it tomorrow, sort of thing. But I think, you know, understanding the complexity—

There are criteria, I think, that they have to take into account, but, you're right, it is a much more straightforward process.

Is it more of a desktop exercise, or will there be consultation?

There is a requirement in the Bill for consultation.

Consultation. Okay. And when—? Remind me when it's meant to report by.

Once the legislation is passed, it's officially empowered to actually do the pairing, but the pairing has to be by a particular date, doesn't it?

The final report needs to be before 1 April 2025.

Right, okay. And finally from me, and we're coming up to time: we heard some evidence from the Commission, from Manon Antoniazzi and Ken Skates—last week, I believe—around how they'd gone about doing some of the modelling for you on travel and the cost of running the Commission and the associated cost with 36 new Members. Some of the questions there were with regard to travelling expenses, and it was linked a little bit to what those pairs might be and that element. I suppose it's more of a comment than a question, or to get confirmation, that, as this Bill matures and goes through the processes and gets closer to understanding where those pairs might be, would you rerun that exercise to work out how much travelling was involved. Because, obviously, you've got 40 Members—and I think it was Mike's point, and I'll bring Mike, as well, into this—that 40 Members currently travel within a small geographical area; 20, like myself, travel across a wider area. I'll be travelling less, in theory—shorter distances—but Mike might be travelling more, and that sort of thing. Is that some of the—? Those modellings would need to be matured through.

Can I just carry on from that? I don't charge for travel in the constituency. My constituency is about six miles across, and I treat that as my place of work; I'm sure a large number of other Members do exactly the same thing. But with the new huge constituency of Cwmtawe, Brecon and Radnor, which stretches from Presteigne to Lower Brynamman and Gwaun-Cae-Gurwen, if you decide to merge that, the only two logical places to merge it with are Monmouth or Ceredigion. Any Member who represented Monmouth, like Peter would probably hope to do, would probably want to charge for travelling to Gwaun-Cae-Gurwen because it'd be a substantial journey; the same with anybody living in Aberystwyth, who'd want to also charge and also go in the other direction.

So, I think that if you do go ahead with these merged constituencies, which I am fundamentally against, but that's a political view rather than a financial view, there will be a substantial increase in Members' expenses in large parts of Wales, including Arfon and Ynys Môn, where people probably don't charge for going around Ynys Môn, but, if you add in Arfon and Aberconwy, all of a sudden their journeys are getting 20 and 30 miles.

No, I think that's—. Listen, that's an element and that's a matter I'm sure the Senedd will do. It's one of those unknowns that, once the pairing is known, you'll know where it is. It also, I suppose, depends on where people actually live, where they actually are within the constituency and so on. But, as I say, it's a work in progress, and I'm sure, equally, we will be wanting to look at and to hone any figures that we have on the best information that is available.

Yes, thank you very much. That brings us to time. Thank you so much for your time this morning. Obviously, as usual, you'll have a transcript of proceedings that you'll be able to just check for accuracy for us.

So, I propose, in accordance with Standing Order 17.42, that we resolve now to exclude the public from the remainder of this meeting. Is everybody okay? Yes. We'll do that, thank you. Diolch yn fawr iawn.