1.         How the Welsh Government should legislate to put sustainability and sustainable development at the heart of government and the wider public sector


            The Bill is a good starting point.  However, other areas of legislation may conflict with the achievement of the goals and this must be considered.


            Legislation on its own will not be effective; a comprehensive programme will need to be put into place to educate and inform the public and future generations about the goals and how they can be best achieved.  However, considering the ongoing funding cuts that public bodies are facing, this approach could be compromised by bodies’ inabilities to allocate appropriate resources (human and financial) to effectively supporting any meaningful change.


            Welsh Government will also need to consider how a shrinking Welsh public sector will impact on future health, well-being and poverty to Wales.



 2.        The general principles of the Well-being of Future Generations (Wales)           Bill and the need for legislation in the following areas:


·                     The “Common Aim” and “Sustainable Development” principle established by the Bill and the “Public Bodies” specified


            The only concern is how the purpose of the Act will be met in a real and meaningful way without the robust collection of data (protected characteristics) that clearly demonstrates improvement of well-being for all communities in Wales.


·                     The approach to improving well-being, including setting of well-being goals, establishment of objectives by public bodies and the duties imposed on public bodies


                        Whilst the common aims as defined are considered valid, the whole approach is confusing.  It may be clearer to allow the public sector to agree ‘common objectives’ for their area for inclusion in the well-being plan rather than each member body deciding their own and providing themes on which the plans could be based; therefore, building a common partner approach to local needs in delivering future well-being.




·                     The approach to measuring progress towards achieving well-being goals     and reporting progress


                        It is important to be able to compare success across all bodies and to be able to judge meaningful improvement across all sectors of society.  Therefore any metrics that are developed need to focus on outcome.


·                     The establishment of a Future Generation’s Commissioner for Wales and the Commissioner’s role, powers, responsibility, governance and accountability


                        Establishing a Commissioner is fine but it is suggested that the Equality & Human Rights’ Commissioner should also be included in the advisory panel.  However, it must be ensured that such a panel should not detract from the goals by promoting their own agenda but ensuring compliance and integration with relevant laws.


·                     The establishment of statutory public service boards and assessment of local well-being plans


                        The concept of public service boards is well embedded through the local service board approach; however the concept is further strengthened by the statutory member approach.  With regard to fire and rescue services, the legislation states that either the Chief Fire Officer, Chair of the Fire & Rescue Authority, or both, should attend.  This would mean the Chief Fire Officer/Chair having to attend 10 boards which will be extremely difficult to achieve.  It would be better to allow for a representative to be appointed by the Chief Fire Officer and either write the legislation accordingly or allow the Chief Fire Officer delegation to appoint a representative.  Such action will allow the Service to structure its approach to public sector bodies more effectively.


                        Careful consideration of extant legislation is also needed, such as the Crime & Disorder Act 1998 that establishes community safety partnerships, and how these structures will integrate with the public service boards.



3.         How effectively the Bill addresses Welsh international obligations in relation to sustainable development


            Whilst it is acknowledged that we have an impact beyond our border and that the Welsh Government contributes to the network of local government for sustainable development, it is only when we have success within Wales can we truly influence others.  The goals of this Bill and what it is intended to achieve in Wales should not be compromised by what needs to be achieved internationally as this will often be outside of our control or area of major influence.


4.         Any potential barriers to the implementation of these provisions and whether the Bill takes account of them


            The Bill is not specific enough.  It is unclear on how the objectives are to be achieved and it may be better to introduce themes around which the plans can be framed.  It is also unclear how organisations will be audited with regard to their compliance with the provisions of the Bill.  Also, how are public service boards going to be audited on their collective contribution to improving community well-being across a large regional or sub-regional area?



5.         Whether there are any unintended consequences arising from the Bill


            There is potential conflict with other pieces of legislation and there is also potential conflict from other national initiatives that are taking place/being proposed.


            The role of conflicting structures will need to be considered: regional collaborative boards, existing community safety partnerships and city regions.



6.         The financial implications of the Bill (as set out in part 2 of the explanatory memorandum and regulatory impact assessment, which estimates the costs and benefits of implementation of the Bill)


            Whilst the explanatory memorandum explores many cost options, it is not clear how accurate these costs are.  It must be remembered that the Welsh pubic sector is facing unprecedented cuts to budgets and are engaging with communities over multi-million pound cuts to their budgets to introduce requirements which effectively put extra burden on public sector bodies but may not be in the best interests of all at the moment.



7.         The appropriateness of the powers in the Bill for Welsh Ministers to make subordinate legislation (as set out in chapter 5 of part 1 of the explanatory memorandum, which contains a table summarising the powers for Welsh Ministers to make subordinate legislation)


            Whilst it may be sensible for Welsh Ministers to have these powers, the use of them will need careful consideration given the comments earlier in this response about budgets.


            Subordinate legislation and Welsh Ministers should establish the vision and allow local partners to develop delivery plans to secure the future well-being of individuals, families and the communities they serve.