Lesley Griffiths AM

Minister for Local Government and Government Business

Welsh Government



29 July 2014


Dear Minister


Gender-based Violence, Domestic Abuse and Sexual Violence (Wales) Bill


At the Committee meeting on 16 July the Committee considered the financial implications of this Bill.  The Members had a number of queries which we would appreciate your views on.


Attached at annex A is details of the areas we would like a response on.  I am also sending a copy of this letter to Christine Chapman AM Chair of the Communities Equality and Local Government Committee.


Yours sincerely,


Jocelyn Davies AM



Annex A


Additional funding in the Welsh Government budget

The Draft Budget 2014-15 narrative document noted an increase in the revenue allocation to the Domestic Abuse action for 2014-15 and 2015-16 by £0.3 million to ensure the strategic direction and approach to funding in this area is grounded in a sound understanding of the current landscape of provision in this field and ensure the spending is aligned to support the implementation of the forthcoming Bill.

Given that the additional costs to the Welsh Government for each year from 2015-16 to 2017-18 range between £0.4 million and £0.5 million, it would be helpful to have clarity on whether the additional funding allocated is sufficient to meet the requirements of the legislation, particularly given that the implementation of the Act is anticipated to lead to a further increase in the number of clients accessing public and specialist services, and possible additional costs in excess of those included in the RIA.


Costs associated with Local Government reorganisation

The costs contained within the Bill on Local Strategies are based on the current position of 22 local authorities, and are split between local authorities and LHBs. If there were to be mergers of authorities following the response of the Welsh Government to the Williams Commission, this could have two potential impacts. Firstly, there could be a short-term increase in costs as the new authorities will be required to develop new strategies, while over the long term it is possible that there would be fewer authorities, and therefore fewer individual authorities incurring costs.

It would be beneficial to know whether newly merged local authorities would be required to produce new strategies, and what assessment of the potential costs of this before 2017-18 has been made.


Statutory guidance

There are a number of areas where the Welsh Government may wish to issue statutory guidance following the Bill coming into force, although the RIA states that it is not clear exactly which aspects guidance will be issued on. Therefore the costs in this section of the RIA are based on example draft guidance in a number of key areas that has been prepared by the Welsh Government.

It would be useful to understand whether the Welsh Government is able to update the Committee on the areas it intends to issue guidance on, and whether there will be any additional costs associated with this.



Opportunity costs of National Training Framework and Ask and Act

The largest costs in the Bill are the opportunity costs to public sector bodies of £5.6 million between 2014-15 and 2017-18. As stated earlier, these do not represent a direct financial outlay by any organisation and will not be met by the Welsh Government, but are the opportunity cost based on the time commitment of undertaking the training under the National Training Framework or Ask and Act.

It is not clear from the RIA what the opportunity cost of not undertaking this training is, or what the level of benefits of undertaking the training is.

In order to assess the value for money of this part of the Bill, it would be helpful to ascertain whether any assessment has been made in these areas, and whether the Welsh Government believes that the benefits of this training outweigh the opportunity costs.


Subordinate legislation

The costs to the Welsh Government associated with supporting implementation of the National Strategy include administrative costs associated with the three other elements of the Bill. These include the development of guidance on Local Strategies, the National Training Framework and Ask and Act, as well as engaging with the Ministerial Advisor and managing consultations.

It therefore seems likely that costs associated with the five powers to make subordinate legislation contained within the Bill will be covered by this area; however it would be useful if you could confirm this.