Gareth Williams Clerk Constitutional and Legislative Affairs Committee Ty Hywel National Assembly for Wales Cardiff Bay CARDIFF CF99 1NA
	Our ref:        CE/SGJ/R12
	Date:            30^th June 2014
	Direct Dial:   01352 702107
	E.mail Address: Chief_Executive@flintshire.gov.uk

Dear Gareth

Consultation on Welsh Assembly Law Making

Thank you for the opportunity to provide a consultation response.

Solace Wales is the Welsh branch of the Society of Local Authority Chief Executives and Senior Managers (Solace).  It is the professional society for senior strategic managers working in local government in Wales.  Solace is a UK wide organisation with over 1700 members representing the most senior managers in local authorities. 

Solace aims to give added value in consultations by providing strategic comment. We avoid replicating the more detailed and operational consultation feedback provided by professional groups; on this particular consultation there will be detailed responses from governance and legal senior lead officers from across the local government community. Solace would concur with the more detailed response made by the Welsh Local Government Association.   

Solace has one over-riding concern to share on the impact of new legislation on the reducing resource base available to local government during a period of austerity.  This subject would best fit under the first consultation question on policy development.

The process for assessing the resource impacts of new legislation, both within the executive and the legislative functions, is in its infancy. The system of Regulatory Impact Assessments (RIAs) is under-developed and Solace would support a more forward planned system of assessing the resource requirements of intended legislation both at the publication of legislative programmes, and in the researching and drafting of individual pieces of legislation (within Bill Project Boards) themselves. In informal discussions between Welsh Government officials and representatives of Solace and the Welsh Local Government Association the need for a more robust and evidential approach to resource forecasting has been recognised.

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Where a need for resources is demonstrated, Welsh Government in partnership with local government should together be considering whether the provision of a new resource or a redirection of resources would be required, as a priority, as the resourcing solution. Local government has long held a position that new initiatives should be funded to ensure that their policy intent is achieved. It has been contested that some recent legislation which is considered by the National Assembly for Wales to be largely cost neutral will, in reality, introduce costs pressures. It is not in the public interest that social policy, implemented through legislation, is ‘set up to fail’ through inadequate resourcing. This is no more so that in the current fiscal climate where there is diminishing resources for flexible and creative action.

Solace proposes a fuller evaluation of the RIAs system leading to a more robust and evidential system of resource mapping and planning for legislation. As a Society we would willingly contribute to this evaluation.          

Yours sincerely

Colin Everett

Chief Executive Portfolio Lead on Finance and Corporate

Colin Everett, Honorary Secretary

SOLACE Wales / Cymru

SOLACE Cymru