Update of integrated impact assessment following the end of the 17-day firebreak in Wales

Over the course of the coronavirus pandemic, the Welsh Government has published a number of assessments of the impact of measures to manage the virus. On 22 October, Welsh Ministers decided to put in place a number of enhanced ‘firebreak’ measures for a short time period, with the aim of rapidly reducing the rate of transmission and bringing the virus back under control. Read a summary integrated impact assessment, (IIA) of these measures.

This document is intended to be read alongside the evidence presented in the firebreak IIA.

When the firebreak ends, there will be a new set of national Regulations. The principal measures in these Regulations are as follows:

• At home, including in the garden, people will only be able to meet others from their extended household, and an extended household will be limited to just two households coming together.
• Anywhere else, only four people (not including those aged under 11) can meet indoors or outdoors, except where more than four people from the same household are together
• Up to 15 people (not including those aged under 11) will be able to take part in an organised indoors activity and up to 30 (not including those aged under 11) in organised outdoors activities, providing all social distancing, hand hygiene and other Covid safety measures are followed.
• Schools will reopen in full from next Monday.
• All business premises, which have been shut since October 23 will be able to reopen on November 9.
• There will be no travel restrictions inside Wales but during the month-long lockdown in England, travel will not be permitted outside Wales without a reasonable excuse.

Duty to self-isolate

• A duty will be placed on employers not to knowingly enable or encourage people to work when they should be self-isolating. Employers knowingly not allowing an employee to isolate may be issued with a £1,000 fine.
• A failure to self-isolate by an individual, if required to do so will be an offence which will be enforced by a standard FPN of £60 for a first offence and then escalating. In addition, providing false information to contact tracers or once notified to isolate about your isolation address and the members of your household will incur the standard £60 FPN.
• Subject to eligibility, a self-isolation support payment of £500 will be made to people who are required to self-isolate with a positive test or a close contact of someone who has a positive test, who cannot work and will lose income and suffer hardship as a result. 

The primary harm the Welsh Government is seeking to mitigate is in relation to direct harm from COVID 19: protecting public health and preserving life. The decision to implement a firebreak in Wales was based on scientific evidence and advice produced in the light of the worsening public situation in the UK and Wales. The UK Government Scientific Advisory Group for Emergencies non-pharmaceutical interventions (NPI) paper suggested that a firebreak would mean any resumption in the epidemic’s exponential growth after 9 November would be from a significantly lower level than would have been the case without the break. This assumption was on the basis of good adherence to measures, and no additional increase in contacts before or after the break.

Whilst the package of measures agreed for implementation between 23 October and 9 November infringed on many of the European Convention on Human Rights articles, this was considered proportionate in seeking to preserve life. The severe restrictions for households and widespread closures in the economy struck a balance between protecting public health and the social, financial, economic and well-being harms caused by the restrictions. Tighter restrictions during this short period were intended to reduce the need for further restrictions, although this could not be, and cannot be ruled out.

Broadly speaking, the new national measures introduced on 9 November will have a positive economic, social and equality impact in comparison to the firebreak, easing some of the negative effects described in the firebreak IIA. These included:

• Negative impacts from the ‘stay at home’ measures in respect of women and children experiencing abuse; exacerbated feelings of loneliness and isolation for many sections of the population; and disproportionate impacts on the lives of disabled people, BAME people and women
• Negative impacts from business closures in particular in term of the economic impact on people who earn less than the Welsh median. The sectors required to close will have had a disproportionate impact on particular groups such as women (close contact services and non-essential retail), BAME (hospitality and transport services) and younger people (hospitality)
• Negative impacts in terms of the disruption - particularly on protected groups - to the learning of older children and young people, years 9 and above who were not in secondary school or FE (unless for the purposes of sitting exams)

It is however important to note that there remain strict limitations on what people can do after the firebreak comes to an end – and those limitations impact differentially. Fundamentally, over the winter period we must all live our lives differently. We must all keep our contacts with others to an absolute minimum, keep our circle of friends and people we meet as small as possible and consider whether it is necessary to meet face to face, or whether we can meet in another way. This will continue to have negative socio-economic and equality impacts. 

Household mixing

In general terms the decision to allow the formation of extended households promotes equality as it will enable people to develop an additional and often mutual support base. The restriction allowing the formation of an extended household with only one other household is considered proportionate in order to manage the wider public health risk and keep coronavirus transmissions as low as possible. Although not exhaustive, the following impacts have been identified:

• An ability to form extended households will benefit all age groups, mitigating effects of loneliness and isolation (a particular issue for younger people) or digital exclusion (for older people).
• However, people over 70 may be concerned about increased risks to them from a greater mixing of people and those at higher risk might feel pressure to join extended households to provide care and support (e.g. elderly grandparents; BAME people).
• Conversely feelings of loneliness may be exacerbated for some if they are excluded from the extended households they wish to form.
• Extended households will provide valuable additional care and support and this could be positive for women in particular, who often take up a disproportionate burden in terms of caring[1]. Extended households could be of particular benefit to low income households struggling with childcare or care needs.
• It is acknowledged extended households work well for some families, for example parents and grandparents, while creating some challenges for families having to choose between two sets of grandparents. It also works less well for any individual or family which has more complex relationships or on anyone whose primary social interaction and support is through a network of friends

Gatherings outside the household, excluding organised activities

Enabling four people to gather outside or in a regulated setting will help to mitigate against some of the negative impacts on household mixing described above and will have a positive impact, particularly for children and young people. Not being able to see friends was cited as the single thing which had an impact on how children and young people felt in the Coronavirus and Me survey.

The following impacts have been identified:

• All businesses, as regulated settings, will be subject to a range of requirements in legislation to enable them to operate in a Covid-safe way. These measures allow businesses to be open and to serve groups of four however it is acknowledged that they come with one-off and ongoing additional costs. They also constrain businesses’ ability to operate as they normally would, reducing their output and profitability and changing the demand for staff. In a few cases this has provided new opportunities but the much more common experience, particularly in public facing sectors like non-essential retail, tourism, hospitality and entertainment, has been negative. In the sectors we expect to be significantly impacted we will see a disproportionate impact of certain groups: younger workers (especially in hospitality), women (especially in close contact services and non-essential retail) and BAME people (especially in parts of the hospitality sector and in transport services including taxis.) In the earlier stages of the pandemic, disabled people were more likely to be furloughed and this pattern may be repeated.
• People on lower incomes will be less able to afford to go out to a café, restaurant or pub.

Organised activities, (up to 15 indoors; up to 30 outdoors)

Whilst organised activities will be possible after the firebreak, activities will be subject to a range of requirements in legislation to enable them to operate in a Covid-safe way. Numbers should be kept as low as practicable, and the activity should take place on-line where possible. However, allowing these varied activities should contribute to reducing loneliness and isolation and improve physical and mental well-being. The face to face element may be particularly important for vulnerable groups, as many cannot access on-line groups for a variety of reasons including digital exclusion.

Reopening places of worship

Places of worship were closed during the firebreak and this will have had an adverse impact on some people with religious or other beliefs. Reopening places of worship should therefore have a positive overall impact on well-being.

Travel

Rather than being required to stay at home, there will be no travel restrictions inside Wales. During the month-long lockdown in England, travel will not be permitted outside Wales without a reasonable excuse.

Whilst this will have a positive impact on well-being for many, restrictions on travel will continue to have negative equality impacts. These arise from constraining the locations where people access services and recreation and in many instances it will mean restricting people from meeting family and friends if they live in other parts of the UK or abroad. It is anticipated this may have an adverse impact on BAME people, who have close family and extended family living in other parts of the UK and overseas. 

Businesses re-opening

Enabling businesses to re-open and trade will have positive economic and social impacts and will ease some of the negative cumulative impacts of coronavirus control measures described below.

As set out above, there will still be limitations on operation and extra costs which will fall on certain businesses and the people they employ. These will not be evenly distributed across the economy or the population. In particular:

• BAME people are disproportionately represented in a number of the sectors which have been adversely impacted by the control measures parts of hospitality and transport. The Resolution Foundation found that, while more than half of those furloughed during lockdown had returned to work by September, 9 per cent of those previously furloughed had lost their jobs. This rate was highest for 18-24-year-olds, Black, Asian and minority ethnic workers, and the low paid. There may also be particular adverse impact on BAME businesses that sell specialised cultural foods – such as ethnic cuisine who already struggle to maintain customers because of the scarcity of food products.
• There is also evidence[2] that the economic costs of the control measures are impacting on disabled people disproportionately.
• There will be negative impacts on young people as a result of the medium and longer term economic consequences of efforts to control the virus in terms of their employment and earning opportunities.

Working from home

Working from home is more likely to be an option for those working in an office and in higher paid occupations. It will not be available to all and for many lower paid occupations – retail, care work, close contact services and hospitality it is acknowledged it would not be an option. For those working at home, disparities include: lack of space to work at home either because of the size of home or having to share with others; cost and reliability of broadband; additional heating and lighting bills, particularly over the winter period.

Self-isolation

The duty to self-isolate and connected duties on employers will help to disrupt transmission of the virus, and would mean protecting others, particularly those who are most vulnerable from being exposed to COVID-19 and the potential severe impacts it could cause (for some, this could mean avoiding likely death). The £500 payment is designed to support those on a low income or in precarious employment and to enable compliance with the duty. The following impacts of the duty have been identified:

• There is good evidence from the earlier part of the pandemic that the additional caring responsibilities arising from the pandemic, including childcare, fall disproportionately on women. It will continue to be the case that children will be asked to self-isolate when there are cases in schools and based on the first lockdown, looking after children and supporting them to learn, if there is remote learning taking place, will fall more to women than to men. 
• For pupils required to self-isolate, blended learning (a combination of on line learning and face to face teaching) is not regarded as a comparable substitute for face to face teaching and would impact disproportionally on more vulnerable and disadvantaged learners. However, self-isolation enables in person education for those not self-isolating continue in a controlled, safe manner. Having TTP amongst other measures in place means we can prevent onwards transmission within educational establishments ensuring continuity of schooling for the majority.
• For BAME people in particular, the use of their information to check compliance with the duty is an important issue of trust and confidence in public authorities. The Welsh Government is engaging with the Information Commissioner’s Office to ensure this is undertaken appropriately and fairly. Welsh Government will ensure that enforcement bodies see the minimum amount of data required to carry out their functions, and this will be shared in line with data protection legislation including GDPR.
• For businesses, the duty to self-isolate will have a positive impact in terms of disrupting further transmission at the workplace, leading to less sickness absence. However, the duty will cause short term staffing issues where large numbers of staff are asked to isolate at the same time.
• Self-isolation will help prevent significant risks to the NHS and wider public services becoming over-run which, would lead to further loss of life.

Reopening of schools and other educational establishments and the broader impact on children and young people

The right to an education is one of the core principles of the UNCRC. While the Coronavirus and Me survey showed that the majority of respondents were confident about their learning in the initial lockdown, only 11% of respondents aged 12-18 said they were not worried about their education. The greatest concern reported (54%) was of falling behind in their learning. Re-opening of schools and education is therefore a priority for the Welsh Government following the firebreak.

The benefits of a high quality education for all children and young people cannot be overstated. There is clear evidence that disrupted learning, blended learning and remote learning will have a disproportionate, negative impact on some children, in particular children from lower socio-economic backgrounds, disabled children or children with additional learning needs and BAME children. Even if they are able to access learning via a digital device, other practical barriers in terms of the availability of space, other demands on their time (e.g. caring for younger siblings), lack of specialist support they would have in school and the capacity and capability of their families to help them with school work will negatively impact on their ability to learn. In respect of other services for children after 9 November:

• Maternity and perinatal services will continue, with access to health visitors and wider support services in place. This will include running breastfeeding classes and parent and child classes, both to support maternal perinatal mental health and ensure young children are seen and their development assessed to enable early intervention as required. Broader support services via Flying Start will also resume, including face to face support, where it is in a covid-safe environment. This will help to reduce the impact on child development
• Access to childcare, and particularly Flying Start childcare will continue. Formal, registered, childcare covers children aged 0-12, though the bulk of provision in terms of both places and hours of care provided is for children in their early years. All childcare settings are required to work to the principles of the Foundation Phase, even where they are not early education providers, supporting early learning and development. Regular attendance at childcare also support socialisation and allows for early identification of developmental delay, as well as enabling parents to work.
• Access to extra-curricular and organised activities will restart. This includes sporting activities, but also a wide range of cultural, educational and development activities. Examples include attendance at dance, drama and sports clubs, as well as support groups for young carers and children with additional needs, learning disabilities or complex health needs.
• Play facilities, including outdoor playgrounds and indoor play areas, will remain open and accessible, in line with the child’s right to play set out in the UNCRC and enshrined in Welsh law. This should include access to parks and open places, public pitches and courts and a continuation of street play where it is safe to do so. For older children the expectation is that Youth Services would remain operational, providing safe spaces for children and older young people to meet, socialise and gain support as needed.

Environmental impacts

There is likely to be an overall negative environmental impact following the fire break due to an increase in travel, as only essential journeys were allowed during the fire break. In the week ending 29 October, road traffic, bus and rail receipts decreased as a result of it being half term and the fire break. Road traffic decreased by 18 percentage points compared to the previous week and stands at 54% of the levels seen on 13 March. This remains higher than a weekday low of 35% which followed the stay at home announcement back in March (Covid-19 Data Monitor 2 November).

[1] Women are the majority of those providing care, paid and unpaid and the majority of health workers and are more likely than men to deliver unpaid care at home (Women’s Budget Group, Covid-19: Gender and Equality Issues)

[2] Citizen’s Advice’s report: An Unequal Crisis (England & Wales) states that of the 1 in 6 (17%) of the working population facing redundancy: 

1 in 4 disabled people (27%) are facing redundancy, rising to 37% for those people whose disability has a substantial impact on their activities

1 in 2 people who are extremely clinically vulnerable to coronavirus (48%) are facing redundancy

2 in 5 people with caring responsibilities (39%), either for children or vulnerable adults, are facing redundancy