Welsh Language Education Bill: an outline of costs and impacts

1. The White Paper sets out proposals for primary legislation to transform the way we think about the Welsh language and the role of education in this context, placing a clear and decisive focus on pupils’ linguistic outcomes. The White Paper also contains proposals that can be fulfilled without legislating, as part of the work programme. This document does not include the costs or effects of those proposals.
2. A regulatory impact assessment will be published alongside the Bill when it is introduced into the Senedd. This document outlines the initial considerations on the proposed provisions set out in the White Paper. It therefore presents the initial stages of gathering evidence to support an assessment of the costs, benefits and disadvantages associated with the proposed changes, and is a starting point that provides an opportunity to consider the types of costs that will arise and who will bear the costs, based on the current proposals. We are seeking views on these proposals. The nature of the provisions means that the information on costs, benefits and disadvantages will continue to develop as these provisions change in light of the feedback on the White Paper.
3. Where financial costs are included, they are based on the expenditure budgeted for 2022 to 2023. These costs are included as proxies to the types of information that will be included in the final regulatory impact assessment and are not commitments to future expenditures as the development process is still ongoing.
4. This document does not include the costs of the wider programme to support Welsh language education provision. Rather, reference is made only to the costs of the associated legislative requirements, which have been declared in the White Paper.

5. The proposals will have a different impact on different groups. Those included in the document are divided as follows:
6. The main beneficiaries of the proposals: pupils and parents.
7. Operating partners: The groups of individuals or organisations responsible for implementing the provisions: These include maintained schools and nursery classes, including Pupil Referral Units and special schools; practitioners in these sectors; local authorities; regional education consortia; initial teacher education providers and in-service training providers.
8. National strategic operating partners: The groups of individuals or organisations responsible for implementing the provisions at a strategic level: Welsh Government, Estyn, Qualifications Wales, the National Centre for Learning Welsh.
9. A number of bodies and partnerships are supporting individuals on their journey along the Welsh language skills continuum, from the initial provision by Mudiad Meithrin to the continuity of learning through the medium of Welsh within further and higher education, with the support and guidance of the Coleg Cymraeg Cenedlaethol.

10. The proposals within the White Paper and their impact are divided as follows:
     
11. Making the target of a million Welsh speakers by 2050 a statutory target and making provision for a linguistic outcome for learners through the education system

• Place the target of one million Welsh speakers on the face of the Bill so that it has a statutory basis.
• Place a duty on local authorities to work towards achieving a linguistic outcome at the end of statutory education by 2050, that all pupils can speak Welsh with confidence, and as a minimum at a level that is synonymous with level B2 of the Common European Framework of Reference for Languages (CEFR).

12. Lifelong Welsh language skills continuum

• Place a duty on the Welsh Ministers to publish the Welsh language skills continuum.

13. Categorising schools according to language-medium

• Establish a statutory system to categorise schools according to language-medium.
• Give the Welsh Ministers powers to specify statutory descriptions for each category, including the minimum time for Welsh language provision. 
• Local authorities to approve the language category of maintained schools in their county, and to monitor that the requirements of that category are met.
• Place a duty on maintained schools to publish a plan detailing how they intend to increase Welsh language provision, and the relevant timeline
• Seek views on how a local authority should decide whether a newly established school should be a Welsh-medium school.

14. Statutory National Plan for the acquisition and learning of Welsh

• Place a duty on the Welsh Ministers to produce a National Plan for the acquisition and learning of the Welsh language.
• The Welsh Ministers to set targets for the number of teachers it is estimated that will be needed to facilitate the growth in Welsh language education. 
• The Welsh Ministers to set targets for increasing the number of learners who receive Welsh-medium education. 

15. Welsh language in education planning within local authorities

• Reform the system of Welsh in Education Strategic Plans (WESPs).
• Change the name of the WESPs to Welsh in Education Implementation Plans (WEIPs) which will set out how the local authority will operate to meet the target(s) set by the Welsh Ministers in the National Plan.
• The Welsh Ministers to set targets in the National Plan for all local authorities to increase Welsh-medium provision.
• Place a duty on local authorities to review their WEIP after 5 years in compliance with the 5-year progress report of the National Plan.
• The Welsh Ministers to commission an external review of the content of a draft WEIP before proposing modifications, when they consider it appropriate to do so. 
• Place a duty on local authorities to set 10-year targets in their proposed WEIP, and review them every 5 years, for increasing the number of practitioners able to teach through the medium of Welsh.
• Place a duty on local authorities to set 10-year targets in their proposed WEIP, and review them every 5 years, for increasing the number of practitioners with Welsh language skills based on analysis of the relevant data in the School Workforce Annual Census (SWAC).
• Local authorities to publish their annual review reports.
• Place a duty on the Welsh Ministers to publish a national report of progress against the targets in the National Plan every year. 
• Estyn to be given a function, at the request of the Welsh Ministers, to conduct a rapid review and provide recommendations in situations where there appears to be a risk that an authority will not achieve its targets.

16. Duty on local authorities to proactively promote Welsh-medium education

• Place a duty on local authorities to promote Welsh-medium education to parents and carers.
• Seek views on the idea of placing a duty on local authorities to promote late immersion education to parents, carers and pupils. 
• Seek views on the idea of placing a duty on local authorities to provide late immersion education for pupils.

17. Support to realise the objectives of the Bill

• Centralise specialist support for lifelong Welsh language learning, including school education, within a single organisation.
• Consider expanding the role of the National Centre for Learning Welsh, or another model, to undertake the role.
• Consider placing a duty on the Welsh Ministers to guarantee that sufficient Welsh language learning provision and suitable structures are in place to support learners of all ages in Wales.

• Place the one million Welsh speakers target on the face of the Bill so that it has a statutory basis.

• Local authorities to work towards achieving a linguistic outcome at the end of statutory education by 2050, that all pupils can speak Welsh with confidence and as a minimum at a level that is synonymous with level B2 of the Common European Framework of Reference for Languages (CEFR).

Cost

18. Putting the target of a million Welsh speakers on the face of the Bill would mean placing the target that already exists within the Cymraeg 2050 strategy on a statutory footing. No additional cost is anticipated as a result of doing this. The cost of fulfilling the duty is dependent on the other proposals outlined in the White Paper, and an initial outline of these costs can be found in the remainder of this document. However, there would be a cost incurred by Estyn to undertake a review of the performance of a local authority (detailed in paragraph 84).
19. The proposal has implications with regard to how learners' progression up to level B2 will be interpreted, understood and assessed. This will need to be further explored and understood as the proposal is developed.
20. The cost of setting a goal for local authorities to work towards enabling all pupils leaving statutory education to speak Welsh with confidence, and as a minimum at a level synonymous with CEFR level B2, would be covered by the costs of the proposals outlined in this document.

Benefits and disadvantages

21. These proposals support the vision of the Cymraeg 2050 strategy, and the first strategic theme of 'increasing the number of Welsh speakers’. Over time, the proposals would expand access to the Welsh language to pupils in Wales.
22. These proposals provide a strong statutory basis for organisations’ reasoning behind their decision-making across the education field.
23. In fulfilling the outcome that all pupils are aimed to achieve by 2050, this could lead to a wider range of opportunities for pupils both in terms of employment and in their daily lives. 
24. In the long term, the proposals would provide context to the improvement expected in workforce skills, including the education workforce, with more pupils entering the workplace with better Welsh language skills.

• Place a duty on the Welsh Ministers to publish the Welsh language skills continuum.

Cost

25. There would be no familiarisation or operating costs for schools.

Welsh Government costs

26. The work programme to develop the continuum would be undertaken by existing Welsh Government officials, so this would be an opportunity cost for Welsh Government.
27. Costs would be incurred by the Welsh Government to produce the proposed document that would define the continuum. There would be no additional financial outlay, but this would be an opportunity cost. The document would offer detailed descriptions to describe a pupil’s language journey along a lifelong Welsh language skills continuum. The document would be produced internally by Welsh Government officials, with the support of a Task Group. This would be part of the work of an existing Welsh Government SEO officer:

28. There would also be a cost incurred by Welsh Government to consult on this document with experts in the field of Welsh language acquisition and learning.

Benefits and disadvantages

29. This proposal would provide context for way that all Welsh pupils learn Welsh, improve their Welsh language skills and progress on their language journey, whatever the language-medium of the school they attend and in whichever area they live. The proposal supports the Curriculum for Wales requirement for all schools to teach Welsh.
30. The proposal could contribute to laying the foundations for designing a lifelong Welsh language learning provision. Not only would it contribute to learners, teachers, parents and employers' understanding of the journey to learn Welsh and the expected linguistic outcomes at each stage of that journey, but it would also be established as a universal method of identifying Welsh proficiency by policy makers and employers among others.

• Categorising schools according to language-medium Give the Welsh Ministers powers to specify statutory descriptions for each category, including the minimum time for Welsh language provision.

• Local authorities to approve the language category of maintained schools in their county, and to monitor that the requirements of that category are being met.

• Place a duty on maintained schools to publish a plan detailing how they intend to increase Welsh language provision, and the relevant timeline.

• Seek views on how a local authority should decide whether a newly established school should be a Welsh-medium school.

Cost

Welsh Government costs

31. There would be administrative costs incurred by the Welsh Government for developing categories, and also for creating guidance for schools on how to go about determining their language category. These costs would include consulting on the guidance. The guidance would provide clarity on the data to be used to determine the language category, any considerations that should be made, and any processes and timescales that must be followed. This would be done by an existing official, and so it would be an opportunity cost.
32. There would be a cost incurred by Welsh Government for an official to create regulations to determine the details of the categories. We assume this would be the cost of an SEO officer for a period of 6 months. Based on an SEO salary for one year (£66,364), this would cost £33,182. This would be done by an existing official so it would be an opportunity cost.

School costs

33. There would be a cost incurred by schools as a result of increasing a proportion of each week devoted to Welsh language provision, in line with the school's language category and with the aim of moving towards a higher language category. This would include:

• Training for school leaders
• Training to upskill staff
• Supply costs for staff

34. along the school categorisation continuum. The Welsh in Education Grant which is currently part of the Education Improvement Grant (a total of £6.7 million due to a contribution from Welsh Government and match funding from local authorities) and the Welsh Language Professional Learning Grant (£2.5 million) are allocated annually to the local authorities and/or consortia to support a number of activities that support the Welsh language. These include funding provision for latecomers, providing training to support practitioners in the Welsh-medium sector and supporting the teaching of Welsh in English-medium schools. In line with the Welsh in Education Workforce Plan, we are reviewing the funding currently available to support the provision of professional learning opportunities and support for the implementation of WESPs to establish clear funding streams and outcomes. This work is currently ongoing. Additional funds will be invested over the next 3 years to implement the scheme. A total of £1.845 million will be allocated in 2022 to 2023 (an increase of 1 million) with further increases of £500,000 in 2023 to 2024 and £2 million in 2024 to 2025. This funding will be prioritised to support the objectives of the scheme, which include workforce training.
35. Other funding is also prioritised to support the linguistic development of the education workforce, such as the Sabbatical Scheme and the National Centre for Learning Welsh courses. In addition, funding is dedicated to supporting growth in the number of Welsh and Welsh-medium teachers through the Transition Plans and Initial Teacher Education incentives. Local authorities do not receive this funding, but this funding will help them to make their plans a reality. 
36. There would be work for school governing bodies to determine the language category of the school every 5 years, in discussion with the local authority. Governing bodies already do this annually under the current system.
37. According to this proposal, schools will have a duty to produce a delivery plan outlining how they will go about increasing their Welsh language provision.

Local Authority costs

38. Local authorities would have an approving role for determining school categories, and in order for them to do this, they would need to have a clear picture of the language position of each school in the county. This would include voluntary and foundation schools. The process would take place every 5 years. Local authorities would fund this as part of their school support package.
39. There would be costs for local authorities to monitor that a school is:
    • providing education according to the assigned language category
    • making progress towards the target that has been set for it, in terms of progressing within a category or moving to a higher category
    The basis of this monitoring would be the delivery plan that each school would prepare. We would expect the school and authority to discuss the plan on a regular basis.
40. As part of this, there will be discussions between governors, school leaders, teachers and parents and local authority officials about schools' delivery plans, and how they will go about increasing their Welsh language provision. Local authority officials working on the WESPs are already expected to do this, so it would be an opportunity cost.
41. There would be no requirement to build new schools in response to this proposal, so this would not incur an additional cost.

Costs for Estyn

42. Estyn would consider a school’s delivery plan when inspecting schools in accordance with the normal inspection cycle. This would take place as part of activities Estyn already undertakes. This would not incur an additional cost.

Benefits and disadvantages

43. This proposal would lead to more pupils in statutory education across Wales receiving more Welsh language provision. It would do this by improving pupils' access to Welsh-medium education in whichever area a pupil lives and ensuring that Welsh language provision in all schools gives pupils opportunities to develop their Welsh language skills. It could create more cohesive communities as pupils across the country improve their Welsh language skills. This in turn would be intended to increase opportunities for people to engage and communicate with each other in Welsh, in formal and informal contexts, including the workplace.
44. In the long term, the proposal would contribute to upskilling the workforce, including the education workforce, due to more pupils entering the workplace with better Welsh language skills. 
45. Compared to the current non-statutory arrangement, statutory categories would provide a firm basis to monitor schools' performance in fulfilling their category requirements, and would provide a clear context for the progress targets that will be set out in the Welsh in Education Implementation Plans.
46. The proposal could lead to a more consistent approach and a common understanding across local authorities about school language categories.
47. Non-statutory guidance on school categories was published in 2007 and new non-statutory guidance in 2021, so the further change could be an additional burden on stakeholders.
48. The proposal could give governing bodies the impression that their power is being reduced and that a category or target to move to a higher category is being imposed on them against their will. There would need to be clear arrangements for transparent and open discussions between local authorities and school governing bodies.

• Place a duty on the Welsh Ministers to produce a national statutory plan for the acquisition and learning of the Welsh language, and for it to be reviewed in each Senedd term.

• The Welsh Ministers to continue to set targets for the number of teachers it is estimated that will be needed to facilitate the growth in Welsh language education.

• The Welsh Ministers to set targets for increasing the number of learners who receive Welsh-medium education.

Cost

49. There would be an administrative cost for Welsh Government to create a National Plan for the acquisition and learning of Welsh every 10 years, to be reviewed in each Senedd term. This would be an opportunity cost, as it would be part of the work of existing officials over a 6 to 18 month period, including scoping and consultation. 
50. It is anticipated that the following resource would be required:

51. In addition, there would be a time investment engaging with other officials within Welsh Government, along with the time of a Deputy Director.
52. There would be a cost for carrying out analyses of the data in order to set national targets for local authorities. It is likely this work would be carried out in-house by Welsh Government officials. It is envisaged this would mean a fortnight’s work each for two SEO officers (at a cost of £66,364 each per annum), and two days of a Grade 7 officer’s time (at a cost of £86,731 per annum).

53. The costs of implementing and monitoring the plan are included in the Welsh language in education planning within local authorities section.

Benefits and disadvantages

54. This proposal would support the Cymraeg 2050 aim for creating ‘a statutory education system which increases the number of confident Welsh speakers' by providing strategic direction and clear leadership to local authorities about their expectations in relation to increasing their Welsh language provision. It would create a link between the target of a million speakers and local authorities' Welsh in Education Implementation Plans. The proposal would be a response to the message that has been given in county education forums by local authorities about the need for Welsh Government to set the strategic lead in the field. The proposal would also present to local authorities and the public a more comprehensive picture of the expectations on local authorities in terms of increasing the percentage of pupils learning through the medium of Welsh.
55. The proposal would create a single coherent system of learning and acquiring the Welsh language, bringing together all elements and ensuring that all partners in the field are working towards one goal. It would provide guidance to those providing support to the education system in the acquisition and learning of Welsh, thereby laying the foundations for facilitating the language journey for schools and pupils in Wales.
56. The proposal would see learners, regardless of age, able to continue to learn and improve their Welsh skills on a lifelong basis.
57. This may, in time, contribute to the tackling poverty agenda by equipping pupils with Welsh language skills who may not have had the opportunity of developing them without this proposal. As a result, those pupils may be able to apply for jobs where the Welsh language is desirable or essential, thereby opening up a sector of the labour market to them which would otherwise have been closed.
58. This proposal would contribute to promoting the Welsh language in all areas.

• Reform the system of Welsh in Education Strategic Plans (WESPs)

• The Welsh Ministers to set targets in the National Plan for all local authorities to increase Welsh-medium provision.

• Change the name of the WESPs to Welsh in Education Implementation Plans (WEIPs).

• Place a duty on local authorities to review their WEIP after 5 years in compliance with the 5-year progress report of the National Plan.

• The Welsh Ministers to commission an external review of the content of a draft WEIP when they consider it appropriate to do so.

• Place a duty on local authorities to set 10-year targets in their proposed WEIP, and review them every 5 years, for increasing the number of practitioners able to teach through the medium of Welsh.

• Place a duty on local authorities to set 10-year targets in their proposed WEIP, and review them every 5 years, for increasing the number of practitioners with Welsh language skills, based on analysis of the relevant data in the Annual Census of the School Workforce.

• Local authorities to publish their annual review reports.

• Place a duty on the Welsh Ministers to publish a national report of progress against the targets in the National Plan every year.

• Estyn to be given a function to conduct a rapid review and provide recommendations in situations where there appears to be a risk that an authority will not achieve its targets.

Cost

59. The costs of local authority’s existing plans are divided into three parts, falling to the Welsh Government and local authorities:

• Welsh Government administration costs
• Local authority costs - costs involved in the preparation of plans and costs of implementing the plans

Welsh Government costs

60. Local authorities would be required to submit their draft plans for approval, and the plans would be subject to annual monitoring once approved. This would involve the deployment of staff to oversee the submission of plans and to undertake the approval and monitoring process.
61. Welsh Government has administered the Welsh in Education Strategic Plans system since 2013, and so has a firm evidence-based understanding of the staffing levels required to deal with the system. The tasks undertaken by Welsh Government staff include assessing each individual draft plan, providing written and verbal feedback to local authorities, receiving and responding to updates on progress and revisions, and advising Ministers on the content of plans, and on progress made in monitoring review reports. Three full-time equivalent (FTE) SEO officers and one FTE Grade 7 officer are deployed to work on the plans. The current recurring annual staffing costs are as follows:

62. There would be an administrative cost for Welsh Government to develop guidance for local authorities on how to detail and analyse the language skills of the education workforce. The development of guidance is already taking place in collaboration with local authorities, and is a small part of the broader work of officials, it would be revised as needed. This would therefore be an opportunity cost.
63. Under the proposal, the Welsh Ministers will publish a national report of progress against the targets in the National Plan every year. This work would be carried out by Welsh Government officials, and so there would be no additional expenditure, but this would be an opportunity cost. It is anticipated this would involve a fortnight’s work each for two SEO officers, and two days of a Grade 7 officer’s time.

64. In summary, therefore, there would be opportunity costs associated with approving and monitoring plans.
65. The Welsh Government's costs in setting targets in the National Plan regarding increasing Welsh-medium education are discussed in the National Plan section (see paragraph 52).
66. As a local authority goes through the process of consulting on a plan and submitting it to Welsh Ministers, according to the proposal, the Welsh Ministers would be able to commission an external independent review of a draft proposed plan. This would be done in specific circumstances, where they consider, following an assessment of the plan, that it would be beneficial to receive an independent external opinion, before deciding whether to approve, approve with modifications or refuse to approve.

Local authority costs: Cost involved in the preparation of plans

67. Local authorities allocate officer time to prepare and submit Welsh in Education Strategic Plans currently, and to respond to feedback from Welsh Government. Officer time is also allocated to support the implementation of the plans in the local area. As a rule, this is not a full-time officer role within local authorities. On the basis of Welsh Government’s experience of dealing with local authorities since these arrangements were put in place, we estimate it entails the time of an FTE SEO officer in each local authority for a period of approximately four months per year.
68. Local authorities are under a duty to publish their plans. They tend to do this on their own websites and may print copies on demand if required. The associated costs are minimal, and most local authorities do not routinely publish hard copies of their plans.
69. The recurring annual staffing costs for local authorities in relation to the preparation and implementation of plans are estimated to be as follows:

70. Under this proposal, local authorities would review their implementation plans every 5 years. Current local authority officials would be expected to do this, as they would have done with their 10-year plans. Operating costs falling to local authorities would be covered by their current support packages. Welsh language in education planning is part of the education role of local authorities, and therefore it is appropriate for costs relating to the Welsh language to be part of any local considerations regarding how to prioritise education budgets. Since 2019, Welsh in Education Strategic Plans have been a means of seeing how local authorities respond to national expectations. The 10-year plans have represented a move to act on the basis of targets calculated by local authorities, but that are also driven by the milestones within Cymraeg 2050. The proposal in the White Paper, therefore, does not offer substantial changes to what local authorities have already considered as part of their current WESP preparations. There are commitments in place to continue to provide additional finance for the Welsh language, to support local authorities to implement their plans.
71. Local authorities already have a duty to produce annual review reports under the current system. This would continue under the new system. In addition, under this proposal, local authorities would be expected to publish their annual reports. Similarly to the publication of the current WESPs, the associated costs would be minimal.
72. In relation to the education workforce proposal, costs would fall to local authorities in identifying individuals to undertake an annual process of analysing the data gathered through the Annual Census of the School Workforce (in order to set targets as part of the plan and monitor annual progress). However, it is already a requirement for schools to gather data and submit it to local authorities under the Education (Supply of Information about the School Workforce) (Wales) Regulations 2017. In addition, under the current WESPs, there is a requirement for local authorities to analyse the data, but this is done in different ways.
73. Local authorities would need to invest time in preparing the implementation plans, as they do for WESPs. In summary, therefore, we do not believe the White Paper proposals would impact the costs of preparing plans, as it would be a matter of introducing a new framework, rather than a significant change.

Local authority costs: Costs of implementing the plans

74. Once the plans are approved by the Welsh Ministers, they should be implemented by local authorities.
75. There are costs associated with increasing the provision of Welsh-medium education. These costs may include building new schools or running immersion centres. However, this should be regarded as expenditure on the education system rather than expenditure on delivering Welsh language policy. To a degree, expenditure on increasing Welsh-medium education provision displaces expenditure that would be spent otherwise on English-medium education. If a local authority creates places in Welsh-medium education in line with its plans to meet a target, but no-one applies for those places, leading to surplus places, there is a risk of additional costs.
76. Funding for statutory age education in schools in Wales, as for other services delivered by local government, is provided in the main by Welsh Government through the local government revenue settlement (the Revenue Support Grant). The funding is not ring-fenced specifically, as the Welsh Government considers local authorities to be best placed to judge local needs and circumstances and to fund schools accordingly.
77. The Welsh in Education Implementation Plans will assist local authorities in identifying needs and deciding how to plan their schools’ expenditure. Once the Revenue Support Grant has been distributed to local authorities, it is the responsibility of individual authorities to set budgets for their schools which are determined by a local funding formula. The School Funding (Wales) Regulations 2010 require 70% of funding for schools’ budgets to be distributed in line with one or more of the methods based on pupil numbers.
78. Authorities have discretion to distribute the remaining 30% on the basis of a range of factors so that they can take account of individual school circumstances. Local authorities may take into account in their funding formula whether a pupil is being educated through the medium of Welsh and fund schools accordingly, taking into account the costs involved in delivering the same service through the medium of the Welsh language.
79. Therefore, the duty to ensure that all suitable educational provision is made available to all children rests with local authorities, and the amount of funding each authority sets aside for school budgets is entirely for the authority to determine.
80. The Welsh in Education Grant (totalling £6.7 million through Welsh Government contribution and local authority match funding) is separate from the Revenue Support Grant and is allocated to local authorities or regional consortia to support the development of the Welsh language in schools. In some counties, it is spent on immersion centres or late immersion provision within Welsh-medium secondary schools. In other counties, it is mainly spent on supporting Welsh language learning in English schools, and training to develop practitioners in Welsh-medium schools. This funding would be expected to continue to be available to support practitioner development as well as the other funding allocated to other stakeholders to support practitioner language development and to increase the number of Welsh and Welsh-medium teachers (see paragraph 34).
81. Implementing Welsh in Education Implementation Plans and the associated costs should therefore be viewed within the wider context of funding the authority’s education system.
82. This proposal itself would not lead to authorities having to educate more children or appoint additional practitioners in the short-term, as it would not impact population or demographic trends. However, it would require planning in terms of how to move towards more Welsh-medium school places and more practitioners who can teach through the medium of Welsh, in order to meet the need over time.
83. Capital costs to support children with additional learning needs are absorbed through the Sustainable Communities for Learning Programme. Additional funding is also allocated to local authorities to support the findings of their reviews under Section 63 of the Additional Learning Needs and Education Tribunal (Wales) Act 2018, to improve Welsh language provision for people with additional learning needs and in relation to workforce planning within the additional learning needs sector.

Costs for Estyn

84. As the Welsh Ministers monitor the progress of local authorities against their target, if a pattern of underachievement appears over a period of time, according to this proposal, the Welsh Ministers would be able to make a request to Estyn to undertake a rapid review of the local authority and make recommendations to the local authority and/or Welsh Ministers on the steps that should be taken. The estimated cost is £23,500 per year.

Benefits and disadvantages

85. This proposal would improve clarity on requirements between the Welsh Ministers and local authorities. The Welsh Ministers would plan national progress in Welsh-medium education on a strategic level, and local authorities would demonstrate how they are planning and working to make it a reality.
86. This proposal would improve transparency in relation to setting targets, collecting data and agreeing on plans.
87. This proposal would expand pupils' access across Wales to Welsh-medium education, whatever area of Wales they live in, and increase the number of pupils developing Welsh language skills. This proposal would offer inclusive opportunities in terms of accessing Welsh language provision which, in turn, could lead to improved community cohesion across Wales.
88. Increasing the number of Welsh-medium schools could allow pupils to stay in their communities and reduce the need to travel.

• Place a duty on local authorities to promote Welsh-medium education to parents and carers.

• Place a duty on local authorities to promote late immersion provision to parents and carers.

• Seek views on the idea of placing a duty on authorities to provide late immersion education for pupils.

Cost

89. Imposing a duty on local authorities to promote Welsh-medium education and to provide and promote late immersion education would impose duties in relation to objectives already articulated in Cymraeg 2050. No additional cost is anticipated as a result of doing this. To fulfil these duties, local authorities would use funding they already receive from the Welsh Government for Welsh language provision through the Education Improvement Grant or the Revenue Support Grant, outlined in paragraphs 34 and 76 to 78 and 80.
90. Also, the Welsh Government is investing £6.6 million of revenue funding over the course of this Parliamentary term to support all local authorities to develop or expand their late immersion provision. Local authority late immersion provision has been funded through the Education Improvement Grant or the Revenue Support Grant, so this revenue funding offers local authorities the opportunity to repurpose the funding from the Revenue Support Grant to support new schools where appropriate.
91. The Welsh Ministers provide £106 million annually to provide home to school transport. Some local authorities use this allocation to fund pupils travelling to immersion centres or to school.

Benefits and disadvantages

92. These proposals lay a strong foundation for local authorities to make ambitious decisions about Welsh-medium education.
93. These proposals would support parents and carers to understand the options available to them in terms of the language of their children's education.
94. Placing a duty on local authorities to provide late immersion provision would reassure parents and carers that the provision will be available, whether the Welsh Government were to fund through a grant or not. It would ensure that pupils have access to Welsh-medium education at various entry points.

• Centralise specialist support for lifelong Welsh language learning, including school education, within a single organisation.

• Consider expanding the role of the National Centre for Learning Welsh, or another model, to undertake the role.

• Consider placing a duty on the Welsh Ministers to guarantee that sufficient Welsh language learning provision and suitable structures are in place to support learners of all ages in Wales.

Cost

95. The cost of the proposal in relation to centralising support for Welsh language learning would depend on the nature and form of the body that would be developed to increase the specialist support available in acquiring and learning Welsh. There is further work to be done concerning this proposal. We will consider which model is most suitable, and an assessment of the relevant costs and benefits of options will be part of this work.
96. The proposals concerning centralising support for learning Welsh have been formulated with the intention that they be realised outside the scope of the Bill.
97. There will be costs for the Welsh Ministers that are associated with the proposals to ensure that there is sufficient Welsh language learning provision available to support learners of all ages in Wales; and to ensure that suitable structures are put in place to support the learning of Welsh. We will consider costs, benefits and disadvantages when undertaking further work to consider the extent of any duties placed on the Welsh Ministers.

Please note: The numbering of these questions follows on from the questions asked in the main consultation document.

• Consultation Question 30: Do you agree with our interpretation of the groups and bodies affected by the changes? Are there any other groups or bodies that fall within the scope of the changes apart from those identified in the outline of costs and impacts that will form the basis of a Regulatory Impact Assessment for a Welsh Language Education Bill?
• Consultation Question 31: Apart from the groups and bodies identified in outline of costs and impacts that will form the basis of a Regulatory Impact Assessment for a Welsh Language Education Bill, which groups or bodies could have to pick up the costs?
• Consultation Question 32: What other impacts (both financial and non-financial) are there relating to the proposed legislation that are not outlined in the outline of costs and impacts that will form the basis of a Regulatory Impact Assessment for a Welsh Language Education Bill?
• Consultation Question 33: Are there any other comments on the outline of costs and impacts that will form the basis of a Regulatory Impact Assessment for a Welsh Language Education Bill?

• Davies, S. (2013) One language for all: Review of Welsh second language at Key Stages 3 and 4: final report. Cardiff: Welsh Government.
• Estyn (2021) Her Majesty's Chief Inspector's Annual Report 2021-2022. Cardiff: Estyn.
• Morris, S. A rapid review of the National Centre for Learning Welsh. Cardiff: Welsh Government.
• Welsh Government (2018) Effective second language teaching approaches and methods: rapid evidence assessment Cardiff: Welsh Government.