Finance Committee

Right, let's move on, then, to item 3. Item 3 is the financial implications of the Food (Wales) Bill, the evidence session with the Minister and her officials—or her official. I'd like to welcome you, Minister. Would you be able to, for the record, just introduce yourself and your official? That would be great.

Yes. Thank you very much, Chair. I'm Lesley Griffiths, I'm the Minister for Rural Affairs and North Wales, and Trefnydd. I'm joined by David Lloyd-Thomas, who's head of the food policy and strategy unit.

Okay, lovely. Well, croeso cynnes—welcome. Thank you for making time to come and talk to us this morning.

I'd like to start by exploring how realistic the costs included in the regulatory impact assessment are to deliver a sustainable food system in Wales, and the potential replication of Welsh Government's future community food strategy. Do you feel that the total costs outlined in the RIA of the Bill are realistic to deliver a sustainable food system for Wales? And do you think that the RIA covers all the related costs?

Thank you. Well, I think the Bill does fall well short of delivering a sustainable food system, so the costs really bear no relation to whatever might be needed to create a completely sustainable food system. What we do think is the Bill would create an additional system of public body planning and reporting with the Welsh food commission, which the Bill suggests would be playing an advisory role. I think the costs that are presented in the RIA are estimates for the new planning and reporting functions that various bodies would have to undertake, and that includes the new commission, but they do not include the cost of executing whatever actions might be identified in the plans coming forward. So, that approach, of that planning and target setting, is really a framework—it's not actual action. So, all the costs action itself would entail—. So, I think it really falls well short of delivering a sustainable food system in itself.

Importantly, I think it's also worth noting that the Bill only focuses on part of the food system, and that's the role of public bodies. Important though that is—I absolutely accept that—some perspective is needed in considering the food system, what that might include and what might change. You have to look at this from a UK perspective, really. It's a very important role of food businesses in the food system, but it is done across the UK. It's completely integral, and particularly, if you think about international trade, you have to do it on a UK basis.

So, if you think about the food that's bought in Wales, probably 98 per cent of it is bought in our major retailers, from our major retailers. So, I do think the cost in the RIA does really underestimate the likely cost to the Welsh Government and other public bodies. My officials—and obviously David is with me today—the work that would be involved in creating a national food strategy, the targets, establishing a commission—it would be absolutely significantly more than is estimated. I think my paper that I've given to the committee really makes that point, and provides the example of the resource that's needed to create our current strategic vision for the food and drink industry. That costs about £195,000 a year, so I think you can see that the cost in the RIA really is underestimated. I understand that a lot of the costs are based on the Scottish Government's Good Food Nation (Scotland) Act 2022, which I think—. Peter has put this food Bill very similarly to the Scottish equivalent. But I know my officials work closely, obviously, with their counterparts in Scotland, and the latest information we've got from Scotland is that more resources are being used—human resources—to commence the Act and prepare for the plans going forward. So, I think we would find that the costs are underestimated. I would certainly think public bodies also would also find that it's more resource-consuming as well, and I do wonder how detailed Peter's conversations have been with local authorities and with health boards, because those same bodies may seek considerably more support from the food commission that Peter's proposing, and also from the Future Generations Commissioner for Wales, for instance. So, I don't know how detailed his conversations have been.

Okay. Thank you very much. Given that a lot of Welsh Government Bills go over the estimate, and, obviously, we see them all come through here and then, looking at when they're implemented, that they cost considerably more, why should a potential underestimation of costs be a barrier to you supporting this Bill?

The cost is important, and that's why I've pointed out in the paper that I gave to committee where I thought the costs were underestimated. But I think the bigger issue for me, and certainly for Welsh Government, is that the Bill—. We don't believe it's necessary, but not on the basis of cost. There are lots of issues why we don't think the Bill is necessary, and that's because of the legislative framework, particularly, that we have here in Wales that we don't see in other countries, and that's obviously the Well-being of Future Generations (Wales) Act 2015. So, I do accept that cost estimation of Bills is a very inexact science. For me, the more fundamental issue here is not the money.

Okay. Thank you very much. Rhianon. There we are.

Thank you. Can you hear me, Chair?

Yes, we can. Thank you.

Thank you, and thank you, Minister, for your responses so far. We've mentioned within the programme for government, I believe, the intention to develop a Wales community food strategy. So, has there been, to date, a cost analysis of those plans and, if so, how does that compare with the costs set out in this RIA?

So, no, we haven't done a cost analysis, or cost-benefit analysis, as yet. The work that we've done so far on the community food strategy—and, unfortunately, that work has had to be stopped because David Lloyd-Thomas is working on this at the moment and is also working on the community food strategy—but what we had done, probably over the previous year, we'd been looking at what the strategy might focus on—so, talking to my ministerial colleagues, because the community food strategy will be cross-Government piece of work. We want to start co-designing policy options with stakeholders. So, there's a lot of planning to do ahead of doing a cost-benefit analysis.

Okay. Would there be in your view, or in David Lloyd-Thomas's view, if he was, in a sense, seconded to work on this proposed piece of work—? Do you feel that there would be aspects of this Bill that could potentially duplicate the food strategy? And if so, in regard to that cost-benefit analysis comment, which do you think would present the greatest value for money, bearing in mind your comments that I wouldn't mind drilling down into around the legislative framework? Which would present the greatest value for money?

So, the community food strategy is, as I say, in development, and that is a specific programme for government commitment. It was in our manifesto and we are taking that forward. We've also got the Welsh Government's strategic vision for the food industry, which I announced—I was going to say last year, but I think it was 2021, actually; time goes quickly. That's much more about having a clear vision and mission for our food and drink sector; it replaces the previous action plan we had from 2014 to 2020, which delivered significant benefits for our food and drink industry here in Wales. So, that strategy, I think, is where you could have more of a comparison, rather than the community food strategy. It's really important that we support our food and drink businesses and that we help them take the message of Welsh food and drink out to the world, with our trade visits, et cetera. But also it's really clear that the strategic vision we have for the food and drink sector joins up with other policies, and that's what we are concentrating on, going forward. So, having that strategic vision, and having other Welsh Government policies to tackle other aspects of food, such as the community food strategy, is where I think we will get better value for money.

Thank you. So, you're being quite clear, in terms of cost, that you think that it would be more than on the RIA basis, as a result of this Bill. Do you feel that the basis for the costs is an accurate reflection of the role Welsh Government would perform? I think, from your previous answers, it's 'no'. And you've mentioned public bodies and health bodies would potentially find this more costly. How have you engaged to work out that position with health bodies, or even the Member himself?

Obviously, it's the Member's proposed Bill; it's a Bill that Welsh Government isn't supporting, so it's not for me to engage with the local authorities and health boards; that is for Peter to do. And as I said earlier, I'm not sure how much of that engagement he's had. I think, if you look at the calculations, they do appear to be broadly correct, but I think, if you put the technicalities aside, it's around does the RIA capture the scope and size of the workload—so, the human resources—that the Bill would create. I do think—I've already said—I do think that it underestimates significantly the human resource level. And I think that one of the things that I could talk about—. I suppose I've just mentioned to you about the Welsh Government's strategic food and drink vision. That took officials to work on that for a significant amount of time, and probably cost around £195,000 a year. So, again, it's considerably more than has been suggested that the food Bill would take of Welsh Government officials' time to implement the Bill. So, I go back to what I said about the Scottish Government: this Bill—and Peter would be the first to say—is very much based on the Scottish Government's good food nation Bill, which has now become an Act. And my officials talk regularly to their counterparts, and they know from that that it is taking far more human resource than was anticipated.

Thank you. Chair, I do want to ask a further question around the commentary around the legislative framework and the Well-being of Future Generations (Wales) Act 2015, but I'm not sure if others will be doing that. Thank you.

Carry on with that one if you want, and then I'll bring Sam in.

Yes. So, in terms of the cost element that we've discussed, you've been very clear, Minister, in that regard, but you've also mentioned that the other reasoning would be around the fitting in within our legislative framework, and you mentioned the future generations Act. Can you flesh that out, in terms of this committee's understanding of why you feel this would be incongruent within that?

Well, as you know, the well-being of future generations Act requires our public bodies—and Welsh Government obviously as well—and that includes, obviously, local authorities, health boards, to look at the well-being goals, the targets that have been set within any policy or piece of legislation. You have to look at that before you bring that policy and legislation forward. So, to me, this is just another layer. So, if you've got the food commission requiring the same things, it's just duplication, and, as you know, Rhianon, budgets are incredibly tight at the moment—there is no spare money for anything. So, I just think we already have that legislation, which, obviously, Scotland haven't got. So, I think that's one of the reasons why—. I hate duplication in any form, and I just think it's going to be a massive amount of duplication, for us as a Government, and, if it's a huge amount of work for us as a Government, it will be the same for public bodies.

So, it's the duplication point. Okay. Thank you, Chair.

Thank you. Sam.

Thanks, Chairman. Morning, Minister; I appreciate your time this morning. We know the estimated costs of this are between £3.8 million and £7.5 million over the five-year period, and you've already mentioned things like the food and drink vision, which already costs the Government about £195,000 a year—I think that's the number you mentioned. I wonder whether you could clarify whether these additional costs outlined in the Bill would impact on the future funding of other food-related programmes, and how you would see that impact.

Yes, it would impact on the future funding of things that we're doing, or things that we're planning to do as a Government, unless I had an increase in my budget, and I don't see that happening any time soon, with the pressures our budgets are under. To be absolutely fair, yes, it would have an impact.

I think the costs are of two different types, if you think about it. First is the cost in terms of officials' time that would be spent on implementing any new duties that came forward from the Bill. They'd have to make the regulations, which would establish them, and then we'd have to create a national food strategy. And of course, the Welsh food commission would have to be established as well. I've already said that I have one official working on this piece of work; he's also the same official who's working on my community food strategy, which is really important to me. That's a programme for government commitment, on a manifesto I stood on, so that's a really important commitment that's had to be put to one side. So, it's happening now, let alone if the Bill went forward.

I think you need to look at the costs as opportunity costs and also cash costs. On the opportunity side, because officials would be spending time doing new things, they wouldn't be able to do other things that are priorities for me. I've just given you an example about the community food strategy. But also, and this is really important to me, we'd have to run fewer events. As I say, we take Wales out to the world. We've got Gulfood coming up the week after next. Things like that might have to stop. I've always had a focus, since I've been in this portfolio, on making sure we attend international trade events. That work might also have to be slowed down as well.

There are also the cash costs, as I referred to. A Welsh food commission is estimated by Peter at between £750,000 and £1.5 million. If we'd have to meet that cost, that would have to come out of my food budget. And so, if you think about a big event, like BlasCymru, which we hold every other year—I would love to hold it every year, but there are cost resources, and there are also human resources in doing that, so we hold it every two years—I may not be able to hold that. And as I say, I'm sure I would have to reduce my international trade events as well.

Thanks for that, Minister. You've mentioned a number of areas or initiatives there that are currently active within the Welsh Government in relation to food policy. Perhaps there's a risk that some of those are acting in silo, because of the number of initiatives and the number of areas it covers. Do you think you've got a handle on the total cost of food policy delivery to you?

I don't think it's possible to estimate the resource completely, but I don't think it's because work is in silos. We're a very small Government, if you like, so officials talk to each other. I don't think there's a silo, in the negative sense. But I do think that food issues are very, very complex, and they're relevant to lots of policy agendas. I think the community food strategy—the early work that David's done on scoping that—has shown us just how much work is going on across Government that could fit in to the community food strategy that, perhaps, when we started to think about it, hadn't crossed our minds.

But obviously, I can tell you about my food division, and that's absolutely at the core of food and drink policy in Welsh Government. That is the food division, which sits in my portfolio. My food division is a very small team—there are only 44 posts. And that might sound a lot, but when you look at what we deliver in relation to food matters—. They manage a budget of just over £7 million, and those 44 posts cost £2.5 million. We do have some additional funding as well, which we get from the rural development programme. Beyond the food division, there are obviously officials working on the foundational economy, fisheries, agriculture, poverty, trade, health issues, public health issues. So, there are lots of officials working across Government, but, obviously, the food division is the core team. So I think it's very hard to then estimate the costs in the way that you suggest.

Perhaps just one more point, Mr Chairman. Again, thank you for that, Minister. Obviously, you have a concern with the cost of delivering the Bill here, and obviously as the Finance Committee, that's what we're focusing on. I wonder, even if the cost was zero, would you still have the same concern?

Yes, I would, because one of the earlier questions from the Chair was, 'Why should the cost be a barrier?' I tried to explain that it's not the cost that's the main barrier for me; it's the fact that I don't think we need a piece of legislation to do what Peter Fox is suggesting his Bill will do. Because we've already got the legislative framework there—I mentioned the Well-being of Future Generations (Wales) Act 2015 primarily being the piece of legislation we already have—but we also have the other policies. There's a lot in Peter's Bill that are really good suggestions, and I'm very happy to work with Peter to take it forward on the policy side. So, even if the cost was zero, because that's not my major concern, yes, I would still have the other significant concerns.

Thank you, Sam. I know Mike will probably want to follow that last point as well, but if I may—and I'll bring Mike in afterwards—you've talked a fair bit this morning about David taking time out from the substantive role, if you like, to look into this Bill. With your abhorrence of duplication, how much of that work can he use in the substantive role, if you like? Or is it completely null and void and there's nothing that he'll be able to use going forward? Maybe it's more of a question for him rather than yourself, if he's willing to answer.

I'll let David answer that one.

Hang on. Let's just unmute David, please. There we are. Lovely. Thank you.

Thank you. Can you hear me okay?

Yes. I think we've got a bit of an echo, but I think we can cope.

Fine. Clearly, there's a relationship between the community food strategy's development and the Bill in terms of they're both about food, but the Bill is essentially a framework Bill, creating a planning and reporting system. And so, I think, largely, in terms of work I've been doing in supporting the Minister on this Bill, it is fairly exclusive from anything we would do on the community food strategy. Because the sort of work that officials do in this Bill-work situation is essentially about scrutinising the Bill, understanding what it involves, what the implications would be, and then preparing the briefing and doing the analysis of different aspects of it. None of the Bill is specifically about community food itself, although you can see in theory there could be a connection in terms of what the food goals ultimately might be and what a national food strategy might be about.

[Inaudible.]—think, 'Actually, they're very good ideas, let's borrow them and put them into any strategies'? David or the Minister.

As I said, I'm very happy to look at some aspects of Peter's proposed Bill, and I've certainly had some good conversations with him on that.

Okay. Thank you. Mike, I know you might want to go a little bit further on that.

I do. I share the Minister's concern about the food commissioner. I think of the Future Generations Commissioner for Wales and what that's cost and how little, if anything, that's achieved. I have a view that, unless there's a specific reason for a commissioner, it is a complete waste of resources. But that's just a personal view.

Assuming there's some good in the Bill, some of which can be done at very low or zero cost, is there any possibility of the Minister carrying out some of Peter's suggestions by ministerial statement/letter or by incorporating it in future Bills or just generally promoting it? I mean, some of it doesn't actually cost any money, it's just promoting some good practice. I think that there are good things there; to throw the whole thing away now would be disadvantageous. But in terms of costs, can some things in there be done at low or zero cost, and the cost being, perhaps, the Minister writing a letter to appropriate people?

Yes, absolutely. Obviously, on the policy side, we are looking at that. As you say, these things don't cost any money, really, do they? That's something that we're looking at on the policy side, for sure. I mentioned the national food strategy—that's something that we can look at. We've already published community food case studies online, for instance. So, there are quite a few things we can do, Mike, going forward, I think.

Can you be more specific on naming one thing that you think is good in the Bill?

I suppose the national food strategy. I think we could certainly look at that.

Okay. Thank you. Sorry, Mike. Carry on.

If I can push on something I raised earlier, what can be done in there that you think is good, but just by ministerial action rather than needing a Bill? I think one of the great weaknesses we have as a Senedd, and dare I say Ministers as well, is we want a Bill for everything. I always remember that comprehensive education was brought in via a Department of Education and Science circular.

In my early discussions with Peter—. He wants better procurement, for instance, and I agree with that, so I don't think we would need this Bill to do that; we have other legislative frameworks—you know that we've got the procurement Bill coming forward. So, that's one aspect. And I think, again, the community food strategy could help with that. I think, for me, the big thing that I don't agree with in the Bill is the setting up of a food commission. I heard what you said, Mike, at the start, and I do think that that would really duplicate things. So, you've got the well-being of future generations commissioner, you've got the Food Standards Agency, which provides advice to the Welsh Government and to public bodies in relation to food matters in the way that Peter's Bill is outlining. I just think not only is there duplication, which is a waste, and we can't waste any money, I also think it could lead to some confusion and uncertainty going forward as well, and waste. I really do think that the commission probably is the worst aspect of the Bill, if you like. But, there's nothing to stop the Senedd looking at published strategies that we have and offering opinions. I'd be very happy to take forward any suggestions.

Did you have any more questions, Mike, or—?

No, just something that I will raise with Peter as well: I think that I will follow that advert, 'It's good to talk', and suggest that the Minister has further discussions with Peter about what can be carried out without actually having to pass a Bill. Would the Minister be happy to do that?

Yes, absolutely. As I say, I haven't met Peter certainly since Christmas, because obviously the Bill is now progressing, but I had some very good conversations with Peter, and he's doing this with the very best of intentions, I don't doubt that. But, obviously, this committee is looking purely at cost, and I don't think that money would be—. I would rather spend my money on holding BlasCymru and doing trade events, and realistically, unless my budget has a significant uplift—and I don't think that's going to happen any time soon—or we get a better settlement from the UK Government, which, again, I don't see coming any time soon, then I'm not going to be able to do everything. Obviously, I have my programme for government commitments that I need to fulfil, and there are ministerial priorities that I have as well.

Thank you. Just finally then, the local authorities and health boards would incur a total cost of between £0.9 million and £1 million across a five-year appraisal period. Do you think that the proposed benefits of the Bill would justify these additional costs? From your answers, probably not, but—

No.

There we are. Okay. Thank you.

Because I'm not convinced the Bill would create any benefits really, I don't think the cost is justified, and I hope I've explained why I think that. I think what we can be sure of is it would create costs for many other public bodies. I'm also very sceptical about the cost estimates, as you know, being accurate. I think they're underestimated both in human and financial resources, and, again, I'm not sure how detailed Peter Fox's proposals have been discussed with the public bodies. I think it would definitely be an increased cost on us, so I'm sure it will be the same. As I say, I'm not sure about those conversations and how detailed they've been. And I just think, if you look at local authorities and the health boards, they're already involved in public services boards, and they already contribute a lot in relation to food matters.

Just going to something you said a couple of minutes ago—and I'll finish on this—you said that you'd had conversations with Peter around procurement policy and that that was something that you were interested in and exploring. Do you think there's a benefit to having a target in place for local procurement?

A target?

Yes.

So, I'm a Minister who likes targets; not all Ministers do. And, obviously, I’m not taking the procurement Bill forward, but for me, targets—sometimes, they can give unintended consequences. But, I personally think that targets, when you look at the amount of Welsh food and drink that is procured by our schools, for instance, in school meals, and our hospitals and health boards, I certainly think that we need to increase it. Whether having a target—. Whenever you set a target or whenever you set a strategy or a policy, you need to look at where you want to be—what's the end game? Where do you want to go to? And if targets will help us get there, then certainly, I think it's worth looking at.

Yes, being aspirational and being able to have a goal of where you're going to, and not as a stick to beat somebody up with, it's more to do with having a driver to take things forward. So, I'd echo your thoughts there, because I very much come from a background of targets and things. But as you say, we're not talking about procurement so much here, but about food.

But thank you so much for your time this morning. There will be a transcript available for you to check through for accuracy. We're going to take a break now until 11:15, and then we'll have Peter in with us then.

So, diolch yn fawr. Awn ni i mewn i breifat.

Croeso nôl ar gyfer ein hail sesiwn ni y bore yma. Rydyn ni yma efo Peter Fox, y Member in charge o'r Bil.

It's good to see you, Peter, on that side of the table, rather than as part of the committee, but welcome. Would you be able to introduce yourself for the record and your officials as well, please?

Thank you, Chair. I'm Peter Fox, the Member in charge of the Bill. I'm joined by Tyler Walsh, a member of my support staff; and Martin Jennings and Elfyn Henderson, who are part of the Bill team that the Commission kindly wrapped around this process.

Wonderful. Thank you very much. As you'll be aware, there'll be a transcript available for you for this and translation is available as well. So, we'll move on to questions. I think we've got an hour or so with you, so we'll crack on. We've got a fair bit to cover. I'll start off the questions. Basically, we want to look, to start off with, at the engagement you've had with the Minister, and maybe you can reflect on what you may have heard this morning, if you were listening in to the Minister's session this morning. So, what engagement have you had with the Welsh Government when modelling the financial implications of this Bill?

Well, thank you, Chair. It's good to be with you today. This is a very important piece of work that we've been doing for some time, as you'll know, and we welcome the discussions that we've had with the Minister and her officials to date. I think, personally, there could have been a lot more engagement to help and work with us, but, as we heard this morning—. And I know, in the supporting letter that the Minister made available to this committee, she and the Government are minded not to support it, whatever. I think that concerns me, in many ways, that there is already a closed mind to something so fundamental, even prior to looking at all the evidence that has been taken by all of the committees. And that worries me, as somebody who has been a public servant for many years and sees the importance of scrutiny and challenge. So, I was disappointed, in many ways.

However, engagement has primarily been based on policy-related issues. So, as far as I can remember, there was no specific engagement with Welsh Government officials regarding costings or the final implications of the Bill. When I had meetings, they were generally policy related or to share concerns over elements of the Bill, such as the commission. As I said, the Minister has made her position clear, and she is not supporting the Bill. However, when undertaking work to cost the provisions of the Bill and the wider regulatory impact assessment, discussions were had with a variety of public bodies, including local government. And you'll know from the consultation responses that local government, health boards and many other people have been absolutely fundamental to the consultation and contributed to it and worked with us. It has been an amazing process of so many people connected with the food system right across Wales who absolutely see the need for what we're putting forward. And as you can note from the responses, 100 per cent of people feel there isn't a joined-up approach here in Wales, and the majority believe that there is a need for what we're trying to do.

Discussions were also had between members of the Bill team and officials of the Scottish Government working on the Good Food Nation (Scotland) Act 2022, and we're thankful for the interaction that we've had with them to help us through that financial side of things. I'm not sure if colleagues want to add anything further to that.

Yes. So, I suppose it was Welsh Local Government Association representatives; people like Food Sense Wales; Public Health Wales; Caerphilly county borough services, who are quite leading in this field; and the future generations commissioner's office as well; and NHS Wales Shared Service Partnership; the National Infrastructure Commission for Wales, when we were looking at different models; and then experts in the field as well. And I think what we've done is we've done more than just send out consultations; we've set up meetings to specifically talk through costs, ask for costs in cases, or advice and followed up on that advice.

So, you've estimated that the costs of establishing the food commission would be between £750,000 and £1.5 million annually. Can you explain why there's such a large range of costs, and does this reflect the uncertainty around the skill and scope of the food commission?

Yes, thank you, Chair. As we previously discussed, the Bill gives the Welsh Government adequate scope to set up arrangements flexibly within the framework of the Bill. I won't be the person who can enact this Bill, so, we've made it purposely in a framework and given the scope to the Ministers and the Government to shape the nature as long as it can achieve what the Bill sets out. This is because, as I say, we're designing legislation, but I can't implement it, so, it's not like a conventional bit of legislation that the Government would bring forward because they're enacting it. We've had to make it flexible enough for those partners to enact it.

We took a top-down approach to assessing the overall cost of the food commission rather than trying to build up an overall cost, based on detailed actions that the commission will undertake. It also reflects the Scottish Government—the work that they'd undertaken to estimate their costs of a food commission, and, as such, the costs have been modelled on different viable options, as you'll be aware: either a commission similar to the Scottish one or similar to other commissioner offices that currently exist, and that's where you get the variance of cost between what Scotland's costs were and what we know the average costs of what commissioners have worked out to be here in Wales. Again, I'll refer to the more technical elements of this—

Yes. So, is that why there's no detailed breakdown of the cost of the food commission in the RIA?

Yes. Do you want to, Martin—?

Yes. We talked to the Scottish Government officials who put together early on and then, late again, in the process the costings. And then, we also looked at the differences between the two commissions that were being proposed, and whilst the scope is slightly wider in Wales, the food sector in terms of value is about twice as big in Scotland and there are almost twice as many health boards and quite a lot more local authorities. So, it seems reasonable to be prudent. Peter's always saying, 'Don't underestimate the costs', so, we didn't want to go too low. And, as we say, we couldn't really build up the costs, so, I think, when there are discussions about where the work would fall and whether costs were underestimated, we haven't apportioned that cost, so, while it's being set up, some of the functions may be covered by the food commission or maybe seconded staff or Welsh Government staff or—.

It was quite interesting, I did listen in to the Minister's contribution, and I think somebody challenged her as to what the cost of the existing set of legislative frameworks, linked to food is, and the Minister said that they can't make that assessment. Well, it's very difficult—if the Government can't make an assessment of its own costs on what it's delivering already, it's very difficult for us to be prescriptive on every element of what this might cost.

Okay, thank you. So, given the significant resources required to establish and operate a food commission, why do you think it would represent value for money?

Well, taken as a whole, the Bill is intended to provide value for money by providing an opportunity for Welsh Ministers and public bodies to consider the policies and funding directed towards addressing food-related issues and whether existing resources could be better directed to meeting the Bill's wider objectives. There are a range of positive and social benefits that the Bill aims to provide. And I've said this a few times: this is such an important Bill, we believe, that we're bringing forward, because this effects change for future generations over many decades ahead. Benefits can't always be determined in financial terms, not immediately. The social benefits, the societal benefits, the health benefits can become quantifiable after a period, but without the pump-priming and the foresight and the groundwork and the foundations that you need to invest into that major shift, you won't be able to appraise fully the societal value for future generations.

And then, if we look just at the environmental opportunities, as well, of reducing the footprint of our food and those other benefits—. I know that the Minister was suggesting that this is very much focused on just the public sector and not the wider food situation; well, no, very clearly, it affects all parts outside of public bodies—the producers, the sustainable nature of how the food is produced and all the benefits that come to reducing and heading toward our net-zero targets. And not forgetting those wider issues that just need to be addressed, like food security, holistic food systems; things we haven't got, which have been very much a threat, because of some of those big issues that we're facing across the globe, with Ukraine and the implications to our food system through that, and how COVID made us very vulnerable. Some of those things have to be—. Sometimes in life, Governments have to retake, restock, and take stock, and deliver something for the longer term, and I think what we're giving the Government here is the perfect opportunity to create a framework to do that. And you perhaps may not have seen some of the contributions, but certainly, as Professor Terry Marsden said at the Economy, Trade, and Rural Affairs Committee in January, the costs of not doing this are greater than the costs of doing it.

Okay. Tyler, did you want to come in?

Diolch, Chair. Thank you, Chair. I thought I'd pick up on a comment that's been raised in a couple of the committee sessions about the potential overlap between the future generations commissioner and the food commission, because I think it's quite important when we're discussing why we think the food commission is value for money. And there's been a suggestion that, perhaps you could input some of this into the future generations commissioner's remit, and we know from discussion from the commissioner's office that they don't have the expertise, they don't have the capacity, to look at a lot of what we're proposing within their current resources. So, if we were to go ahead with one of the options that has been suggested of enabling the future generations commissioner to do this, then there's a cost impact to that; there's a resource impact to that, both financial and in terms of human resource implications as well.

So, I think what we're trying to argue is that, actually, that money would be better spent on a body that had the specific focus and the expertise, and also then, the accountability measures that we've included within the Bill. So, for us, some of the other options that have been suggested to us also have a cost impact; they also have a resource impact. So, our argument is: instead of tucking this away in an existing body, where resources would inevitably have to be used for other things anyway, and we know the range of fantastic work that the future generations commissioner undertakes, why don't we put that into a commission that then can help us to extract as many social and financial benefits as we can?

Okay.

Can I supplement that bit, because Tyler prompted me there, actually? It was only a couple of weeks ago, in the last week of Sophie Howe's role, that I put the question to her: could her commission, could she absorb this work, could she do it? No way; she couldn't take it on. This was too broad, and I think you'd need to totally revamp that whole department, the whole purpose of the future generations commission as it is, and that doesn't come at a zilch cost. There would be massive investment needed in that. And, would it be able to achieve, without detracting from its current purpose, in the way that it would need to to deliver this holistic food system?

Thank you. Just briefly, you spend half the commission's cost in the first year of the transition costs. Can you explain your rationale for this and why you assume that the costs to establish and operate the food commission in the first year will be then the same as operating it in the second, third, fourth and subsequent years?

Can I bring in somebody who knows those details better than me?

That was really just to bring a bit of flexibility into it. We looked at when commissioners had been set up, and, like you say, the costs aren't full costs in the first year. I remember that the future generations commissioner did it like 15 months' accounts, and it was less than what its budget would be in future years. So, almost to be safe and cover these points where people might be saying that, 'Oh, well, there are more costs involved with organising it, and maybe the Welsh Government might have a few additional costs,' that almost can be swept up into these costs. So, it was just to show that—

It was more of a smoothing out, then, was it?

Yes, I think so. Just to understand that, yes, there could be some costs that we didn't think of if we were to say, 'Oh, this is only going to cost half what it will in the following year,' then I'm sure we would have had criticism for that. So, it was just to build a bit of flexibility into the resourcing available, really.

Okay, thank you. A final question from me, and then I'll go over to Mike. In the RIA, you quantify the costs of the current four commissioners in Wales to a range of between £1.5 million and £3.1 million, but you say that the scope of the Government's estimate for a food commission is £0.75 million per annum. Can you explain why this is the case and what differences you envisage between the roles of the food commission in Wales and Scotland? And, given that the Scottish good food nation Bill was passed in June 2022, has the Scottish Government been able to refine its costs regarding the establishment of the food commission in your discussions with them?

Elfyn, can I bring you in on that?

Yes. I can partly answer this one. In looking at the costs, we felt that the Scottish commission model was the most similar to what the Member's preferred option might be for the Welsh version. We also looked at the infrastructure commission in Wales as well, although that has a bit of a narrower remit than is envisaged for the Welsh food commission. The Scottish and Welsh commissions are broadly similar, both with a supporting and scrutiny function for the various food plans that would fall within their remits, but the Welsh commission's functions, as set out in the Bill, are probably broader in their role in helping with the statutory food targets and the food goals. But we also felt that Scotland is bigger; its food sector, as Martin has already said, is significantly bigger, it has a larger number of public bodies, so they would have more plans to deal with, effectively. So, whilst the Welsh commission might be broader, the volume in Scotland is probably greater, so we felt, maybe, that those two things evened out, and so, we felt that the Scottish model was a fair one to base the Welsh costings on.

Could I bring Tyler in to supplement that as well?

Just to come to your second question, Chair, we did undertake a lot of work with Scottish Government officials over the good food nation Bill as it was, now an Act, whilst we were drafting this Bill. I know that colleagues had a number of meetings with Scottish Government officials about some of the costings. Now, as far as we understand it, I think I'm correct in saying that the explanatory memorandum to the Scottish Bill wasn't laid long before it was passed, so the costings that we've used in the EM are the most up-to-date figures that we had and what we were notified of by Scottish colleagues, so, from our final discussions. We're not quite sure what further work the Scottish Government has undertaken, but, again, this could be developed further in consultation with colleagues in Scotland. I know that the Minister suggested that she'd had or her officials have had some discussions about the Act up in Scotland, so perhaps they might be party to more information about any further scoping work that's been undertaken.

Thank you very much. Mike, I'll bring you in now.

Thank you. Diolch, Peredur. A lot of what I was going to ask was answered in the first part, which is, as you know, not unusual. We're not allowed to talk about the policy, so I will try and circumvent that and hope that you don't call me out of order. Could a lot of what you are attempting to achieve be undertaken by working with the Minister and the Minister incorporating it in advice notes and/or in her own legislation, which would mean that there would be no cost to achieve many of the things that you wish to achieve, most of which I'm in favour of? I don't like the commission. I've seen the future generations commissioner, and that puts me off commissioners completely.

Thank you, Mike. Obviously, our proposal was taken to the Senedd and they gave me leave to, and I have no choice but to bring this Bill forward, and I think it's right, anyway, to bring it forward in its current guise. It's for later Stages if people want to challenge elements of this that they feel could be operated in different areas.

I don't believe that the current framework that we have can deliver all that we want. There is talk of a community food strategy, which is, to say the least, underdeveloped or almost non-existent because, as the Minister said again today, she's only got one official to be able to work on that, and they've spent time scrutinising this Bill. However, I recognise that there is £1.8 million put aside for that, yet I'm not quite sure where it is. I don't believe that the community food strategy—. It's difficult, Mike, because unless you know the scope of what that will entail—. We believe that it's more around local produce and things like that. We don't know if it could capture what I'm suggesting here. I noticed this morning in the discussion that lots of people talk about just the food production side of this, the food element of it, but the wider side of things is how we use that food. So, how does that food find its way through to alter the fortunes of the health of future generations? How does it tackle societal issues like malnutrition, obesity and all of those things? I don't see anything in the current framework on food policy within the Government at the moment that even tries to address those fundamental parts of this.

That's why I call this a holistic Bill, because it goes from production to how you use the food, how you educate people and children for the future on how to use their food, and by doing so, effecting real future generations change. I don't believe that the current elements of the framework could do this, because, if they could have done and they're seen as important, why weren't they already incorporated? Why wasn't the partnership and procurement Bill developed with something wider in mind? Why weren't the other strategies focused on these wider elements? It's all well and good saying, 'Could they be fitted in now?', well, the reality is that there wasn't anything. I've brought a Bill forward that fills those gaps, and that's what I have to take forward. I still believe that there isn't anything, until we see the scope of a worked-up food strategy, there isn't any work done that we can scrutinise at all, even though there's money put aside without any cost-benefit analysis of £1.8 million, I don't know how anything else in the framework currently can deliver anything that we're seeing here.

I'm fairly certain you're right, but bits of it can. What I'm asking you: are you prepared to talk to the Minister to discuss if some of the bits of the Bill that have almost universal support, could actually be fitted in either into current legislation being put forward or into ministerial statements? I always tell people a Department of Education and Science circular gave us comprehensive education. Lots of things can be done by ministerial decree, rather than needing legislation.

We were challenged in—. I was challenged in a similar way by the Legislation, Justice and Constitution Committee, by Members there, who wanted to know what my red lines were, and this, that and the other, and I think it's wholly inappropriate, really, for me to defeat my own Bill by suggesting that this isn't needed. I have a role to play of taking the Bill through, as the Parliament asked me to do, to take it through its course. Of course, there will be opportunities for conversations. It's disappointing that the Government—to an earlier question—that the Government didn't see the benefits of what we were trying to do and work with us to help shape the Bill as it's come through. I hope though, recognising what the Minister said about the food strategy, that there might be opportunities for further conversations, if we get leave to move on through the later debates. But, at this point, Mike, I won't be drawn on that.

I have nothing further to ask, Chair.

Okay. Just on the social value and the return on investment, Mike, I just wondered if I could just jump in there and say: have you attempted to model any of the possible benefits? You talked about the other benefits earlier. You haven't quantified those, as far as we can see, in the RIA or anywhere else. Have you given any thought—? Or why has that not been followed through?

Well, it's important to note that, whilst this could become law, the resources and access to information that we have had so far, compared to what the Welsh Government would likely have during the same process, is very different. We have done our best, if you like, to look at the costs and benefits of some difficult issues the best that we can, and these have been set out in the explanatory memorandum. But I'll give you an example. For example, if you're looking more broadly, the cost of obesity to Wales is around £3 billion a year. This Bill is not a silver bullet, we know that, but, if it helps to reduce obesity rates by an amount through its focus on creating a more equitable food system, which is focused on securing better diets that may help to improve people's health, then it could help to ensure cost savings to the public purse. And it goes back to something I was saying earlier, about how do you quantify all of the benefits in a monetary term. There is a need sometimes for investment in the future. I think this lays the framework for that further investment going forward. I don't know if colleagues want to add more things. Tyler.

Just very quickly on this point, Chair, I just want to note what the Minister stated in her letter to the committee, because I know we were slightly criticised by the Minister for not including alternative non-legislative options, and so she states that it's not possible to fully consider whether the Bill offers value for money because of this. Just for the record, as Members will know, it's the norm for non-Government Bills to look at two options: a 'do nothing' option and 'introduce a Bill'. Of course, we don't have the remit to introduce non-legislative options, so it's not appropriate for us to consider what policies we could introduce, because we can't introduce this. And a good example of this is your predecessor Finance Committee on the Public Services Ombudsman (Wales) Bill, which obviously became an Act in the previous Senedd, and that included two options, which were 'do nothing' and 'include a Bill'. So, I just wanted to mention the Minister's comment, I think, about this, because we have had to work within the constraints of what a Member Bill gives us. It's not in our remit to consider whether the non-legislative options are available to us, and so the work that we've done is based on what we think would happen if we introduced the Bill, and it's for Ministers to look at what other options could achieve instead of this Bill.

Thank you. Right. Thank you. Sam, would you like to take over?

Yes. Thanks, Chairman. Thank you for your attendance this morning to committee. Just carrying on the conversation we've been having around the ability to quantify some of the costs, in the RIA you point out that it's not possible to quantify some of the cost savings, because they'll be informed by the content of the national food strategy. So, would you envisage undertaking an analysis of cost savings when the food strategy has been published?

Thank you, Sam. Well, given the nature of the Bill—and, as I said earlier, I won't be enacting it as such—it would be for Welsh Ministers, and possibly the food commission, with their support, to analyse and quantify the actual cost savings. The food strategy is intended to allow the Welsh Government to bring together its existing plans and strategies into a coherent direction of travel, and so it brings about the opportunity for Ministers—what is currently spent on what, and whether any spending could be redirected to achieve better outcomes or to remove areas of contradictory spending. As I said, this is very much a framework Bill. It's in the hands of the Government to shape the nature and the costings of much of this afterwards. If we look at the costings of the commission, the Government can decide some of the details around how the commission would operate, how much it pays its staff, how much staff it would need. All of those things can determine some of those costs. We can't predict those. They will have to happen afterwards.

Okay. Thanks, Chair, and thanks, Peter, for that response. Just one more look at this from my side, in terms of being able to quantify some of the costs here, and in particular in relation to implementation of local food plans. Could you help me again to understand why you're unable to source the information you'd want, and how it impacts on the costs set out in the RIA?

Thank you. Well, our approach while formulating the policy was to identify the key impacts and which type of organisations would be affected. Costs have been estimated on the basis of either figures provided by those organisations, costs based on advice that we have taken, shared with these contacts, or costs based on information in regulatory impact assessments that have been considered appropriate for this purpose. However, not all organisations were able to provide us with the information, so in some cases it's difficult to gauge the exact figures. The costing of the plans would be dependent upon how they were designed, again, and it would be up to Welsh Ministers, as I said earlier, in consultation with the food commission, to shape those. So that's probably why it's a little bit unquantifiable, to be honest. But, Tyler, do you want to come in?

Yes. Thank you, Chair. In addition as well, Sam, one of the things that we found is that some local authorities, some health boards, public bodies, are doing a degree of work already on some of these issues. So, the cost impact overall, if we were to give a blanket figure, would be different according to local authority. As we mentioned earlier, you might expect a council like Caerphilly, which is quite progressive on this, to already be able to quantify its costs, know how much it spends on its work and the streams deriving from that, whereas other councils—and we've been told this in our stakeholder engagement—perhaps are not at a similar level, so the extent to which they can estimate the costs that they already have, and what they might envisage that they might need, is quite difficult from their perspective. And so what, I think, they're asking for, and what we saw in our consultation responses, was that they would very much appreciate a framework to be able to work within, so then public bodies could actually start doing this work on a more consistent basis. And if we were at that point, then I think we would be able to much more accurately try to model some of these cost impacts. But, again, as Peter mentioned, there is scope here for a bit of rationalisation of some of these policies, some of the work that councils are already doing, and I'm sure there's actually work that councils may not consider to be part of this, but actually would be and would come under some of the things that we're talking about within this Bill. So, I think it's a very good opportunity to take stock and audit, almost, what are we doing at a local level, what's missing and what support needs to be put in place then, both policy-wise and financially to progress this forward.

There was a good quote from Carmarthenshire, actually, because we've spoken a lot about Caerphilly and we talked a lot to them about the great work that they're doing, but from Carmarthenshire, the response to the Economy, Trade, and Rural Affairs Committee—. They said that they were

'confident that local food partnerships, within a statutory coordinating framework, can offer value for money.'

They said,

'Carmarthenshire is taking forward actions proposed by the Bill already. However, a Food Commission and defined Food Goals would sharpen focus, even out delivery across regions, as well as providing more opportunities for collaboration and shared learning.'

So, I think we've discussed and looked at the admin for putting the plans together, and due to the way we wouldn't be sure what the content of those plans would be, implementing those plans will depend what's in those plans, what's in the strategy and how far forward each organisation is.

Sorry, Chair, just really, really quickly on Martin's point about the local food partnerships, it was highlighted by Food Sense Wales, actually, during the ETRA committee, that the Welsh Government are currently in the process of investing £2.5 million in the development of cross-sector food partnerships through their prosperous futures team. So, actually, there is money there to be able to link the work that's already taking place with the work that we might envisage local authorities undertaking. So, actually, some of that cost could possibly—and, again, it's a 'possibly'—fall under some of that existing funding that has already been allocated by Welsh Government.

Great, thank you. That discussion there was in relation to local food plans, but there's also the estimated cost directly to local authorities and health boards, I guess, as well. I think in your paperwork you show between £0.9 million and £1 million over a five-year period. And we've already heard a quote—I think it was Carmarthenshire council—talking about good value for money from some of this work. So, do you want to expand on that point at all about how you see this being good value for money or not?

Yes, thank you, Sam. A lot of bodies, as we've heard already, are doing a lot of work in this area already, and what we gained through some of the responses to the consultation was their overall support for what we're trying to do to try and join up the dots on this, because you get great pieces of work acting in isolation. Loads of councils who want to do the best thing within their community have already got small community food sub-strategies being developed, and different things like that. We believe there is an appetite to do this because of the opportunities it can create within those councils. Yes, sometimes people may have already purposed some of their resources in a certain area; that's not to say they can't realign their forward thinking. We both know as past council leaders how that happens regularly, where you adjust your position because there is a need to and a desire to.

So, what we haven't seen, I don't think, unless somebody tells me differently—. I haven't had councils and health boards coming in sharing their fear of what the costs of implementing some of this might be. There's more of an acceptance that we need to put something in place and we need to move forward really quickly. So, colleagues—

Just on that—you may be coming on to this yourself, Sam—but we heard from the Minister this morning two or three times that she wasn't sure how much engagement you'd had with authorities. I just wondered if you wanted to comment on that.

Can I bring one of you guys in, perhaps, there?

I can have a go. In terms of the local authorities, we met with the Welsh Local Government Association. We had a response from them and also individual authorities to the consultation. There were consultation responses from a number of public health boards—I think Swansea, Aneurin Bevan and a few others, and some other NHS organisations as well, Betsi Cadwaladr. I'm just looking through the consultation responses now and not one of them was opposed to the Bill. As Peter has said, they were welcoming of the—

She was questioning how much engagement you'd had and what information you'd been able to glean from that, I think, from my recollection of this morning.

We met up and then we shared what our thinking was. They gave us quite a few pointers as to where we could probably find comparable costs, what was going on in different areas. So, we followed up on those, shared our costings with them, and then they were happy. So, it's not that we've invented something; we've consulted and then used that and then okayed the costings with them.

Can I just expand on that point in terms of first setting up this food plan? I think your RIA estimated an increase of about 20 per cent in terms of the staff resource. Is that where perhaps that figure of 20 per cent came from, as an estimate for that increase in the budget?

I'm not sure where that 20 per cent—. I think it might be around the food plans. We were talking about 20 per cent of—if I can identify it in my notes—two particular staff members at certain grades. This is where we talked about, 'What grade should they be? How does this look?'

And you're confident that's not an underestimation, then, because you had that engagement with those relevant stakeholders to come up with that.

Yes, and it was broadly in line with what the Scottish had in their Bill, and they didn't have any negative comment or feedback. And then we've shared these—. I haven't seen any negative comments or feedback. I'm sure somebody would come up with a bigger figure.

We've been thorough in our engagement via consultation with all bodies throughout, and we've obviously received a really proactive response from them. I've had individual people, even chief execs from local authorities, who have been supportive and constantly wanting to know how we're progressing, because they are supportive of what we're trying to do because it joins up a lot of the work they're trying to do. The whole nature of putting a Bill together is about consultation, it's about engagement and following up, and the amount of various meetings we've had—online, generally—with colleagues has been massive, from the food sector, from all walks of life, from the health side to food production to local authorities, you know, to actually shape our thinking throughout. As I've said, I haven't seen any responses that have said, 'Look, Peter, this is totally unaffordable, we're right up against it and we can't afford this'. I think, as an ex-council leader, that would be an absolute non-answer for something so fundamental for their communities as this.

I know Tyler wants to come in, but just on the points you were talking about there, you were saying that consultation and developing a Bill is also about making some assumptions. When it comes to staffing costs, did you assume local authority pay scales or did you assume health board pay scales?

That's a good point.

We did it for the local government pay scales. I looked at the health board ones and I found it a bit harder to fathom them. I assumed that it would be similar people paid a similar amount.

In terms of the future generations costs, we didn't mention that, and I think the Minister was questioning those costs. For those, we've had a number of meetings with the future generations office. I said, 'Could you please cost this?' and they said, 'Yes'. I was slightly concerned because the costs came in quite late for inclusion in the Bill. But, yes, on the future generations costs, their office just provided the costs.

I'm just conscious of time. Have you got something briefly you wanted to say?

Yes, please, Chair. It's just to really tie up two questions in terms of engagement with public bodies and social value. In the explanatory memorandum, we've included some of the responses we had from stakeholders. For example, you had Torfaen County Borough Council, who welcomed what we were doing. They said that

'Overall we believe that the Food (Wales) Bill would significantly strengthen the work which is already being developed at a local and regional level to create a better Welsh food system. It would ensure that local initiatives are aligned with national commitments and vice versa, avoid duplication, increase efficiency and add value to our community wealth.'

I've quoted from the explanatory memorandum, and that's in the stakeholder responses as well. Swansea Council said:

'It will ensure transparency and accountability towards meeting those goals, by means of oversight by a Welsh Food Commission, which is to be welcomed.'

And then Swansea Bay University Health Board said that

'In the absence of regulation, there has been inconsistency in terms of how our food environments (including those within the public sector) enable healthy behaviours. Often the easiest or lowest cost choice/option prevails which can result in the normalisation of cheap unhealthy foodstuffs.'

And they talk about food deserts as well across Wales. So, we're hearing from our engagement with public bodies that they see the social value of this, and also there would be, inevitably, what we'd hope would be a positive economic impact from this as well in tackling some of these issues. So, on the Minister's comment that she wasn't sure how much engagement we'd had, we have done a lot of engagement and it is these public bodies who are saying, 'We would like to see a lot of this Bill come forward.'

Thank you very much. I'll bring Rhianon in at this point. Can we unmute Rhianon, please? There we are. Lovely.

Thank you very much, Chair. I've been listening with interest. I think one of the Minister's comments was on engagement with her. I'll go on to the questions that I have. The RIA notes that costs in relation to the five-year review of local food plans will be outside the time frame of costing of this impact assessment. Given that these additional costs would impact, as we've spoken of already, local authorities and health boards, why did you choose to quantify the financial implications of the Bill for five years only? To what extent can we be satisfied that we're receiving a thorough assessment of the costs associated with this Bill?

Thank you, Rhianon. Providing an impact assessment over a five-year timescale has been the standard approach for Member legislation and also for the previous Finance Committee's Public Services Ombudsman (Wales) Act 2019, as I know Tyler talked about earlier. It's easy to see the recurrent costs, such as those for the food commission, and the various reporting requirements from those tables that we gleaned from that. We did note that the five-year review of local plans falls outside of the five-year costings provided. And, to be transparent, we provided a cost for this work in the RIA, noting it would fall outside the five-year period.

Okay. Thank you very much. You mentioned there are no costs directly resulting from the Bill for voluntary organisations and the private sector. So, how confident are you that all stakeholder costs have been identified, firstly, and how did you confirm that?

The Bill does not require any input from voluntary organisations or the private sector. The benefits, opportunities and costs on these organisations will result from the food plans, and obviously they would have to be produced afterwards. For example, it is envisaged that private sector organisations and voluntary organisations may benefit from the Bill's focus on the shortening of their supply chains, for instance, which could provide more opportunities for such bodies to supply produce. It's difficult to quantify exactly what this potential impact will be, as this is dependent on the extent to which public bodies are able to source local produce, as well as the capacity and resources of local producers to meet the demand. We know that, arguably, public bodies currently underutilise locally produced food when considering their procurement contracts. In a Plenary note I recall, on 9 November, the Minister for Climate Change stated, and I will quote her:

'Public sector food procurement spend accounts for some £84 million expenditure a year.... And whilst I absolutely agree we must use public procurement to lever wide change, we should also put this in context: the total public expenditure on food procurement in Wales is similar to the consumer spending at just one major supermarket outlet in Cardiff. Therefore...there needs to be a societal change in food purchasing patterns.'

I think that captures it pretty well. But I'm not sure if anybody else wants to add anything.

And obviously not speaking to the Bill itself. So, you feel confident that all stakeholder costs have been identified. And the second part of that question was how did you confirm that all stakeholder costs have been identified.

As I said, Rhianon, some of the stakeholder costs are unquantifiable as yet, because we won't be enacting the Bill. The nature and the shape of all of the constituent parts of it will be determined by the Welsh Government. We've allowed that flexibility in the Bill to be shaped. So, it would be very difficult to quantify all elements, because, as we said, that would very much be about how the private sector and the voluntary sector would be affected by the nature of how the food plans are developed. And those food plans will be developed between the Welsh Government and the commission. So, it's very difficult to actually, on the face of the Bill or in the explanatory memorandum, put all of those costings in. But I'm conscious—

It comes back to Sam's question, doesn't it: should there be an impact assessment when the strategy is put out there? And your answer to that is, 'yes'. But it isn't part of the impact of this Bill.

Okay. That's clear; thank you. And my final question pertains to the auditor general's written evidence to the Economy, Trade and Rural Affairs Committee. He believes an additional £30,000 would be required to undertake sustainable development principle examinations and that that would be in addition to the annual costs of the audited accounts. How will this be reflected in the RIA?

Thank you. As we understand it, the audit office undertakes a sustainable development principle examination at least once every five years. The fee of £30,000 would come out of the unallocated proportion of the £750,000 funding estimated for the food commission.

Thank you very much, Chair. Thank you, Peter Fox.

That brings us to a conclusion, unless anybody has got any other questions for Peter and the team. That leaves me just to thank you very much for your time this morning and shortly into this afternoon. I wish you well with the Bill, Peter, and we will be reporting back in the usual manner. As I said earlier, there'll be a transcript available for you to check for accuracy.

Under Standing Order 17.42, I propose that we go into private session now for the remainder of our meeting. Is everybody happy? I don't see any dissent, so, yes, we'll go into private session. Thank you.