This article includes the detailed response submitted by Russell George MS, Craig Williams MP, and others to Phase Three of the Wales Air Ambulance Engagement Process.
Dear Stephen,
Although members of this group may submit their own personal response, or respond on behalf of others they represent, we felt the need to send a joint response to this Phase 3 consultation as a group.
We have discussed detailed concerns with you on many occasions, and are grateful for your time and consideration in doing so. The following do not supersede these detailed concerns, and should be read alongside those fed back throughout the process, but are intended to focus our response on issues specifically under the spotlight within Phase 3.
We are concerned regarding:
Mission Creep / Narrative slippage
The original rationale/justification for this significant service change has now been shown to be severely deficient. References made (by WAA/EMRTS) to the potential number of lives saved and benefits amassed now (as we stated at the time) seem utterly hyperbolic and dangerously misleading. We are concerned that the lack of a well-publicised public correction of these hyperbolic statements, and their repetition and ongoing referencing by both EMRTS and WAA, may have mislead the public (as it recently did the First Minister), and will have impacted the nature of their response to this consultation. We do not believe a strong alternative justification has been clearly communicated to the public (nor do we believe that one exists), and stress that if this were the case, the process should have started again from first principles, not progressed step by step from a defunct proposition. In the absence of such a strong justification we now fail to see the need for such significant change in service delivery and organisation/infrastructure, when far smaller adjustments (eg. to shift patterns and dispatch criteria) would seemingly satisfy the vast majority of the need as currently outlined.
With options A and B offering a broadly identical ‘solution’ to that presented as a fait accompli by WAA/EMRTS before Phase 1, we see a worrying trajectory where the only constant is the desired result, with justification, rationale and need being applied fluidly in order to meet this aim.
The Unmet Need
Throughout the process the figure of 2 to 3 people a day of ‘unmet need’ has been at the forefront of the need to change /close /merge current bases (in order to improve/reduce this number). Recorded in report as fact in 2021 it averaged 4.4 people a day (1613 in the year), in 2022 it dropped to average 2.75 a day (1004 for the year). No details have been provided as to how this figure was reduced from 2021 to 2022, nor where the greatest unmet need still resides (temporally, geographically etc), nor how the current ‘preferred options’ respond to these unresolved issues.
With the promise of an additional 139 scene attendances from the proposed change of service, and North East Wales seemingly being the major beneficiary (47% of the 139 or 65 extra missions) the report lacks clarity on how this is achieved by simply combining and co-locating resources. At the same time the modelling produces a 5.7% gain in the far reaches of Hwyel Dda area without any significant change with South Wales arrangements, again hard to see the logistic explanation for how this forecast was determined.
Taking the figure of 1004 unmet need calls made in 2022 (calls that did not get the service that met all aspects required in meeting the dispatch criteria), the fairly low forecast of improving scene attendance by only 139 still leaves a total of 865 patients still not getting the service they desperately need.
We also note that there is no robust evidence regarding clinical outcomes for this ‘unmet need’ cohort, and whether their need remaining ‘unmet’ effected this outcome, with detailed breakdown by area/proximity to DGH/WAST response availability etc.
Considering the stated levels of utilization within the Caernarfon and Welshpool bases, and EMRTS/WAA’s assurance that these areas’ needs can be met from a North Central combined base, we fail to see how the inverse is not also the case, with the stated ‘underutilisation’ of Mid/North assets being tasked to meet the unmet need in North East Wales. We consequently question the dispatch protocols and shift/crew availability, not the base locations, as a potential solution.
Therefore we fail to see the evidenced rationale following much more than the annual variabilities of critical care responses and the benefits of laying on an additional shift – hardly justification for such significant reorganisation.
The ‘additional extras’
Although they may address some systemic inequities within wider NHS provision in rural Wales, they have not formed a fully worked-up part of this consultation process, and therefore ourselves and the wider public have had little chance to consider them, nor to evaluate appraisals/modelling relating to their deployment. With such a tight timeline for responses, a thorough public appraisal of their usefulness or otherwise seems unlikely.
‘Preferred Option’ A and B combined with the layering of these additional extras seems to provide, at best, a service which mitigates for the deficiencies of not (currently) having a 24hr response in Mid and North Wales, but with a significantly increased risk profile when compared to options that do not require the centralisation of resources and aircraft. Additional critical healthcare provision in rural Wales is a proposition to be welcomed, but as a separate consideration to the unnecessary centralisation of Mid/North Wales WAA assets and EMRTS crews, through option A/B or any other variation or option.
The Scoring/Ranking Workshop
This element of the process was not outlined at any point during the public engagement prior to the announcement of Phase 3, yet it also seems to have happened independently of phase 3. We do not understand the need for this workshop, nor do we agree with the need for it to have prioritised two ’preferred options’ from the shortlist of 6.
We have significant concerns that both the unfamiliarity of the workshop participants with this specific proposal, alongside the potential for highly partisan ‘information’ dissemination from the in-workshop ‘experts’ (WAA/EMRTS) and opportunities for informal influence may have impacted both the scoring and the workshop narrative.
There are discrepancies within the workshop outputs that give us a very low confidence in its ability, as a method, to objectively appraise the options. There are also assurances provided (and subsequently published) by the in-workshop ‘experts’ (e.g. around confidence in staffing probabilities for the new model) and concerns expressed (e.g. around issues relating to night-time RRV staffing) that we find both contradictory and partisan towards a specific predetermined option outcome. As such we believe that the publication of the workshop outcomes, alongside the prioritisation of two ‘preferred options’ risks severely misleading both the public and healthcare professionals alike.
We also note with concern that neither impacted communities nor their representatives were involved in either witnessing nor participating in this workshop.
The Preferred Options
We would note that both options A and B are in fact one option with a single variation applied, not two separate options – meaning in essence that the questionnaire predominantly leads the public to comment on a single option, an illusion of choice.
We note that the reports compiled by EASC do not contain any factual evidence to support the claim of improved service to those currently serviced out of Welshpool and Caernarfon, and in fact suggest the opposite – that the combined Rhuddlan base serves 499,266 less people when one considers the population coverage for a 30 minute response dispatched from the current base configuration.
We find this option unacceptable for numerous reasons that we have already communicated to you, including:
The loss of systemic resilience in Mid/North Wales, with both aircraft likely to be taken offline at the same time if adversely affected by weather or other issues relating to the (now combined) airbase
The risk of skills and staff drain through decreased retention and losing some of the most experienced and qualified staff
The critical risk to core service delivery, even without expansion of operational hours, should too many key staff leave the service in the period prior to or closely after the base move (a cliff-edge in terms of staffing)
The reduction in the commutable radius (as a result of the reduction in base locations) for permanent staff to attend the service’s bases impacting both staff retention and recruitment
The loss of the aircraft as an ‘anchor’ for Critical Care services in Mid and North West Wales
The irreversibility of the change once implemented – the closure of the bases and the potential loss of staff significantly reduces options for future reactive/proactive service development
The loss of the aircraft as a recruitment and retention tool for bases within the ‘additional extras’ RRV category, for critical care staff within a highly competitive sector where cross-border staff ‘bleed’ is a justifiable concern
The lack of a proven, sustainable model for RRV provision to/in Mid and North West Wales when the aircraft is offline, and the inability of the RRVs to attend incidents across a substantial area of Mid/North West Wales if centrally based at Rhuddlan.
The additional flying time (especially in adverse weather when crossing Eryri / Clwydian range or skirting coastal zones) when attending incidents in Mid and North West Wales if a helicopter is dispatched from a North Central location, especially for extremely time-critical incidents e.g. cardiac arrest or severe blood loss. This concern is especially pertinent if the air asset in Welshpool is lost, considering the size of its population coverage with a 30 minute air response when compared to Rhuddlan.
The Questionnaire
As previously stated, the questionnaire leads respondents into answering from within the framework of a single ‘preferred’ option (with variation), yet still requires respondents to answer 11 questions and read an 83 page document. We feel this is both leading and unrealistic, and consequently compounds issues already referred to around the broader public narrative.
We do not believe the materials provided gave the public, their representatives, nor professional stakeholders a clear image of the impact/results of the changes outlined within the options, and thus adversely impacted their ability to meaningfully engage with and answer the questionnaire.
Appended to this document are both a format of questionnaire we believe would avoid the deficiencies of the Phase 3 Questionnaire, and a graphical rendering of the impacts of the options on service delivery, as examples of what we would see to be more appropriate materials for public dissemination.
Ministerial Oversight
We do not believe that the Minister has been effectively briefed as to the details of this proposal, and the separation of responsibilities between EMRTS/NHS and WAA has been additionally unhelpful in this regard, with the latter seemingly neglecting their duties as a publicly/beneficiary accountable organisation throughout this process, and the former providing the minister with misleading statements and statistics. We have asked Llais to take up the concerns raised in this consultation directly with the minister.
We also seek assurances that, due to the lack of trust in EMRTS/WAA’s ability to objectively appraise service change, ongoing monitoring, benchmarking, and appraisal of the new operational model is undertaken independently of both EMRTS and WAA management, and takes into account the views of a far broader range of stakeholders whilst engaging expert input from individuals not directly connected to the delivery of the current service.
WAA Charity
Although beyond of the scope of this consultation, we would note that the first relevant date listed in the timeline on page 21 of the original EMRTS Service Development Proposal (Phase 1) is that of WAA’s (un-consulted and privately held) decision in 2021 to appraise options in order to close their Welshpool base and relocate their assets – we believe that this unnecessary decision is primarily responsible for the trajectory of events since that point. Through this ongoing process we would seek reassurance for the public (the charity’s beneficiaries) that the charity’s misguided desire for change and unilateral approach to decision making will not impact the people of Mid and North West Wales in this manner in future.
We are deeply concerned that much damage has already been done to the WAA brand, and their ongoing ability to raise funds within the affected areas and beyond, and would consequently wish to see significant change within the charity to avoid a repetition of this debacle and reassure the fundraising public in order that the current level of fundraising can be maintained and enhanced.
Our Preferred Option
Our preferred option from the consultation shortlist continues to be Option 6. We strongly believe that the only acceptable option would see the retention of 4 separate crewed air bases, with helicopters and RRV backup, at their current geographical distribution, and would wish to see this provision enhanced in order to meet the unmet need identified, especially through the development of a ‘late shift’ (or potentially 24 hour operation) in Mid/North Wales and the provision of a RRV capable of responding to the needs of the more urban-based population of North East Wales.
Following consideration of points raised in your most recent report however, we understand and appreciate the shortcomings of Option 6.
We also note however that some (but not all) of the shortcomings listed seem contradictory when considered alongside proposals for the ‘additional extras’, and that altered dispatch criteria and adjustments to shift patterns, alongside the provision of additional staff welfare/rest facilities would mitigate a significant number of the operational concerns outlined.
We no longer believe that a split shift between Caernarfon and Welshpool is practical, and would lead to a reduced level of equity between 08.00 and 14.00. To this end we would propose that both daytime shifts for Welshpool and Caernarfon crews are retained, with the addition of a late/night shift (with or without an aircraft) to enhance provision, considering staffing/cost constraints and recognised unmet need profile, potentially focused on the north Wales A55 corridor.
We also appreciate the constraints of dispatching a road-based response from the Dinas Dinlle base, and would like to see consideration of the relocation of some or all of the resources (human and material) to a more accessible proximate location (Ysbyty Gwynedd?)
We also copy into this letter, Eluned Morgan MS, Minister for Health and Social Services, Alyson Thomas, Chief Executive of LLAIS, Katie Blackburn LLAIS.
Kind Regards
Russell George MS for Montgomeryshire
Craig Williams MP for Montgomeryshire
Cllr Elwyn Vaughan – Plaid Cymru Group Leader, Powys County Council
Cllr Joy Jones – Independent County Councillor for Newtown East
Cllr Graham Breeze – Independent County Councillor for Welshpool Llanerchyddol
Cynthia & Clive Duce - Leaders, Save Air Ambulance Mid Wales Base Campaign
Bob Benyon – Member of the Save Air Ambulance Mid Wales Base Campaign Team
