Other Comments - Regulation
What we asked
Q8: Do you have any other comments about the draft Regulation?
This question sought to provide an opportunity for respondents to offer their views on the draft regulation which were not captured in their earlier commentary regarding a single criterion as a basis for locality planning with a population maximum.
143. 34 respondents added additional commentary regarding the draft regulation. Not all of these comments related to the draft regulation with some reiterating what had been included in their comments in relation to earlier questions in the consultation.
144. There was wide ranging commentary provided in the responses to this question, with themes emerging around: effective engagement and participation; spread and depth of inequality.
Effective engagement and participation
145. This theme was highlighted by a range of respondents and possibly most simply when a public body stated that "effective community engagement is often most challenging with the communities who need the most support".
146. This was followed by a number of comments relating to engagement support and planning with one third sector respondent keen to see a Community Participation Plan indicating that "How much Community Planning Partnerships involve communities will determine the success of the wider Act."
147. A Public Body also sought more clarity around who has responsibilities for developing communities' ability to engage in the community empowerment agenda.
148. Whilst another Public Body expressed "concerns relating to community capacity …risk that the least deprived communities are the ones which are most likely to avail themselves of the new legislative powers. This, in turn, may well have some detrimental impact on CPPs' abilities to support positive change within the most deprived communities."
149. This concern about resources was also relayed in a response from a Public Body who considered a potential danger in that "significant increased demand" for local supports assessments and other analytical products will outstrip capacity of partners to supply.
Spread and depth of inequality across CPPs is not the same
150. This was considered especially challenging for those CPPs which have more localities experiencing disadvantage as they respond to relatively greater identified need by, amongst other things developing and supporting more communities participate in more locality plans
151. Communities experiencing disadvantage will require support to enable them to participate fully in their locality plan, and some respondents considered that this is likely to be greater in those areas with a higher level of disadvantage or potentially more pockets of such disadvantage.
152. Some respondents considered locality planning duties will exacerbate any community capacity building issues at play in CPP areas with higher levels of disadvantage, as CPPs seek to secure the participation of community bodies representing the views of those experiencing disadvantage and whose views have historically been less well recognised.
153. An NHS respondent considered that the task of locality planning will vary across partnerships with some experiencing higher levels and more 'pockets' of inequality, they also venture that all need to recognise limitations to ability of locality planning to reduce inequalities to avoid potential for inequality to be perceived as fault of those communities.
154. Others considered that the regulation was challenging for island communities in that inequality was spread across populations rather than concentrated in geographic pockets. Island respondents stated that the criteria maxima would have no impact as their entire population was below the maxima for a locality.