Maximum Population Basis for Locality Planning Regulation
What we asked
Q7: The draft regulation sets a maximum population size for localities subject to locality planning of 30,000 residents. It also proposes an exception which allows a CPP to designate a local authority electoral ward as a locality even where its population exceeds 30,000 residents. Are there circumstances in which these criteria would prevent a CPP from applying a reasonable approach to locality planning? What difference would it make to how localities were identified for the purposes of locality planning in the CPP area(s) in which you have an interest, if the maximum population size were set at (a) 25,000 residents or (b) 20,000 residents?
127. The draft regulation proposes that a locality must be "an electoral ward; or a geographic area with a population that does not exceed 30,000.
128. Paragraph 157 of the draft guidance states that a CPP may choose to identify localities through formal boundaries or take account of other factors which can identify local civic identity and attachment. The Guidance continues (paragraph 158) that "in practice we expect CPPs will often identify small communities (with populations of fewer than 10,000 residents) as localities" and that provided criteria are satisfied, the localities may, but need not, be the same as those identified for health and social care integration.
129. This series of consultation questions seeks to understand whether there are factors which would inhibit the use of the proposed maximum population criteria and what the impact would be if that criterion were to be lowered. Under the proposed regulation a locality would therefore have a population of equal to or less than 30,000 with the exception being a local authority ward area being designated as a locality even if that ward area has a population in excess of 30,000.
130. The guidance recognises that locality planning it is not the only means by which CPPs should seek to address inequality and CPPs should fulfil their duty under section 5 of the 2015 Act in other ways including for communities of interest and specific households experiencing disadvantage.
131. 70 respondents replied to this question with a wide ranging and lengthy commentary provided in support of views expressed.
132. Emerging themes in response to this question include: the potential difference of views between rural and urban areas; community involvement in setting locality; balance between size of locality and structures to support implementation; existing locality structures and potential confusion around locality terminology.
Difference between urban and rural
133. Some CPP sought less prescription whilst noting that as largely rural areas the criteria would not impact upon them but may prove more challenging for urban areas.
134. As noted earlier, rural and island respondents were generally less concerned about the 30,000 maximum population criterion identified in the regulation. They did not recognise this as being helpful in establishing localities.
135. Some Third sector respondents rejected the exception proposal to designate an electoral ward area as a locality even where its population exceeds 30,000 on the basis that electoral wards are not necessarily linked to communities. Whilst other third sector and individual respondents considered that CPPs should be encouraged to identify localities of much smaller size.
Community involvement in setting localities
136. A Public Body stated that "A maximum size may be helpful but given the diverse sizes and concentrations of populations perhaps it would more appropriate if the CPPs and communities should have the flexibility to identify the localities and the population size which can support the development of priorities for each CPP. Whilst a CPP added that it "should be left to CPPs, in consultation with the community, to agree the size of localities". They considered that "subdividing ….into smaller areas would undermine work to date, be resource, intensive, and risk jeopardising community buy-in" This concern was voiced by a public body which stated "setting a maximum population size for localities when any size limits risks appearing arbitrary and might inhibit local flexibility "and continued "Communities themselves must be instrumental in identifying a locality that works for them".
137. A third sector respondent who did not directly reply to the yes no element replied that "localities should also be defined by taking into account to where communities feel that they naturally exist, and share a distinct sense of identity and character."
Balance of communities and structures
138. Echoing earlier comments in response to question 6, respondents across categories recognised a potential tension between the appropriate scale of localities and partner's capacity to engage effectively with a locality with a smaller population size. This was envisaged as particularly challenging for those CPP areas where there are more localities experiencing disadvantage relative to the rest of Scotland. A Public Body noted that increasing demand for data and analysis at a more local level may outstrip current capacity of partners to address. Another Public Body respondent encapsulated this tension when proposing that a "locality should be large enough to ensure effective partnership working and small enough to ensure effective community engagement."
Existing locality structures
139. A local authority respondent noted that "The Integration Joint Board has defined localities …. which considerably exceed the 30,000 limit proposed - and as a partnership we would wish to be able to use these localities more generally." They continued "The principle should be to target resources where the need is greatest, rather than to meet specific criteria for population size". The response makes no reference to what the maxima or minima should be in relation to population.
140. Some CPP, Local Authority and Public Body respondents noted that they should have the ability to have a flexible approach to designating localities with the identification of localities mirroring existing sensible structures and arrangements. A CPP favoured "Flexibility to align plans to existing local planning cycles and structures facilitating a streamlined approach which best suits local need". Others welcomed this as an opportunity to develop consistency with other planning structures.
141. A range of respondents also made a number of other suggestions and requests for more information and greater clarity, for example, some have expressed confusion over the term "localities" which is utilised in integrated health and social care plans and also in community planning contexts for locality plans. One CPP respondent commented that "If terminology was changes to reflect that CPPs are working in communities/ neighbourhoods rather than localities that would allow a more comprehensive local approach to be taken".
142. In paragraph 159, the draft guidance confirms that "provided other criteria are satisfied, the localities may, but need not be the same as localities in the CPP area which are identified for the purposes of health and social care integration". Respondents indicate that this may potentially create confusion for both communities and officers when referring to their "localities".