Vivienne Nicoll, Evening Times

A group has been set up to help people tackle problems with their properties and their communities. One of the issues it will focus on is how homeowners can deal with factors who fail to deliver the services they should.

The Govanhill Community Empowerment Project aims to give people the knowledge, skills and confidence they need to confront problems.  It plans to educate individuals about their legal rights in relation to property law, anti-social behaviour and other important issues that affect day-to-day lives.

Project bosses recently made a submission to the Glasgow Factoring Commission, which was set up by the city council to look at problems surrounding property management. It was formed after the Property Factors (Scotland) Bill was passed by the Scottish Parliament in March.

When it becomes law on October 1, the Act will make it an offence to operate as a property factor unless they are registered with the Scottish Government. The registration requirement will apply to existing and new property factors.

Govan Law Centre, which set up the Govanhill project, worked with others in the campaign for the new law.

Project spokesman Damien Cohen said: “We welcome the new law on factors, which will give homeowners more rights when factors provide a poor service. But having rights and knowing how to use them are two different things. There is a real need to raise awareness about these new rights.”

“That kind of empowerment will improve the common property and environment and give people confidence and improve their well-being. People will feel more in control of their lives and there will be increased pride and confidence in the area they live.”

The Govanhill Community Empowerment Project, one of the first public legal education services to be launched in Scotland, is open to anyone living in the area. It may be extended to other areas at a later date.

A council spokesman said: “The Commission is looking at all issues to do with factoring in Glasgow and is due to report on its findings at the end of the year. There is undoubtedly a shared responsibility for common property, so anything that encourages people to become more involved in the continuing maintenance of their homes has to be welcomed.”

The Scotsman Tuesday 4 September 2012

I have followed with great interest the recent debate in your letters page regarding wind turbines and in particular those regarding community benefit. 

Several letters have conflated community benefit payments, with joint ventures and community-owned turbines, but these are very different types of projects. Community benefit payments are typically associated with privately owned, large-scale renewable projects, such as wind farms. In these instances, the project is developed by a private developer and landowner, who then retains a majority of the revenue generated from the site.

Projects such as the one by the Neilston Development Trust (NDT), referred to by Aileen Jackson (Letters, 29 August), are joint ventures, in this case between the developer Carbon Free Developments and NDT. 

This project will see the community receive an estimated £10 million over the next 25 years, because NDT secured the finance to allow it to invest in the project, taking a share in the risk and reward. 

Neilston is in the lowest 10-15 per cent of the Scottish Government’s Index of Multiple Depravation; these turbines will provide a sustainable and secure income for the area for a generation.

The website of the Neilston Community Wind Farm outlines ambitions plans to regenerate the town through its “Neilston 2030 Vision” to create a “sustainable, economically robust, well planned and well connected small town”.

I would argue that rather than this being an example of “selfishness” it is a commendable example of a community seizing an opportunity to take its future into its own hands. 

‘The third type of community involvement in a wind project is a community-owned development, initiated, developed and realised by communities and where all the revenue is retained locally to be used and distributed how the community sees fit.

One recent example can be seen on the western side of the Isle of Lewis. Here, a 900Kw turbine was installed and is set to generate up to £100,000 annually for the Dalmore, Dalbeg and South Shawbost communities. 

The area has long struggled with depopulation and fuel poverty and it is hoped this new stream of income will help to re-generate the local community. 

When communities develop their own renewable energy projects they are playing a vital role in the global climate change agenda and can also directly address other pressing socio-economic needs. It is understandable that members of the local population may have reservations about wind developments. But these projects are not taken lightly by anyone involved. 

Seeking planning permission is a complicated and lengthy process – and rightfully so, but when communities are involved, there is greater transparency and opportunity for input from a wide variety of viewpoints. 

Perhaps we will never all see eye-to-eye when it comes to wind turbines, but no energy source comes without a cost. Community-owned project are a beacon for all those who believe we must take greater responsibility for our own energy generation and use. 

NICHOLAS GUBBINS

Community Energy Scotland

Dingwall Business Park

Dingwall

From Scottish Govt website:

The Scottish Government is committed to generating innovative and radical proposals on land reform that will contribute to the success of Scotland for future generations. 

The relationship between the land and the people of Scotland is fundamental to the wellbeing, economic success, environmental sustainability and social justice of the country. The structure of land ownership is a defining factor in that relationship: it can facilitate and promote development, but it can also hinder it. In recent years, various approaches to land reform, not least the expansion of community ownership, have contributed positively to a more successful Scotland by assisting in the reduction of barriers to sustainable development, by strengthening communities and by giving them a greater stake in their future. The various strands of land reform that exist in Scotland provide a firm foundation for further developments.  The Government has therefore established a Land Reform Review Group. 

The Group will identify how land reform will: 

• Enable more people in rural and urban Scotland to have a stake in the ownership, governance, management and use of land, which will lead to a greater diversity of land ownership, and ownership types, in Scotland; 

• Assist with the acquisition and management of land (and also land assets) by communities, to make stronger, more resilient, and independent communities which have an even greater stake in their development; 

• Generate, support, promote, and deliver new relationships between land, people, economy and environment in Scotland; 

In making these inquiries, the Group will bear in mind: 

• the sustainability of its proposals for reform, including their economic impact; 

• the importance of good stewardship and governance of land; 

• the relationship between urban and rural concerns and opportunities; 

• the relationship between local and national interests. 

The Group will: 

• be provided with a Secretariat; 

• have access to Ministers, special advisers, and officials (including legal advisers) throughout the Scottish Government, including its agencies; 

• commission independent research, as appropriate; 

• agree, at the outset, a workplan with Ministers. 

The Group will: 

• seek representations from, and consult with, organisations (private, public and voluntary sector) and individuals with an involvement or interest in land ownership, farming, crofting, forestry, the natural heritage, social and affordable housing, planning, economic and community development, and with others as appropriate; 

• draw on the advice of the Advisers appointed to it; 

• make its own independent assessment of this advice and of the varying (and possibly conflicting) views put to it. 

The Group will make: 

• Interim Reports to Ministers on such improvements as the Group considers can readily and speedily be made to existing legislative and other means of bringing about land reform; 

• a draft Final Report to Ministers by December 2013. 

It is expected by the Government that the Group’s Final Report will include: 

• recommendations as to how, by legislative and other means, further land reform can be promoted and secured; 

• an indicative analysis of the economic, social and environmental impact and sustainability of its proposals 

• indication of how the impact of the recommendations on land reform might be measured, monitored and otherwise assessed. 

23rd August 2012. 

Land Reform Review Group 

Chair: Dr Alison Elliot 

Vice Chairs: Professor Jim Hunter & Dr Sarah Skerratt

Land Reform Review Group B1 Spur Saughton House Broomhouse Drive EDINBURGH. EH11 3DX   

Pride in Place: Tackling Incivilities – A Policy Summary

Douglas White Carnegie UK Trust, 2012 

Local environmental problems – or incivilities – can have a serious and long-lasting impact on wellbeing and quality of life for individuals and communities. Issues such as vandalism, graffiti, litter, dog mess and discarded rubbish really matter to people and have a disproportionate impact on those living in the UK’s least affluent communities.

These important local problems however, are currently falling through the gaps in in the environmental and social policy discourse and are too often seen as trivial and unimportant issues.

The Carnegie UK Trust is concerned that society does not give sufficient attention to the problem of environmental incivilities. This policy paper highlights the wide ranging positive impacts that community led approaches to tackling environmental incivilities can bring about and calls on national environmental charities, government and funders to consider how they can support and empower more communities to take on environmental incivilities in their own area.

This Policy summary is underpinned by two, more detailed research papers which can be downloaded here:

Pride in Place: Tackling Incivilities – Desk Based Research Report: Which contains the findings of our in depth literature review.

Pride in Place: Tackling Incivilities – Case Study Research Overarching Report: Which draws together the findings from eight case studies of successful community –led projects to tackle environmental incivilities from across the UK.

Individual fact sheets for each of the eighth case studies featured in the report are also available:

•    Springhill Garden of Reflection, Belfast 

•    Bredhurst Woodland Action Group, Kent 

•    Civic Pride, Lancashire 

•    Tipton Litter Watch, Sandwell 

•    Urban Eye, London 

•    Llwynhendy Growing Spaces project, Llanelli 

•    Redruth Brewery Leats project, Cornwall 

•    Clean Glasgow, Glasgow

The New York Times, by Daniel P Aldrich, 28.08.12

HURRICANE Isaac, which made landfall in Louisiana recently, not only disrupted the Republican National Convention but also brought back painful memories of Hurricane Katrina, which devastated the Gulf Coast seven years ago.

In August 2005, my wife and our small children and I evacuated to Houston just before the storm destroyed the New Orleans home we had moved into six weeks earlier. We took with us just a bag of toys and a suitcase. We applied for federal aid, but especially in the immediate aftermath, it was family, friends and friends-of-friends who came through for us.

As a political scientist (I taught at Tulane at the time), I decided to study how communities respond to natural disasters. I’ve concluded that the density and strength of social networks are the most important variables – not wealth, education or culture – in determining their resilience in the face of catastrophe.

Take, for example, the densely populated region around Kobe, Japan, where an earthquake struck on Jan. 17, 1995, setting off more than 200 fires and killing 6,400 people. In the neighborhood of Mano, local residents self-organized into a bucket brigade and doused the flames, while in nearby Mikura, residents stood by helplessly as the fires destroyed their homes and businesses. The residents of the two inner-city neighborhoods were of roughly the same age and social class. But residents of Mano had forged bonds of trust through civic and voluntary activities, including efforts to combat pollution, while Mikura’s communal experiences were far more limited.

Similarly, after the Indian Ocean tsunami of 2004, rural coastal villages in the Indian state of Tamil Nadu followed very different arcs of recovery. From survivors in the temporary shelters around the city of Nagapattinam, I learned that the villages that had formed and maintained relationships with local government officials and foreign aid workers – in many cases, via women who spoke at least a little English – were able to secure disaster relief more quickly, and distribute it more efficiently, than equally poor villages that did not have outgoing and well-connected residents.

The earthquake, tsunami and nuclear meltdown around Fukushima, Japan, in March 2011 also demonstrated the importance of social capital. Those who were able to flee (often with help from neighbors and friends) moved in with people they knew rather than into the public shelters. While some towns offered incentives to lure back former residents, many who returned did not apply for aid because of onerous paperwork rules. Instead, they told me, they came back to re-establish friendships and daily routines.

Social scientists know that communities that are relatively homogeneous, with honest government and a history of cooperation and civic engagement, have deeper reservoirs of social capital. I would argue that even in diverse countries like the United States, social capital can be built, not just passively acquired.

First, whether in small towns or big cities, there are always people who choose to go the extra mile to get to know their neighbors – an inexpensive tactic that builds social capital – while others are content to hunker down.

Second, local governments and community associations can follow the example of Japan, which gives money to local communities to hold “matsuri,” or small-scale festivals, so that neighbors – including shut-ins and the elderly – can get out and meet one another. Officials in cities like San Francisco, Seattle and Santa Barbara, Calif., have put on such events as part of disaster preparedness.

Third, civic engagement can be enhanced through structured discussions. Teams led by researchers from Harvard and the London School of Hygiene and Tropical Medicine convened focus groups in Nicaragua and South Africa of people who had never met to debate issues like youth literacy, women’s rights and AIDS prevention. The meetings enhanced members’ trust in the other group members, as well as in society and the government more generally. Politically engaged residents plug into existing institutions.

Finally, there is evidence that “community currency” programs, which reward volunteers with an alternative currency that is accepted by local merchants, deepen social networks. 

 A successful form of community currency, also called complementary currency,  was used in the impoverished city of  Curitiba, Brazil. In the 1970s, garbage piled up in shantytowns where the streets were too narrow for trash trucks.   There was no money for a physical fix, so officials offered residents bus tokens and plastic chits exchangeable for food and other goods if they brought garbage to bins placed outside the neighborhoods.  Eventually, more than 70 percent of households participated, an under-used bus system prospered, improved transportation increased employment, the neighborhood was clean,  recycling increased, children had school supplies and improved nutrition, and general health and quality of live got better, all with minimal cash outlay.    

Research in Japan has shown that residents of communities with such programs had greater trust in their government officials than other residents did.

Just as the focus of Western development aid to poor countries has shifted from roads, power plants and factories to productivity, skills and entrepreneurship, so should the field of disaster recovery focus on enhancing resilience – people power – not just physical infrastructure.

There’s no doubt that speedy, efficient distribution of emergency shelter, food, medical care and clothing are among the essential responsibilities of government. But at a time of scarcity, with governments and charities facing financial strain, a focus on the social infrastructure of vulnerable communities may be the best (and most cost-effective) survival strategy.

Glasgow City Council was awarded the top prize for Community Involvement at last night’s Scottish Awards for Quality in Planning. Facing off competition from all around Scotland, Glasgow’s ‘Stalled Spaces’ initiative was awarded the top prize in the Community Involvement category by Planning Minister, Derek Mackay MSP. Glasgow City Council’s Stalled Spaces initiative focuses on the temporary use of vacant or under-utilised land to deliver a range of projects, enabling physical renewal and fostering community empowerment throughout Glasgow.

Alistair MacDonald, Head of Planning and Building Control Services, Glasgow City Council:

“This is a wonderful accolade for a project which is helping to breathe new life into the heart of communities across our city. Glasgow’s innovated approach to utilising stalled construction sites or land for community benefit is a great example of people working together to make a real difference to their local area.”

“I want to take this opportunity to congratulate the Stalled Spaces team for a job well done. We hope that this award will help to promote the Stalled Spaces initiative to a wider audience and encourage more communities, developers and organisations to get involved.” 

Planning Aid for Scotland was invited to assist this year’s judging panel in the Community Involvement category. Petra Biberbach, Chief Executive, Planning Aid for Scotland:

“Glasgow’s Stalled Spaces initiative has been recognised by the Quality in Planning Awards as an innovative example of community involvement in the planning system. It is encouraging to see such a strong partnership approach between the Council, its partner organisations and the many communities around the city, where the people are empowered to make positive changes in their environment.”

Derek Mackay MSP, Minister for Local Government and Planning:

“This is the first year that I have had the pleasure of championing the Scottish Awards for Quality in Planning.  With all of the recent commitment that has gone into planning reform, I am delighted that this year has produced a high number of good quality applications.”

Argyll and Bute Council received a commendation in the Community Involvement category for its Craignish Community Plan, whilst the overall winner at the Scottish Awards for Quality in Planning was Falkirk Council for its Falkirk Greenspace Initiative.

Mark Shucksmith,  Guardian, Friday 17 August 2012 

Projects in the US and across Europe show how localism can work to improve rural communities – but the policy still requires investment

Successful models of localism exist in countries across the world, while here in the UK communities and neighbourhoods have very uneven capacities to help themselves when local funding is cut. The coalition government’s localism policy calls for power to be passed from the central state to local government, and then from local councils to neighbourhoods or communities. But this call has been accompanied by a 31% cut in funding to local authorities and a 46% cut in their capital funding – leading many to ask whether the localism agenda is genuinely about encouraging local empowerment.

My research has looked at how communities in rural Britain can thrive in the face of these challenges. One way to find answers is to look to examples in other parts of the world, such as the US and Europe, where localism has been implemented very differently.

A common approach in America’s small communities is to find anything that can be a niche – or that other people don’t want. One rural area has attracted many call centres, providing local employment, because the local accent appears attractive and intelligible to callers across the US. Other regions have competed to bring in state prisons or other “toxic” activities, but these are often low-wage industries and can be damaging to rural environments.

Another good example is Seneca, already known for inspiring the film It’s a Wonderful Life. Here the community takes much of the refuse from New York City, which over the years has grown into a mountain known locally as “Mount Trashmore”. This does provide vital income and jobs for an area which would otherwise lose population, but many feel it is not an ideal solution.

In European countries, such as France or Norway, small communities may still retain a lot of power. In Røros in Norway, local people worked together when the main employer – a vast copper mine – closed down. It is now a world heritage site with a vibrant tourism economy. At a disused quarry in Sweden, local people and their national and international networks worked together to create a unique new venue for opera.

Localism takes on a different meaning altogether in countries such as Finland, Sweden and Hungary; they hold their own rural parliaments where villagers from across the country assemble and discuss important issues with ministers and civil servants. This same idea is currently under debate in Scotland, where there is a manifesto commitment to introduce a rural parliament.

Localism in these countries is not only about giving real power and responsibility to individuals and communities. It also involves governments (local and central) supporting these actions, building capacity to act and investing as an enabling state – not becoming an absent state.

Rural areas in developed countries countries will experience rapid and uneven change as the countryside, like everywhere else, is affected by globalisation, new technologies and migration. However, research shows that the ability of rural places to adapt and thrive in the context of such changes is that much greater where the people who live there can think about and influence how they change and develop, with the support of an enabling state.

Some rural communities are already doing this effectively but most communities need support to build the necessary skills, trust and institutional capacity.

Professor Mark Shucksmith is director of the Institute for Social Renewal at Newcastle University. His latest book, Rural Transformations in the US and UK, is published by Routledge.

Philip Colligan, 15.08.2012

For a copy of the full report click here.

Last week Nesta and the RSA published a report by Ben Rogers calling for citizens to be trained in how to stop fights and intervene in anti-social behaviour. As you’d expect, the report generated some interesting debate.

The message from the Police Federation was unequivocal – police don’t have time to train citizens, we’re far too busy already. Others argued that citizens should stay away from trouble at all costs, that they’d only get injured or worse. Another popular response has been to blame the government’s austerity measures and call for more police instead of vigilantes. 

I worry that we may be missing the point. 

Let’s take the argument back to its basics. Over many generations, we have accumulated a vast amount of knowledge that can be put to good use if we can get it into the hands of citizens. 

Often that’s about helping people make better choices for themselves or their families. From the advice that our doctors give us to stop smoking or eat more healthily, to the advice that midwifes give new mums on breastfeeding. We have integrated knowledge transfer from professional to citizen into our model of public services. 

I’d argue we haven’t done nearly enough, but in lots of fields it’s now core to what professionals do. 

In some areas we’ve even introduced laws and regulations that require people to have a level of knowledge and competence. The Highway Code is a great example. As more people took to the roads in big heavy lumps of metal that move, it became important to formalise the knowledge about what constituted safe road use. For drivers, that led to the introduction of licensing and the driving test. 

A more recent innovation has been the introduction of speed awareness courses as an alternative to fines, with apparently good evidence that the courses have a positive impact on future driving behaviour, while fines have no effect. 

It’s only a small step from these innovations to providing knowledge that can enable citizens to support each other. 

It’s not about public services retreating. It’s about recognising that value doesn’t only come from tax payer funded professionals doing things to people. With a little imagination, we can equip people with the knowledge and confidence to be useful to others. 

This is the area where I think we haven’t done nearly enough. 

The inspiration for Ben Roger’s report was Surgeon-Major Peter Shepherd who in 1878 came up with the idea of teaching first aid skills to citizens, and created the pioneering St John’s Ambulance first aid course. At the time, the idea caused lots of worry about amateurs causing more harm than good. 

Today, having a population equipped with basic life savings skills is so widely accepted that it’s mandatory in parts of Europe – in some cases a requirement of having a driving license. 

There is surely no doubt that we would all be safer in a society where most people knew the simple, basic actions that could keep us alive in those crucial moments before emergency services can get to us?  

Once you accept that argument, then you open up a whole world of possibilities, some of which at least are already happening. 

The Expert Patient programme, where people who live with a disease provide advice and support to others who share their affliction; the National Childbirth Trust, whose volunteers support thousands of mums and dads; or more recent innovations like FutureYou a new online platform where young people can get support and advice from volunteer mentors – themselves young people – about finding a job or training. 

In all of these examples and many more like them, ordinary people – volunteers – are equipped with formal knowledge that they combine with their own experience, wisdom and judgement to help out other people. 

We need more innovations like these and that’s why Nesta has been working with the Young Foundation on the U, a new citizens’ university that is testing new ultra low cost ways of teaching ordinary people useful skills. 

Is first aid for antisocial behaviour all that different? Clearly there are those who think it is a step too far, but I wonder how many of us have seen something anti-social happening, wanted to intervene, but didn’t have the skills or confidence to do so. 

It’s not about creating an army of have-a-go heroes, but simply putting useful knowledge that already exists into the hands of citizens so that they can put it to use.

Bob Stephens,  Mayor of Springfield, Missouri

How has Springfield, Missouri been able to continue to add jobs and maintain a lower-than-average unemployment rate through the worst recession in 50 years? I would like to suggest to you that our advantages may originate from three non-traditional (or at least, not-often-considered) sources.

First, Springfield is a community that, for whatever reason, collaborates. We don’t really know the source of this high degree of collaboration (might be in the water), but it’s just the way we do things. 

Many communities have an economic development corporation or some similar organization to promote economic development. In Springfield, we have a partnership that promotes economic development, including staff from our award-winning chamber of commerce, but also the city, county, and our locally-owned utility. These players work together as a team to ensure any prospective employer receives seamless, top-quality service while considering where to locate. They provide that same level of service to our existing businesses considering expansion, which has proved to be the source of our growth during the recession. Additionally, we take a regional approach to economic development, truly believing that a rising tide lifts all boats.

Second, it might be our Midwest work ethic. People in Springfield work hard and get the job done instead of just putting in their time. They expect to work hard. This is something else that just seems to be in our heritage. As newcomers arrive, they seem to quickly notice that the bar is raised and they are expected to measure up.

Third, Springfield has recently begun to focus on social capital. Thanks to researchers from Missouri State University (located in Springfield), we’re focused on civic engagement, building relationships, and building trust. These aren’t necessarily the things that most cities focus on, but we are… and we believe that these are the keys to long-term success in our community. Without relationships and trust, nothing else matters.

Of course, it doesn’t hurt that Springfield continues to invest in its top-notch transportation system since we are a transportation cross-roads, has more than 40,000 college students attending 14 colleges and universities that provide companies with a consistent talent pipeline, and is located in the beautiful Ozarks region that provides a great quality of life at costs far less than either coast. And it doesn’t hurt that Springfield’s bond rating actually went up during the recent recession and we are growing manufacturing jobs. But these are advantages that some other cities enjoy, as well, so I’ve tried to focus on a few things that I believe make Springfield unique. It’s working. Springfield and Greene County were near the top of various “job creation” rankings last year. If you’re doing things right, they will find you.

Blog by Kim McKee, St Andrews University

Finally got a chance to sit down and read the Scottish Government’s consultation on the proposed Community Empowerment & Renewal Bill. Underwhelmed is the adjective that first springs to mind. Whilst many of the sentiments are in principal fair enough, there is not really any new thinking or innovation on display here (the Community RTB, enforcing sale of empty buildings, community budgeting, asset transfers – have all been talked about, or are already being taken forward elsewhere in the UK). Given Scotland has historically been a leader in thinking about community asset ownership in the UK context (e.g. CLTs, CBHAs), the lack of new thinking is dispiriting. 

Worst still, there is a surprising lack of connection being made between community empowerment and other government policy areas. The obvious one being the Scottish Government’s recent Regeneration strategy with its focus on community anchor organisations as key regeneration vehicles, supported by the new People & Communities Fund. Why is there no discussion of community anchors in the consultation document? It’s a very useful concept for talking about community controlled and owned organisations that are committed to transforming their local area for the benefit of the people who live there [see my previous post on this]. And there are already lots of great examples of this across Scotland in a multitude of different sectors that could be drawn on.

But the major problem with this document for me, is that it takes as its starting point Community Planning Partnerships (CPPs) which are ultimately local authority vehicles operating at the municipal scale. I would argue if you are genuinely interested in devolving ownership and control to local people then you need to think at a much more local (i.e. neighbourhood) scale, and also give more of a leading role to the voluntary and community sector. Neither of which are common occurrences in CPPs. That’s not to say CPPs don’t have their utility, but promoting grass-roots community engagement doesn’t strike me as one of them.

Another important issue that isn’t picked up in the document is the negative side of the localism agenda. Devolving power downwards may actually exacerbate existing social-spatial inequalities within and between Scotland’s communities. There are several reasons for this, not least the fact that some communities may be more able than others to articulate their needs and command resources (issues such as skills, education, capacity, experience are all relevant here).

Moreover, we should not assume that communities necessarily want to take control – if you look at research in the housing field in many instances local people supported community ownership of social housing as a mean to an end (i.e. to secure investment and improvement in their houses and communities). Where local people are already receiving a good service from public sector providers there may not be any demand for asset transfer -and we should avoid foisting it upon them simply so that assets can be removed from public sector budgets (and thus reduce costs to the public purse).

On a final (slightly left-field) note, I have to say I’m really put off responding to these Scottish Government consultations because of the nature of the respondent form/consultation questions – these are too pre-determined (and often quite technical in focus) and shut off a lot of avenues for debate and discussion…. rather ironic for a consultation on community engagement and empowerment. There is a real need for more open-ended questions that allow some flexibility in how to respond, for responders may wish to respond to different questions to those raised in the document for example.

If you’ve not yet responded to this consultation you still have time to do so. Closes 29th August. (now extended to 26 Sep).