Your name:     Katherine Owen

Organisation (if applicable):Caernarfon Royal Town Council

Email address:clercydref@caernarfontowncouncil.gov.uk

Telephone number:01286 672943

Your address:Institute Building, Pavillion Hill, Caernarfon, LL55 1AS

The Local Government Boundary Commission

Question 1: Is there a need for a Bill to make changes to the constitution and functions of the Local Government Boundary Commission for Wales (“the Commission”) and to make various provisions relating to local government?
Yes	No
Please expand on your answer Caernarfon Town Council supports the Welsh Government’s commitment to reform and modernise the Local Government Boundary Commission for Wales. Legislation is required to enable the strengthening of the Commission’s ability, powers and resources.

Question 2: Do you think the Bill will improve the delivery of the statutory roles and functions of the Commission? (paragraph 3.1 of the explanatory memorandum)
Yes	No
Please expand on your answer The Bill introduces a number of legislative changes that will improve clarity in relation to the Commission’s role and purpose in terms of its work with the Welsh Government and local government, while at the same time allowing flexibility for the future in terms of the Commission’s ability to deal with other public bodies.

Question 3: Do you think the changes being made to the Commission are appropriate? (Part 2 of the Bill)
Yes	No
The Bill explains clear processes for improving the Commission’s functions. They are appropriate and to be welcomed.

Local Government arrangements

Question 4: Do you think the provisions relating to procedures for local government reviews are appropriate? (Chapter 4 and 5)
Yes	No
Please expand on your answer Caernarfon Town Council will support the changes suggested in these sections – specifically, therefore, the need for the Commission to follow a specific procedure for their proposals – subject to the condition that community and town councils have full opportunity to contribute at every stage of every review. Any such arrangements should ensure that the two layers of local government are treated equally in this regard. We support a way of working that is based on true partnership. We would also welcome proposals that give community and town councils the right to appeal to the Minister against the outcomes of local government reviews. In terms of the review of communities, One Voice Wales would wish to see proposals that insist that the Commission publishes how it intends to conduct the review before doing so. There is a need to ensure that community and town councils have adequate time to respond.

Question 5: Do you think the arrangements for local government in relation to: Duties of the Commission Duties of a principal council are appropriate? (Chapter 1)
Yes	No
Please expand on your answer Please refer to Question 4.

Question 6: Do you think the arrangements for local government in relation to: Democratic Services Committees (Section 56) Audit Committees (Section 57) Standards Committees (Section 63) are appropriate?
Yes	No
Please expand on your answer Caernarfon Town Council agrees with the principle of the proposals included in these sections, subject to community and town councils being protected from any detrimental implications as a result of the wider geographical areas that will be created in the wake of establishing joint standards committees. A large number of local councillors already live a considerable distance from the administrative centres where these activities are held.   At the moment, the Standards Committee includes representations from community and town councils and any changes that are introduced as a result of creating joint committees should ensure that this representation is not weakened in any way.

Independent Remuneration Panel for Wales

Question 7: Do you think the provisions relating to the Independent Remuneration Panel for Wales are appropriate? (Chapter 5, Sections 58-62)
Yes	No
Please expand on your answer Yes -

Access to information (Town and Community Councils)

Question 8: Do you think the provisions relating to improving access to information (Town and Community Councils) are appropriate?
Yes	No
Please expand on your answer Caernarfon Town Council agrees with the principle of the direction and outcomes which are aimed for in terms of information for community and town councils in this Bill. However, there is a lack of clear understanding with regard to the implications of that direction for smaller authorities, and a series  of definite guidelines, based on a robust analysis of the needs and requirements of the sector, is required before implementing any proposals to this end.  It is also foreseen that following such analysis this will have resource implications for the Welsh Government. These aspects are detailed further in Questions 11 and 13. Caernarfon Town Council believes that the Bill should allow for specific grant provision for every community and town council in Wales in order to provide for establishing an electronic information link and that it should account for 80% of the resources required to provide information electronically. That would ensure that the sector is equal with other public service providers that receive revenue aid to facilitate this element of the democratic process.

Chairing of Principal Councils (Chairs and Mayors of Principal Councils)

Question 9: Do you think the provisions relating to the Chairing of Principal Councils (Chairs and Mayors of Principal Councils) are appropriate?
Yes	No
Please expand on your answer There are no comments that we wish to add to this question.

General Provisions of the Bill

Question 10: What are the potential barriers to implementing the provisions of the Bill (if any) and does the Bill take account of them?

Please expand on your answer

On the whole, the Bill introduces a number of new processes that we welcome and that will improve the current arrangements.

However, the proposals that enable community and town councils to receive information include potential barriers relating to capacity, expertise, training and / or sufficient funding on behalf of the smaller authorities. In its current format the Bill does not give adequate attention to these barriers. The response to Question 8 sets out the sector’s view on how the lack of current resources should be addressed.

Question 11: What are the financial implications of the Bill, if any? In answering this question you may wish to consider Part 2 of the Explanatory Memorandum (the Impact Assessment), which estimates the costs and benefits of implementation of the Bill.

Please expand on your answer

As noted in Question 10, the potential barriers for many councils would include matters such as capacity, expertise and the need for training and these matters have direct financial implications. 

Providing a website does not necessarily guarantee that the information provided is totally correct, dependable, appropriate, comprehensive and current. It may be the case that a large number of council websites contain interesting information, but it is very difficult work for small institutions to fully and consistently manage the work of providing all the information that local people may expect them to provide.

The explanatory memorandum includes statements on how technical solutions are available to meet these challenges. However, the support offered to councils in terms of the skills, capacity or other elements expected of them to satisfy the public’s requirements in general is scarce. 

Question 12: What are your views on powers in the Bill for Welsh Ministers to make subordinate legislation (i.e. statutory instruments including regulations and orders) (section 5 of the Explanatory Memorandum)?

Please expand on your answer

There are no comments that we wish to add to this question.

Question 13: Are there any other comments you wish to make about specific sections of the Bill?

These comments relate to the proposals for enabling community and town councils to get hold of information.

The overview included in the explanatory memorandum states that a vast proportion of the public now use the internet, e-mail and social networking sites to find information about their local area, to discover what services are available and to contact public bodies. Public bodies themselves also publish a great deal of information about their work, their organization and responsibilities in electronic format. What is not said is that a substantial proportion of those searches do not lead to accessing the required information directly from the relevant public sector body. A possible example of that would be someone looking for information regarding their local surgery or library opening times, when they could have found the relevant information without having to use the local health board or unitary council website.  Indeed, that very example offers some justification in favour of allowing such information transfers on a collaborative stage, rather than encouraging individual bodies to load pieces of information that often overlap with what is being provided by other bodies.

The overview also states that about half of community and town councils have websites already, and there is a clear suggestion in the explanatory memorandum that this figure should increase rapidly. However, the analysis presented here does not make the fundamental point that providing a website does not necessarily mean providing totally accurate, reliable, appropriate, comprehensive and current information. Perhaps, a large number of council websites contain interesting information, but it is very difficult for small institutions to fully and consistently manage the task of providing all the information that local people may expect them to provide.

The impact assessment details some of these matters, by assuming that introducing a Bill will speed up what is likely to happen naturally over a period of time. It is quite possible that that is true, and in that sense, that in itself would not be an inappropriate aim, but there is no clarity in the explanatory memorandum in terms of what exactly needs to be included on community or town council websites. Statements on how technical solutions can be considered are included, but very little is available to help councils with the kind of skills, capacity or other aspects of this challenge that they will require and how best to go about planning the task of regulating the website.

The section on costs and benefits continues to present arguments in the way described above, without giving adequate consideration to those aspects of information provision it most importantly deals with in this regard. The various suggestions for making the task easier for councils includes, mainly, ideas that require contributions from a third party. However, it is unlikely that third party providers will have all the local information required to provide exactly the kind of information that communities would be looking for.

Therefore, there is a need for the guidelines pledged by the Minister in this context to be very comprehensive.