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20Response%20to%20Corp%20Plan%20EIA

Mar 22, 2016

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Page 1: 20Response%20to%20Corp%20Plan%20EIA

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Ove

rvie

w o

f NW

DA

Rol

e: E

xecu

tive

sum

mar

yResidential:

The Corporate Plan emphasises the increased role that sub-regional and local organisations will have in supporting the NWDA to meet its overall aims. Such a strategy can enable a more localised approach to delivery which in turn is better able to respond to the needs of different communities [p.2].

The Corporate Plan does not outline how good practice on equalities will be transferred to sub-regional / local delivery agents.

The corporate plan focuses on the spatial approach (sub-regional / local) taken to service delivery but does not make sufficient reference to the people in receipt of services.

We believe that the corporate plan should highlight the forthcoming Single Equality Scheme. The development of the Equality scheme will involve consultation with delivery agents and thereby ensure buy-in to the NWDA's commitment to equality and diversity.

The Corporate plan should identify that the agency will develop a clear process for implementing Equality Impact Assessments on projects funded by/through the LDA (Single Pot and ERDF).

The Corporate plan doesn’t make any mention of the good practice that the agency has undertaken. In particular we believe that the involvement of disabled people in the development of the Disability Equality Duty was praiseworthy and received plaudits from the then Disability Right Commission.

Such initiatives will be continued in the development of the forthcoming Single Equality Scheme.

Make explicit mention of the progress that is currently being made on implementing EIA's. Note that the ERDF programme underwent an EIA.

Page 5-6 the plan specifically sets out the Agency’s commitment to implementation of the Regional Equality and Diversity Strategy.

Page 5-6 the commits to undertaking EIAs for all relevant activities and programmes including those of partners.

Annex 4 page 70 sets out summary review of progress.

Page 5-6 the commits to undertaking EIAs for all relevant activities and programmes including those of partners.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Redistributive:

The corporate plan does acknowledge the economic pressure of an ageing population and the reduction of the working age population. It does not identify how this impacts on other diversity strands, for example the link between in-migration processes and social cohesion [p.3]

The Executive Summary makes reference to the NWDA's role in managing the new ERDF programme [p.5].

The plan does acknowledge the existence of cross cutting themes – sustainable development and equality and diversity [p.5].

It does not identify how this impacts on other diversity strands, for example the link between in-migration processes and social cohesion.

The Summary does not demonstrate how the NWDA will take account of the impact that projects will have on groups that have a legacy of discrimination.

The Plan does not elaborate about how equality and diversity will be mainstreamed as a cross cutting theme – whilst this may not be required in the executive summary it does need to be picked up elsewhere in the document and can highlight the role of the sub-regional diversity leads, diversity champions and the Single Equality Scheme.

Include reference to the NWDA's commitment to the implementation of EIAs

Somewhere in the document it may be useful to state how equalities is mainstreamed in the NWDA's work and then provide an introduction to it as a cross-cutting theme.

Page 5-6 the commits to undertaking EIAs for all relevant activities and programmes including those of partners.

Individual objectives include a section on embedding E&D. Page 16 – Plan sets out a business case for mainstreaming E&D.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Recognition:

The corporate plan acknowledges the role that equality and diversity will play in delivering the plan: 'In delivering this plan we will support the principles of sustainable development and equality and diversity and economic opportunity for all which are embedded within the RES' [p.5].

Where the Executive Summary defines the challenges that it faces it successfully identifies diversity as part of this – an ageing population and a reduction of the working age population [p.3].

.

The Corporate Plan demonstrates how the NWDA takes an integrated approach and references to other appropriate strategy documents, for example the Regional Economic Strategy [p.2].

Overall the executive summary does not demonstrate why equality is important for the Agency and how it seeks to engage in and respond to equality issues.

Identifying these linkages could be built upon in other areas of the summary and throughout the Plan.

The Corporate Plan does not consider the issue of an ageing population on other related equality strands. For example in-migration and new communities, the link between an ageing workforce and incidence of disability.

The Corporate Plan does not however outline how equality issues will be picked up within these strategies.

The agency needs to be making the business case as well as the moral case for equality and diversity. It needs to highlight how securing improved GVA will require mainstreamed action to remove barriers faced by various communities who live in the region.

Provide cross cutting examples of where addressing equalities will support delivering against an overall objective. For example consulting with local people to ensure delivery meets the needs of all and especially those from disadvantaged groups.

It is recognised that the ageing population in the Northwest and the reduction of the working age population will be important in terms of the performance of the economy in the region. Given that this is the case NWDA could work further with employers to encourage the employment of older workers.

Page 16 – Plan sets out a business case for mainstreaming E&D.

Individual objectives set out actions for delivery.

Page 16 – Plan sets out a business case for an ageing strategy.

The RES underwent a separate Equality Impact Assessment in 2006

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Reflection/future policy development:

The Executive Summary does enforce the Agency's commitment to evaluation and monitoring and makes reference to a three year evaluation plan and toolkit covering all projects and programmes [p.6].

At present the Plan does not identify if this will include specific equality and diversity measures.

The Agency will be developing internal and external measures through the Single Pot and ERDF monitoring requirements and the Single Equality Scheme and this is something that the corporate plan should identify

Page 62 – internal and external measures developed as part of the appraisal and performance management and evaluation of programmes/projects specifically focusing on E&D

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Recognition:

The review of the economic position does acknowledge that the aging population and reduction of the working age population will impact on the economy in the Northwest [p.8].

The report does not highlight any activity that is being undertaken to address the impact that the ageing population will have on the regional economy.

This section should outline targeted activity to address this issue.

Page 16 – Plan sets out a business case for mainstreaming E&D.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

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xtResidential:

The policy outlines a shift towards more local delivery, this presents an opportunity for delivering more tailored services that meets the needs of local communities [p.9].

The NWDA have a responsibility to develop employment creation in or near deprived areas, focused on HMR areas (housing market renewal), Urban Regeneration Companies, and Halton and Knowsley. In the Northwest these are: areas of East Lancashire (Pendle and Rossendale, Burnley, Blackburn with Darwen and Hyndburn); Salford, Liverpool, Sefton and the Wirral; and Oldham and Rochdale [p.12].

The Corporate Plan identifies some key areas for development, for example the growth of Manchester and Liverpool John Lennon airports [p.13].

There is not a clear reference to how the NWDA will try to support sub regional / local delivery partners to meet the needs of different communities. Something that is very much part of SNR.

The plan does not emphasise the importance of considering the impact that such developments will have on specific local communities.

Corporate Plan could outline how good practice on equalities will be transferred to sub-regional / local delivery agents.

Many of the HMR areas in the Northwest have a high percentage of BME residents so it would be useful to ascertain how employment creation work will reflect this.

Highlight the role of Equality Impact Assessments (EIAs) in ensuring that all communities benefit.

Page 62 – internal and external measures to be developed as part of the appraisal and performance management and evaluation of programmes/projects specifically focusing on E&D including with partners.

Page 5-6 the commits to undertaking EIAs for all relevant activities and programmes including those of partners.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Remedial:

The NWDA has identified worklessness as a future priority for research [p.12].

GVA target has been set in the Northwest to one above the average for England – 2.3%. Progress will be measured on the basis of 5 indicators: productivity, employment, skills, innovation and enterprise. NWDA could do work to establish whether there are groups or organisations who could contribute more to the GVA targets or if people are not contributing work to find investigate why this is and how they can be supported to do so [p.9].

The worklessness research and following debate may produce evidence of disadvantage within certain communities, enabling the NWDA to consider specific targeted action.

NWDA could do work to establish whether there are groups or organisations who could contribute more to the GVA targets or and how they can be supported to do so.

Individual objectives set out actions for identification and delivery.

Demographics and Migration paper setting out comparative contribution to GVA produced and will inform Economic Strategy.

Redistributive:

The Policy Context draws attention to the RES Transformational Actions, one of which states 'Deliver the Regional Equality and Diversity Strategy' [p.13].

The context does not identify any achievements against this strategy to date.

The corporate plan needs to identify what the Regional Equality and Diversity Strategy has managed to achieve. It will be important for the NWDA to ensure that targets within the Regional Equality and Diversity Strategy are clearly defined and measurable

Annex 4 page 70 sets out summary review of progress.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Recognition:

The Policy Context outlines the NWDA's new responsibilities some of which have particular implications for equalities [p.9].

The Agency will retain its responsibilities as a Specific Consultation Body [p.11].

The Plan does not refer to the steps that have been put into place to ensure that the Single Regional Strategy considers equality issues.

There is no reference to how the NWDA has conducted such consultation in the past and the impact that this has had. Or how it proposes to engage communities in the future.

The Corporate Plan should identify that the agency is in the process of developing awareness of the EIAs. The importance of ensuring that the needs of equality groups are considered within the Single Regional Strategy is essential.

The Corporate Plan should highlight that consultation provides the NWDA with an opportunity to engage with communities who are often neglected from the consultation process – for example disabled people, those from certain ethnic backgrounds etc.

Page 5-6 the commits to undertaking EIAs for all relevant activities and programmes including those of partners.

Individual objectives set out actions for identification and delivery which will include consultation with relevant delivery bodies.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Reflection/future policy development:

The NWDA will be tasked around outcomes with the focus on a single overarching growth objective for the region – GVA per head [p.10].

The region will be monitored against the GVA/head objective and Government will also measure progress in the Northwest on the basis of 5 indicators: productivity, employment, skills, innovation and Enterprise [p.10].

The policy context refers to services being delivered by partners and the need to set outputs/outcomes [p.9].

The NWDA has taken the positive step of conducting research regarding the demographics of the region [p.12].

It will be important for the NWDA to consider how it will measure the outcomes for particular groups. An increase in the regions overall employment rate may not mean that all groups have benefited due to continued disadvantage and discrimination.

How will this measure identify the impact on particular groups?

The NWDA must ensure that such arrangements are, where relevant, subject to an EIA.

Again the corporate plan will need to develop monitoring processes to ensure this kind of analysis is possible. This is again something that the Equality Scheme should pick up.

Where reasonable and appropriate to do so consider measuring against groups that have faced a legacy of discrimination and disadvantage. For these categories gender, disability, race and ethnicity may be particularly important.

This may provide the opportunity for the Agency to influence the way that partner organisations tackle equality issues. The agency may consider setting targets regarding the profile of beneficiaries for specific services.

Once this has been completed will there be an opportunity for delivery to respond to the local / sub regional and regional need? If so highlight this?

Page 62 – internal and external measures to be developed as part of the appraisal and performance management and evaluation of programmes/projects specifically focusing on E&D including with partners.

As above

As above

Performance framework designed to inform and improve future delivery

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

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Residential:

The review of progress against Corporate Plan 2005 – 2008 identifies a range of substantial achievements across Business Development, Skills and Employment, and Infrastructure [p.15].

The NWDA has not identified the particular impacts that this has had on specific groups.

Will be identified as part of the annual impact evaluation reports.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

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Them

esResidential:

The Corporate Plan does state that the Agency will ensure that objectives address the challenges faced by communities [p.16].

Recognition:

The chapter positively highlights the role of equality and diversity as a cross cutting theme: 'These objectives take an integrated approach to social inclusion, equality and diversity, under represented groups and the needs of rural areas in the region through a mainstreamed approach to their delivery' [p.16].

The chapter also states that the 'principles' of equality and diversity have been applied in developing the objectives [p.16].

The Plan does not go on to state what these may be and how community's needs would be taken into account.

There is no explanation about how this will be achieved.

Despite this statement there is little indication within the objectives of the needs of different equality or how services may need to the delivered differently to remove negative impact or promote a positive impact.

Again could highlight the role of the forthcoming Equality Scheme and the opportunity this presents.

Page 20 – signals commitment to mainstreaming E&D in developing objectives.

The Agency publishes a Racial Equality scheme which sets out the actions we will undertake in support of the efforts to tackle social and economic exclusion.

All objectives now set out specific actions for dealing with E&D.

Objective 1: Sectors

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Recognition:

Objective 1: Sectors - outlines the importance of growth in priority sectors. Objective 1 also states that activity will consider cross-cutting themes [p.19].

The objective details the intended spatial benefits but does not define any groups which are under-represented within various sectors. Equality and diversity is not explicitly acknowledged as a cross cutting theme.

The corporate plan should highlight the positive activity that could be undertaken to support those that are under-represented in the certain growth sectors.

Page 28 – objective commits to engaging with all especially those from underrepresented groups.

Objective 2: Enterprise support

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Redistributive:

Objective 2 relates to the improvement of formation, survival and growth rates of enterprise [p.22].

It is recognised that the Northwest is a diverse region, some groups or communities are still underrepresented within enterprises especially SMEs and have also been found to face the highest level of failure of outcomes as they do not actively participate and share in the benefits of economic growth. Combined with a historical legacy of lack of enterprise awareness, aspiration, skills and capabilities this locks communities into a cycle, which does not foster enterprise leading to poverty of opportunity for individuals resulting in disadvantaged communities [p.22].

Enterprise has traditionally been a sector that attracts those disadvantaged by more generic business sectors.

There is an opportunity for positive action – assess the uptake of services for specific groups and consider developing services relevant to those that may require a different approach.

It would be interesting to see which groups/communities this refers to and if there are any particular geographical areas it affects. Specific targeted work might be needed.

Again both the Single Pot Programme and the ERDF will be targeting those groups (women, BME, people with disabilities and older people).

Page 30/31 - objective commits to engaging with all especially those from underrepresented groups in line with the RES.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Redistributive:

Objective 4: Internationalisation – identifies that the NWDA will work to 'overcome the social-network barriers in terms of language and cultural differences' [p.27].

This may provide an opportunity to consider the impact of globalisation, immigration and social cohesion. This is an important element and one which is likely to direct attention over the next three years.

Page 37 - objective commits to engaging with all especially those from underrepresented groups.

Objective 5: Leadership and management

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Redistributive:

Objective 5: Leadership and Management – increase the proportion those in employment in the Northwest who are in senior management who hold an appropriate higher-level qualification. The objective appreciates that programmes will need to be targeted to meet sub regional needs [p.30].

Remedial:

Objective 7 makes a reference to institutional co-ordination failures [p.29].

As well as specific regional needs there will be specific needs for groups that are under-represented in management post.

The Plan does fully describe how the NWDA will monitor and address these institutional failures.

Does the Leadership and Management Framework for Action monitor the characteristics of those benefiting from it and upon analysis whether the development of a targeted management programme is required?

Again there are issues for under represented groups and meeting their diverse leadership and management needs.

Identify the work that is being undertaken to raise the profile of equalities in NWDA and delivery partners, through the development of the Single Equality Scheme and the EIAs.

Page 39 - objective commits to engaging with all especially those from underrepresented groups.

Page 44 - objective commits to engaging with all especially those from underrepresented groups.

Objective 6: Higher level of skills development

Redistributive:

Objective 6: Higher Level Skills Development – outlines a partnership approach to developing the skills required by employers [p.31].

There is no text to outline the variable level of higher level skills across the equality strands.

Page 41 - objective commits to engaging with all especially those from underrepresented groups.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Objective 7: Size of the workforce

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Objective 7 does provide a backdrop to the equality and diversity work within the NWDA and raises its profile within the Corporate Plan. It makes links between achieving the target and equality; for example increased employment rates and employment for disabled, women, older people, and under-represented and marginalised groups [p.33].

Residential:

Objective 7 develops the spatial approach to the NWDA's role by linking it to key groups. It not only lists employment projects but states that 'All projects will support those furthest from the labour market' [p.34].

Remedial:

The objective makes direct reference to supporting BME/women owned businesses [p.34].

Redistributive:

Objective 7 recognises the economic/social imperatives for addressing worklessness and that groups need to be targeted; those on Incapacity Benefit (IB) [p.33].

The direct link between the workforce objective and equality is made and other sections of the report would benefit from this approach.

Enterprise/business ownership is often high within disadvantaged groups. If rates are particularly high in the Northwest the NWDA may consider how it can not only support BME/women owned businesses but also promote inclusive recruitment practice in the region.

The objective alludes to the fact that the City Employment Strategy will seek to move people from IB into employment but this is not explicit.

Consider developing the Plan with more explicit reference to equality and diversity as a cross cutting theme.

Page 44 - objective commits to engaging with all especially those from underrepresented groups.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Objective 8: Employment sites and enterprise

Remedial:

Objective 8: Employment Sites and Premises. The objective outlines the NWDA's role in developing key employment sites and premises [p.35].

The objective does not define the needs of particular groups and the importance for buildings to reflect the needs of the population. This is particularly important when considering the accessibility of the built environment for disabled people and the requirements of the DDA.

Consider providing guidance or signposting people to information regarding accessibility of premises and sites.

Page 46 - objective commits to engaging with all especially those from underrepresented groups.

Objective 9: Conditions for private sector investment

Recognition:

Objective 9: Conditions for Private Sector Investment reports how the NWDA will improve the physical conditions for increased private sector investment in the key regions in the region [p.37].

The NWDA has the ability to influence planning but the objective does not show how consultation will occur with people in the affected regions and how it will involve all groups within the area.

Outline a clear mechanism for consulting with different groups some of whom are difficult to reach.

Page 49 - objective commits to engaging with all especially those from underrepresented groups.

Objective 10: Adapting to climate change and increasing sustainable resource use

Objective 11: Marketing the region

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Marketing the region: work to be done in relation to improving the negative perception of the region by promoting its opportunities and strengths e.g. cultural attractions in Liverpool and Manchester [p.41].

The chapter could consider if there is a positive link between cultural attractions and the region's diverse communities.

Page 52 - objective commits to marketing the region in manner which reflects the regions cultural diversity.

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Residential:

Chapter 6 positively identifies the need for partnerships to allow the Agency to achieve its goals [p.43].

The Chapter does not elaborate about how these partnerships will allow the Agency to support the agency to address disadvantage, for example by linking with the VCO sector in consultation or working with the private sector to promote the business case for equality and diversity.

Consider developing a programme which encourages business to engage with the agency around diversity issues and be a conduit for good practice.

Be clear about who are you targeting, for example is there a recognition that differing communities may have different perceptions regarding the region as a tourist/business attraction and that these perceptions may be influenced by a range of factors, including race and gender.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

Redistributive:

The NWDA will be responsible for the ERDF [p.44].

Chapter 6 outlines the Agency's commitment to equality and diversity and identifies that it is central the region's economic success [p.46].

Chapter 6 also contains the Agency's CSR statement and it is encouraging that this identifies the linkage between CSR and equality and diversity [p.47].

The Plan does not demonstrate the role of EIA's in the funding process.

The section does not define the different groups encompassed by equality and diversity or the targeted equality activity that is undertaken.

The statement that equality and diversity is central to economic success demonstrates that the NWDA is conscious that equality is a key area of their work, but this does not always come through the rest of the document.

Ensure the EIA process is developed, implemented and that all partners understand their importance.

More comprehensive information is required. Potential areas to address include:

How equalities will be mainstreamed

A statement regarding the equality performance measures in place

Detail of any targeted projects Internal equality training Impacting on procurement.

Page 5-6 the commits to undertaking EIAs for all relevant activities and programmes including those of partners.

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Strategic Activity and the 5 R's Gaps / Risks Recommendations NWDA Response

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Reflection / future policy development:

The Plan rightly emphasises the importance of monitoring and evaluation [p.49].

It does not however mention a commitment to monitoring and evaluating certain aspects of the organisation against equality measures.

The development of the NWDA's Equality Scheme will support this process.

The NWDA is committed to using evaluation evidence to inform its decision making and further improve the effectiveness of future programmes. Evaluation can be used to identify discrimination of both individuals and organisations thus the agency can provide a better service for these groups.

Page 62 – The Agency will be developing measures to capture the impact of its activities in line with our Single Equality Strategy as part of its appraisal, performance monitoring and management and evaluation.

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Reflection / future policy development:

Chapter 8 briefly outlines the steps that the NWDA is to take to improve its overall effectiveness [p.51].

The NWDA is in the process of developing the way that it responds to equalities and by 2008 it is anticipated that the organisation will have taken significant steps forward. This work is not reflected in the current plan.

Developing internal processes and practices will enable the Agency to better advise wider stakeholders about becoming confident in equalities. The plan has identified equality challenges, e.g. an aging working population and this chapter provides the NWDA with an opportunity to state how it will respond internally.

Future policies/developments will undergo EIAs to ensure they are in line with our Single Equality Strategy.

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Remedial:

Funding to programmes will be reduced through a mix of financial reductions and VFM savings [p.52].

The NWDA will need to decide how it best targets its resources, for example concentrating on projects/programmes that seek to engage those that require the most support and are the hardest to reach.

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