Acting Head of Finance

3rd Floor Westgate House

Market Street
Halifax
HX1 1PS
21st November 2014

Welfare Reform Division

4th Floor Fry Building
NW Quarter
2 Marsham Street
LONDON
SW1P 4DF

By email to: LWP.consultation@communities.gsi.gov.uk

RESPONSE TO
CONSULTATION

THE

LOCAL

WELFARE

PROVISION

IN

2015/16

The consultation paper was issued on 10th October 2014 and Calderdale welcomes
the opportunity to comment on the proposals and questions asked:QUESTION 1 Do you have a preference for options 1, 2a, 2b, 3a, 3b or 4? Please
explain how you have come to this view.

Calderdale would prefer option 4.

The 2015/16 indicative funding settlement issued last February did not include any
monies for the Local Welfare Provision. Options 1 to 3, put forward in the
consultation document, each propose that the funding of the Local Welfare Provision
be met from general funding. This would mean that the overall level of cuts imposed
on local government would be greater than indicated in the provisional settlement
putting yet further pressure on local authorities already stretched budgets.
Calderdale also agrees with the comments put forward by SIGOMA that there will be
greater pressure felt by the more disadvantaged authorities where the need for LWP
will be greater. Any option which has a disproportionate effect on particular groups
of authorities cannot be the correct choice.
The Child Poverty Action Group also pointed out that they are questioning whether
this consultation fully abides with the terms of the consent order which required the
government to consult on a fresh decision on LWP.

QUESTION 2 - If you have provided representations on option 4, how else would you
propose delivering and funding local welfare provision? What evidence can you provide
to support this?

It is Calderdales view that the local welfare provision should be treated as a new
burden placed on the local authority and should be funded in accordance with
Central Governments new burdens policy. This being the case the funds should be
transferred from DWP to Councils either via a Section 31 grant or a permanent
transfer of funding from DWP to DCLG.

QUESTION 3 What is the likely impact (and extent of any impact) on groups that
display protected characteristics of the four options discussed?

As stated in the SIGOMA response if option 4 is selected the equality impact

remains as evaluated by DWP at the time of the transfer of responsibility for LWP
funded grants and loans in their report of October 2011.
If councils are forced to scale back or discontinue their schemes as a result of lack of
funding, it is hard to see how beneficiaries from the vulnerable groups will cope in
times of need. There is a real possibility that they may turn to high cost credit which
in turn will deepen their deprivation as a result of the high cost of repayments and
increase the risk of homelessness. While grant giving charities or food-banks may
be able to fill some gaps, these groups have expressed concern about how they will
be able to meet demand if provision continues to erode.
In addition to emergency financial support to protect the vulnerable in the shorter
term, a proactive approach is also being employed to give help and advice to people
to try to break the cycle of crisis and foster financial resilience.
QUESTION 4 Do you agree that some impacts can only be assessed locally
depending on the decisions made by individual authorities?

Currently LWP in councils is based on local schemes so it would naturally be easier

to assess the impact of schemes at the local level as well. However, it is not
straightforward to assess the impact on vulnerable groups as the council is only in
contact with the clients on an ad hoc basis and the situation does not lend itself to
the collection of information required to make detailed assessments.
QUESTION 5 If your preference is for option 4, and you have proposed an alternative
way of delivering and funding local welfare provision, please outline how this will adhere
to the public sector equalities duty.

Maintaining and ring-fencing current levels of funding for LWP will be an effective
way to ensure that vulnerable groups are able to access the support during times of
need and that public sector equalities duties are fulfilled. Any reduction in funding
available may have a detrimental impact on the vulnerable groups which will be
difficult to address.
QUESTION 6 Do you agree that this is the right timetable?

The earlier local authorities are made aware of the outcome of this consultation the
better. It would be helpful if the level of grant is made available in conjunction with
the 2015/16 provisional settlement but by the final settlement at the latest.
In conclusion, as Local Welfare Provision has not already built into councils funding
baseline, Calderdale supports Option 4 with additional resources being provided
either from a Section 31 grant or via a permanent transfer of responsibility from
DWP. As Calderdale supports the principle of greater freedoms over funding
streams any flexibilities around the current ring fencing regime would also be
welcomed.

Nigel Broadbent
Acting Head of Finance