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Corporate peer challenge: Cheltenham Borough Council

Feedback report: 18 – 20 July 2023


1. Executive summary

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Cheltenham Borough Council (CBC) has a unique ambition to cement Cheltenham as the cyber capital of the UK. CBC sets high standards for the council and the town in order to build a better future for everyone in Cheltenham, striving to ensure that everyone who lives and works there can equally share the benefits of Cheltenham’s success. 

CBC understands that it cannot achieve this alone, it will require the support of local partners, many of whom hold the council in high regard. Partners understand and are aware of the key priorities to support the council’s ambition as set out in the revised corporate plan.

The Golden Valley Development is seen as key to achieving the priority to enhance Cheltenham’s reputation as the cyber capital of the UK. This is a project of national significance, and the council has made a substantial investment towards delivery of the project. Given the size and profile of this project, CBC has put robust risk and project management in place to monitor delivery and there is a dedicated team to support the project. 

The council is working with partners to develop Golden Valley, and this is crucial. It is important that the council more proactively engages with communities, residents and businesses. For example, such engagement could help influence and measure the social value of the project, enabling the council to act even more strategically to achieve, for example, a skills plan. A plan such as this could help outline how the future workforce requirements for Golden Valley could be met and local young people benefit from those opportunities. 

In addition to the Golden Valley Development, CBC has an ambitious programme for strategic development across the Borough, including The Reddings housing development as an example of estate regeneration and Junction 10 of the M5 as an infrastructure project which is critical to the success of Golden Valley. Taking the opportunity to fully engage with the community and with partners as projects are delivered, consulting with purpose and communicating regularly will help the council to shape and promote its wider Place shaping activity. That communication, providing a clear focus on outcomes and benefit delivery, will help the council to celebrate with staff and residents all the positive outcomes they are achieving. 

Given the nature of the council’s priorities, including both the opportunities and risks that these create, it has purposely chosen to increase capacity within the finance team to enable a strong focus on the council’s financial position. There is a shared understanding across the council of the financial challenges being faced, although more thorough briefings on the financial position and training to better understand the implications of decisions would reinforce that understanding.  Mechanisms need to be put in place to ensure budget monitoring and delivery of savings. Achievement of savings is a corporate responsibility and accountability should be built in both individually and collectively across the council. 

Working with residents, communities and businesses to help make Cheltenham net zero by 2030 is a council priority.  There is a strong organisational and political commitment to achieving this, but the delivery pathway should be reviewed to include delivery milestones. This will help staff and partners to see progress and how they are contributing to success.   

Increasing the number of affordable homes is also a key priority of the council and this will need to be achieved working with Cheltenham Borough Homes and other development partners. The council should consider further alignment with Cheltenham Borough Homes to support delivery of corporate priorities. This should build on the success of the shared communications team and seek to extend this to IT systems, shared offices, communities’ support resource and housing delivery.

CBC has a strong culture of partnership working and now is a good time to review this and build even stronger and effective relationships into the future. As part of this the council should consider rationalising those partnership arrangements and creating a stakeholder framework to avoid duplication of work and meeting attendance and to effectively signpost residents and communities for support and information.

Council members are well regarded by the external stakeholders we met with and have established effective working relationships, for which they should be commended. The Leader and other Cabinet members provide effective leadership in key strategic areas and are embedding a clear set of political priorities which will support the ambitions set out within the corporate plan.

Member to member relationships are positive. Members could be better supported through a review of the member induction process with the aim being to support their understanding of their roles and responsibilities as well as those of partner organisations. This should include a refresh of scrutiny training enabling members to ensure scrutiny is adding value and providing constructive challenge.

The positive can do culture of the council was highlighted by staff and partners and the senior leadership team actively demonstrate the council values and behaviours. These should formally be rolled out across all levels of management so that all staff can benefit. 

An in-house HR team is in the process of being created and once in place, processes should be developed for staff induction and appraisals. This will support embedding the can do culture across all staff and linking appraisals to corporate priorities will build accountability. Developing internal communications to include regular project updates will again build the sense of accountability amongst staff. The culture that permeates the organisation and many of the improvements suggested within this report will be achieved through a continuation of the direction and momentum already established.

CBC is aware of the changing diversity of its communities and positive examples of council activity within the community were reflected to the peer team such as the work to establish CARE and support to the LGBTQ community. However, some internal stakeholders reported a sense that the council is not doing enough to support staff with protected characteristics. The council has a clear desire to improve and should take the opportunity once the HR team is in place to co-produce an updated equalities, diversity and inclusion policy. The inclusive culture that the council is already developing provides a strong foundation from which they can build and a productive environment for this work to be successful.

2. Key recommendations

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There are a number of observations and suggestions within the main section of the report. The following are the peer team’s key recommendations to the council:

2.1 Golden Valley Development

The Golden Valley Development project is well managed in terms of finance and risk. Now is the time to be engaging with communities, businesses and residents to look at how the council can create and measure social value; it is important that the council thinks strategically about what it wants to achieve, for example, a skills plan and a brighter future plan for the county to provide a pipeline to meet workforce requirements and ensure unique opportunities are not missed. 

2.2 Ensure achievement of savings for 2023/24 budget

Ensure there is the discipline to achieve savings targets included in the 2023/24 revenue budget. Achieving savings is an organisation wide responsibility, build accountability into management of teams and individuals through the appraisal process.

2.3 Net Zero 2030

Refine the pathway to Net Zero 2030 in order to include clear performance measurements and milestones to demonstrate that the council is on track for delivery.

2.4 Further align with Cheltenham Borough Homes

Look for further opportunities for alignment with Cheltenham Borough Homes to support delivery of corporate priorities. 

2.5 Undertake purposeful consultation

Think carefully about communications and consultations. Consult with a purpose – there has been good consultation around the Golden Valley vision but there is a wider place shaping responsibility.  Raise the council’s profile and get people engaged and interested – create advocates for the Place.

2.6 Rationalise partnerships and meetings to work at a strategic level

Consider rationalising the council’s partnerships and meetings and creating a stakeholder framework. The council already works well at a project level, work at a strategic level to deliver Place leadership.

2.7 Member Induction and training

Improve Member Induction to support Members in understanding their roles and responsibilities and look to refresh Scrutiny training to give Members confidence to add value and constructive challenge.

2.8 Embed the Cheltenham Borough Council culture

Work to embed the culture of the organisation more widely so that all staff benefit.

2.9 Develop processes for staff induction and appraisals

Once the HR team is in place, develop processes for staff induction and appraisals that will include targets that link back from the council priorities, enabling staff to have a sense of accountability and responsibility.  Alongside these processes, develop internal communications to be more effective, for example by providing regular updates to staff on the progress of projects and key priorities.

2.10 Equalities, Diversity and Inclusion

The council should take the opportunity once the HR team is in place to co-produce an Equalities, Diversity and Inclusion strategy and policy. The inclusive culture that the council is already developing provides a productive environment for this work to be successful.

3. Summary of the peer challenge approach

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3.1 The peer team

Peer challenges are delivered by experienced elected member and officer peers. The make-up of the peer team reflected the focus of the peer challenge and peers were selected on the basis of their relevant expertise. The peers were:

  • Cllr Sarah Butikofer - Chairman North Norfolk District Council
  • Cllr Simon Minas-Bound - Conservative Group Leader Basingstoke & Deane Borough Council
  • Jason Gooding – Former Chief Executive, Carlisle City Council
  • Gabrielle Mancini – Service Director Transformation, West Berkshire Council
  • David Shepherd – Strategic Director for Growth and Regeneration, Kirklees Council
  • Kathryn Trant – LGA Peer Challenge Manager

3.2 Scope and focus

The peer team considered the following five themes which form the core components of all Corporate Peer Challenges. These areas are critical to councils’ performance and improvement.

  1. Local priorities and outcomes - Are the council’s priorities clear and informed by the local context? Is the council delivering effectively on its priorities? 
  2. Organisational and place leadership - Does the council provide effective local leadership? Are there good relationships with partner organisations and local communities?
  3. Governance and culture - Are there clear and robust governance arrangements? Is there a culture of challenge and scrutiny?
  4. Financial planning and management - Does the council have a grip on its current financial position? Does the council have a strategy and a plan to address its financial challenges?
  5. Capacity for improvement - Is the organisation able to support delivery of local priorities? Does the council have the capacity to improve?

In addition, CBC specifically asked the peer team to provide a view and some recommendations for improvement on the council’s approach to building sustainable communities and ensuring residents, communities and businesses benefit from Cheltenham’s future growth and prosperity.  

3.3 The peer challenge process

Peer challenges are improvement focused; it is important to stress that this was not an inspection. The process is not designed to provide an in-depth or technical assessment of plans and proposals. The peer team used their experience and knowledge of local government to reflect on the information presented to them by people they met, things they saw and material that they read. 

The peer team prepared by reviewing a range of documents and information in order to ensure they were familiar with the council and the challenges it is facing. The team then spent three days onsite at CBC, during which they:

  • gathered information and views from more than 36 meetings, in addition to further research and reading
  • spoke to more than 85 people including a range of council staff together with members and external stakeholders.

This report provides a summary of the peer team’s findings. In presenting feedback, they have done so as fellow local government officers and members.

4. Feedback

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4.1 Local priorities and outcomes

CBC has a newly approved corporate plan that sets out the priorities and future ambition for Cheltenham. The peer team heard from members, officers and external stakeholders that there is a shared understanding of the council priorities. However, there is less clarity on how and when those priorities are to be delivered.

The Golden Valley Development will support the number one key priority to ‘enhance Cheltenham’s reputation as the cyber capital of the UK’. This is a hugely important project of national significance and is accepted as a shared priority amongst external partners. There is confidence both within the council and from partners that this development will be delivered.  There has been significant investment from the council which is reflected in the robust project and risk management that supports it. 

In order to ensure the effective delivery of the Golden Valley Development, there is a dedicated team to support the project progress and the council has entered into an agreement with a development partner. Positive wider partnership working, for example with the county council, will be key to ensuring the infrastructure demands of the development will be met so the council needs to maintain a front and centre focus on these relationships to maintain timely delivery of the project. 

CBC has demonstrated ongoing commitment to the Golden Valley Development and stakeholders stated that the council should be given credit for its part in the project. However, it is clear that the benefits of the Development are not always widely understood by community stakeholders. From an internal perspective, a proactive communications strategy with regular updates will help staff to feel more engaged and to understand how the Development contributes to the council’s wider Place narrative.

Externally, it is important that the council establishes a positive narrative about the benefits of the Development. The peer team recommends engagement with the community, particularly with young people, to help define what social value the council would like to achieve from the Development, for example, the skills requirement for the future employment opportunities. Resources are available to support the council to do this including a Social Value Portal which is used by neighbouring councils and a Social Value Toolkit for District Councils which is available on the LGA website.

CBC has a priority to ‘work with residents, communities and businesses to help make Cheltenham net zero by 2030’. CBC has a dedicated web page providing advice to residents and businesses, a link to the action plan ‘pathway to net zero’ and information about the various projects being undertaken to support this priority.  

Despite this, partners and staff reported that they are unclear on how much progress has been made and there is insufficient clarity on the delivery plan to give confidence to all stakeholders that this priority will be delivered. Staff understand that climate action is an organisation wide responsibility that should not sit with just one team. The cabinet member for climate emergency proactively updates cabinet on a regular basis and sharing those updates more widely, along with a revised action plan with clear milestones, would strengthen the momentum and strong desire amongst staff to achieve this priority. The peer team recommends that the council refines the pathway to net zero 2030 action plan in order to include clear performance measurements and milestones that will demonstrate progress.

CBC is in the process of linking performance management data with corporate plan priorities.  Once complete, this will provide the data to monitor progress against corporate plan delivery and will enable success to be measured. The council now has a performance management system in place that will overcome the previously inconsistent approach. The new system will support managers to use data to make decisions based on evidence and outcomes and so drive improvement. 

The peer team heard how the council is doing a significant amount of work to address the areas of deprivation within Cheltenham, for example, the recent publication of the Tackling Multiple Deprivation report. A further example is the ‘No Child Left Behind’ initiative which is an impressive project that has the involvement of all borough schools, has raised the profile of child poverty and aims to help all young people to thrive.  However, the project outcomes are not widely captured. As with progress against action plans, project outcomes either need to be measured or, if they have been measured, they need to be widely shared as there is a low level of awareness across stakeholders. CBC should be proud of what it achieves and should not be reluctant to share its successes.

A recurring message to the peer team was that the council “quietly gets on and does things”.  Whilst this is admirable, it is important to share outcomes with staff and stakeholders. Regular and detailed communication would help to raise the council’s profile and get residents and communities engaged, potentially creating advocates for Place who could share and support the council’s Place vision. It is equally important to listen, and when the council consults it should do so with a purpose. 

Whilst the peer team heard of good consultation around the Golden Valley Development, the council has a wider place shaping responsibility and engaging with communities, building on the great community support work the council did during Covid, would help to address concerns raised by partners that the focus on the new Golden Valley Development is at the expense of the old Cheltenham.

4.2 Organisational and place leadership

The leadership of CBC is open and approachable with staff valuing the chief executive’s genuine open door policy. 

Both the leader and the chief executive are recognised by staff and stakeholders for their leadership qualities. For example, the business stakeholders appreciated the chief executive setting out the council’s corporate priorities to them and the public sector stakeholders reported that the positive leadership of CBC enabled strong partnerships to form across the public and voluntary sectors with CBC challenging and leading where appropriate. The chief executive has led a change of organisational culture which is valued and recognised across the organisation by staff, managers and members. The senior leadership team demonstrate the values and behaviours of the organisation, for example ‘Own it’ and ‘Get it done’, however, they are not embedded at all levels. It is important that the council works to embed the positive culture throughout the organisation so that the benefits are experienced by all.

CBC is aware of the changing diversity of its communities and has worked with local residents to establish ‘Cheltenham Alliance for Race Equality’ (CARE). The peer team heard some positive examples of council activity within the community, such as the work to establish CARE and support to the LGBTQ community, however, internal stakeholders reported a sense that the council is not doing enough. It is positive to note that a new equality and diversity policy is being produced and equality objectives are being developed with an action plan. The council has a clear desire to improve and should take the opportunity once the HR team is in place to co-produce that updated equalities, diversity and inclusion policy.  The inclusive culture that the council is already developing provides a strong foundation from which they can build and a productive environment for this work to be successful.

 

Post Covid, councils have taken different views regarding hybrid working. CBC offers flexibility to staff to enable working from home and this was seen by staff as positive. However, the peer team also heard from inside and outside the council, of challenges in contacting the right people within the council. This may be exacerbated by a lack of induction training for new starters but equally could easily be addressed internally with an up to date staff contact list which is in the process of being produced.  It is positive to see that the HR function is being brought in house from Publica. Once the HR team is in place, the council should develop processes for staff induction, development and appraisals that will include targets that link back from the council priorities, enabling staff to have a sense of accountability and responsibility.

The Chief Executive’s monthly staff briefings are positively received and are regularly attended by around 100 staff. The leader also attends, demonstrating her keenness to engage with staff.  The World Cafes where staff come together to discuss a specific topic, are similarly well regarded. However, staff also reported that regular updates on progress with priorities and celebrating success for example would be appreciated and again, would help staff with enhance a sense of accountability. 

CBC works with a number of partners and delivery organisations, and this can cause some confusion to communities as the council can be perceived as operating as multiple organisations rather than just one.  Improving external communications would help to address this. For example, the peer team heard that a lack of clarity around lead officers can sometimes mean that members of the community often engage only with their ward members. It is positive that both residents and other stakeholders have good relationships with ward members, but relationships with the council could be enhanced by having clarity over who the most appropriate lead officer is for key communication and engagement issues.  

Given the two tier local government structure in Gloucestershire, CBC works closely with the county council in a number of areas.  A strong relationship with the county council is vital, particularly with the interdependencies around economic growth projects. There is an opportunity to strengthen the relationship between the county council and CBC via the City Region Board that is currently in development.  This could offer a vehicle to align the strategic growth ambition of the county with the place ambition of district partners like CBC, ensuring the proceeds of growth are managed to deliver wider policy outcomes at a place level.  Effective leadership will be required to carefully steer the new governance and achieve long lasting results.

Whilst the council is regarded as working well with partners, the number of partnerships is significant and there is a risk of duplication. The peer team would recommend that the council rationalise the number of partnerships and meetings and have a stakeholder framework to demonstrate a shared vision for Place. This rationalisation would address some duplication and show that the council’s focus is Borough wide. That shared vision for the Place will assist in making sure that interventions are directed to a common purpose and will help to signpost residents and communities to appropriate areas for support and information.

4.3 Governance and culture

CBC operates a strong leader model of governance; the leader is deeply committed to transparency and collective decision making is the standard. The leader holds regular meetings with political group leaders and the cabinet meet monthly on an informal basis with the senior leadership team. There are good working relationships amongst members across the political spectrum. This was reflected in discussions with both members and officers and evidences the positive culture of the organisation. The council should be commended for the high standards of behaviour demonstrated by the positive member to member and member to officer relationships.

CBC has adopted the Gloucestershire wide Member Code of Conduct, based on the LGA Model Code of Conduct, and supplemented by a Protocol for Member/Officer Relations. Adoption of the code demonstrates a desire across the council for mutual respect.

CBC has effective governance arrangements in place demonstrated by the corporate governance group which is chaired by the chief executive and includes the monitoring officer and s151 officer.  Members reported how well officers support them and there is confidence in officers’ knowledge and ability, particularly at a senior management level. Similarly, officers reported constructive working relationships with members with a high degree of engagement.

The council works with many key partners, and it is important that new members understand where those key partners fit in relation to their responsibilities and those of the council. The member induction programme could be improved with a view to giving members a better understanding of their own roles, responsibilities and accountabilities and those of officers, along with how key partners work with the council.  A complete understanding of roles, responsibilities and interdependencies will ultimately enhance the operation of the council. Undertaking a review of the member induction process now would give time for a new induction programme to be in place for the next elections in May 2024.

There are excellent pieces of work from the Overview and Scrutiny Committee, such as the Tackling Deprivation report, and recommendations arising from Overview and Scrutiny Committee are listened to and respected. However, on occasion scrutiny can be light touch and the peer team saw little evidence of ‘pre-scrutiny’ and therefore the scrutiny function may not be adding maximum value, particularly in scrutinising the internal operations of the council. In addition, some members reported a lack of confidence in undertaking their scrutiny role and the processes of the scrutiny function. The peer team would therefore recommend a refresh of scrutiny training to give members confidence in the process to add maximum value and to agree the role and function of scrutiny within CBC.

Historically, a number of reports were presented to council and committees as fully exempt items rather than public reports with exempt appendices for sensitive information. This is not in line with the culture of transparency that about the council advocates. However, the new Monitoring Officer has already had an impact in this area and therefore the peer team does not expect this to be an ongoing issue.

4.4 Financial planning and management

CBC, like all councils, has been impacted by the current economic climate and the cost of living crisis. These challenges have led to the council to respond accordingly and for the financial year 2022/23 a savings target of £1.5m was set. Disappointingly, less that £1m of those savings were made and therefore in February this year the council chose to set a revised budget for 2022/23 by using general fund reserves of £2.5m. 

To set a balanced general fund budget for 2023/24, CBC has set a savings requirement of £1.3m.  The peer team believe the inability to meet the savings target for 2022/23 is a cause for concern and it is fundamentally important that the council now shows the necessary discipline to achieve the savings for 2023/24. We understand the General fund reserves are now below the level recommended by the s151 officer and the current budget includes plans to increase the general fund reserves to an appropriate level by the end of 2023/24. Again, it is important that this is achieved.

Programme governance has been set up around delivery of the savings and the culture of whole organisation accountability should be extended through team and individual performance management arrangements to review and monitor delivery of those savings. The introduction of an organisational performance management system is positive, and progressing the system to link performance with financial information will provide clarity on the relationship between resource consumption and delivery of the council’s objectives.

For the present and importantly for the future, there now appears to be a far clearer shared understanding of the challenging financial position across the political and managerial leadership.  An away day earlier this year attended by cabinet members and the senior leadership team was used to develop a strategy to focus on priorities for resources and savings in line with the corporate plan.  It will be important as the year progresses that members are sighted on progress with savings, borrowing and risk management updates with regular reporting to appropriate council bodies. Continued focus on a culture of openness and accountability will be critical to maintaining momentum and corporate ownership of savings delivery.

CBC carries out discretionary services to a high standard, for example the parks and gardens are maintained to a Green Flag standard. Whilst some councillors and stakeholders associate Cheltenham with those high levels of service, the council may need to take difficult decisions in the future to protect financial sustainability and maintain acceptable levels of statutory service provision.

Risk management is currently reported to leadership team on a monthly basis, and Cabinet twice a year, and will now be reported to Audit, Compliance and Governance Committee on a quarterly basis.  This increased reporting will support transparency and wider corporate knowledge and understanding of current risk appetite and capacity for the council as currently there is an inconsistent approach to the management of risk.  Whilst risk is embedded at a senior management level, the performance management system being implemented will include reporting on risks and risk assessment training to help wider understanding of risk management. One area where there is strong risk management is the Golden Valley Development which has its own risk register considered on a monthly basis by the programme board.  The learning from the Golden Valley Development project, supported by the performance management system, will improve the organisations approach to risk management. 

CBC has an ambitious capital programme which may require significant borrowing into the medium term. Whilst members and officers have a high degree of confidence around the council’s current borrowing and consequent exposure to risk, it will be important to keep this under review and ensure robust and transparent management of projects. The peer team heard an example of a project where the project management had not been robust.  Lessons have been learned and the more stringent project management principles applied to the Golden Valley development will now be replicated across other significant projects which are undertaken. 

More use of the internal audit partnership during the planning phase of projects would strengthen the council’s risk management arrangements. Internal auditors are keen to advise in this way rather than solely being involved in ‘lessons learned’ afterwards.

External audit of the council’s accounts for 2021/22 has not yet been completed owing to capacity issues with external audit, a situation widely reported across the sector. One of the areas for consideration will be the council’s treatment of Minimum Revenue Provision and how the council has structured its borrowing.  The peer team heard that this issue is close to resolution and the council appears to have a set of arrangements in place for managing its borrowing. The peer team will be checking on the progress of this as well as other key financial drivers and pressures, such as the achievement of savings required for 2023/24 when it returns for the progress review in 6-12 months’ time.

4.5 Capacity for improvement

CBC has an impressive officer leadership team; this was reported to the peer team by members and external stakeholders alike. The council works with a number of delivery organisations and those arrangements will be kept under review to ensure they continue to best fit the council’s strategy for the future. In developing a Place shaping vision, the council could consider opportunities for partnership working to build capacity as partners are keen that the council is fully resourced to deliver the ambitious corporate plan. 

An example is the delivery of the key priority ‘increasing the number of affordable homes through our £180m housing investment plan’. The council already has a shared resource with Cheltenham Borough Homes with a shared communications team. To support delivery of the key priority the peer team recommend that the council builds on the success of this arrangement and looks to extend the potential for greater partnership working with IT systems, shared offices, communities’ resource and housing delivery.

The council undertook Phase 1 of an organisational review during 2022. Decisions taken as part of that have provided increased capacity such as the in house finance team and the appointment of a shared monitoring officer. Increased resourcing dedicated to climate emergency links the outcomes of the review to the council priorities.

Phase 2 of the organisational review is ongoing and includes bringing the HR team in house. As the council progresses with Phase 2, it may be helpful to be mindful of team dynamics as well as the skills and capabilities that the council want to recruit. Any senior departure creates opportunities for new structures and the council will be alert to this. 

4.6 The council’s approach to building sustainable communities

CBC asked the peer team to provide a view and some recommendations for improvement on the council’s approach to building sustainable communities and ensuring residents, communities and businesses benefit from Cheltenham’s future growth and prosperity.   

A strategy and metrics for delivering and measuring social value will assist the council with understanding impacts. There are a number of resources available as referenced above to assist the council in developing a social value strategy.

It is important that early community engagement around economic development activity explores the outputs that would benefit the residents and is continued throughout the project as it evolves. Consultation with a purpose and proactive listening to residents, followed up with regular updates on project delivery actions would ensure wider understanding of the councils’ achievements and benefit realisation. 

The peer team heard from community stakeholders and partners that the benefits of the Golden Valley Development are not widely understood. The skills agenda is clearly critical to meeting the objectives of the Golden Valley Development.  It is not clear where this important strategic discussion is taking place. CBC should identify how it can productively contribute to a skills plan for the county.

5. Next steps

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It is recognised that senior political and managerial leadership will want to consider, discuss and reflect on these findings. 

Both the peer team and LGA are keen to build on the relationships formed through the peer challenge. The CPC process includes a six-month check-in session, which provides space for the council’s senior leadership to update peers on its progress against the action plan and discuss next steps.

In the meantime, Paul Clarke, Principal Adviser for the South West, is the main contact between your authority and the Local Government Association. Paul is available to discuss any further support the council requires. [email protected].