Northern Ireland Executive - Draft Programme for Government Framework 2016 - 2021 Disability Action’s Response July 2016 Any enquiry concerning this document should be made to Karen Hall Assistant Director - Policy & External Relations Disability Action Portside Business Park 189 Airport Road West Belfast BT3 9ED Tel: 028 90 297880 Fax 028 90 297881 Textphone: 028 90 297882 Website: www.disabilityaction.org Email: [email protected] INTRODUCTION 1 Disability Action is a pioneering Northern Ireland charity working with and for people with disabilities. We work with our members to provide information, training, transport awareness programmes and representation for people regardless of their disability; whether that is physical, mental, sensory, hidden or learning disability. 2 21% of adults and 6% of children living in private households in Northern Ireland have a disability and the incidence is one of the highest in the United Kingdom. 3 As a campaigning body, we work to bring about positive change to the social, economic and cultural life of people with disabilities and consequently our entire community. In pursuit of our aims we serve 45,000 people each year. 4 Our network of services is provided via our Headquarters in Belfast and in five regional offices in Carrickfergus, Derry, Enniskillen, Newry and Dungannon. 5 Disability Action welcomes the opportunity to respond to this paper. GENERAL COMMENTARY 6 Disability Action undertook two engagement sessions with people with disabilities and their organisations to inform this response. The events in Derry and Belfast were attended by around 40 people in total. A full note of these sessions is available in Appendix 1 for reference. 7 Disability Action is concerned that the consultation has not been made accessible to people with disabilities. No alternative formats were available on the website or in print. We are aware that one organisation requested information in an easy read format and that this was not made available until two days before the consultation period ended. This is not acceptable and the Executive has not met its duties under the DDO or its own Disability Strategy. The Executive should have made provision for the development of accessible formats before publication given the shorter timescales. An extension should have been offered to those people who did not get formats until late in the consultation period. 1 D:\81910712.doc 8 Disability Action welcomes the outcomes based approach that has been taken in the PFG. However, there are some concerns that the indicators are very specific and may not measure the actual outcomes. There was discussion on how the outcomes can be impacted by not just Government but by wider civil society and in particular how the voluntary and community sector can work collaboratively with Government to deliver on the outcomes. One of the issues, particularly with disability, is about government departments working more collaboratively with each other. Within this framework there would appear to be better opportunity to ensure that Departments work more closely together. 9 We are aware that the budget will form part of the process for PFG, and would encourage that the Executive takes a proactive approach in engaging people in helping to shape the budgets that deliver the services that impact on their lives. SPECIFIC COMMENTARY 10 Purpose It was generally accepted as positive; however a specific timeframe should be set against it. 11 Outcomes We have not provided commentary on each of the outcomes, just the outcomes that those we engaged with thought need to be changed or considered in a different way. A narrative of the areas to consider under each outcome in relation to people with disabilities is included in appendix 1. We have a more equal society There was discussion around the term 'more' and whether it should be removed and just read 'we have an equal society'. However, others felt that using the term 'more' showed a direction of travel. 2 D:\81910712.doc Discussions highlighted that there needs to be recognition of multiple identity and that existing strategies such as disability, gender and sexual orientation need to be resourced and implemented if there is to be success with this outcome. We are an innovative, creative society, where people can fulfil their potential. The main area of discussion on this outcome was about what it means to 'fulfil their potential'. This will mean different things to different people and there needs to be recognition of this within any further action plans. We care for others and help those in need We feel that this is a very paternalistic term and not a rights based approach. An alternative suggestion included: We support people to live independently and fulfil their potential. The earlier outcome could then have fulfil their potential removed as it is included here. It should be noted that to 'live independently' does not mean everyone living by themselves; it is a much broader term. The following definition for independent living has been developed by the DRILL Programme. “All disabled people having the same choice, control, dignity and freedom as any other citizen to achieve their goals at home, in education, at work, and as members of the community. This does not necessarily mean disabled people doing things for themselves but it does mean having the right to practical assistance based on their choices and aspirations”. This definition was originally developed by the Disability Rights Commission as would help align the outcome to the Executives Disability Strategy and its duties under the UN Convention on the Rights of Persons with Disabilities (UNCRPD). 3 D:\81910712.doc We give children and young people the best start in life Feedback on this outcome focused on ensuring it meant 'all of our children', it was felt that adding 'all' demonstrated that it included children with disabilities and other S75 groups. The outcome only focuses on 'the best start in life' and it was felt that this was too narrow a period of time and should be the children and young people's whole life. Instead of best start in life the alternative suggested was as follows: We give all children and young people the opportunity to reach their full potential. Link to indictor 42 in outcomes There was also concern that indicator 42 only appears to be contributory to 8 of the 14 outcomes and is notably absent from: o Outcome 1(strong competitive balanced economy) which includes making sure that growth benefits people in all parts of the region (geographical disadvantage v community of disadvantage). o Outcome 4 – long and healthy lives o Outcome 6 - more people working in better jobs o Outcome 7- safe community, hate crime These outcomes all impact on people with disabilities and therefore indicator 42 should cross-cut all of them. For example, in particular Outcome 6 and the impact of disability hate crime on disabled peoples quality of life. 4 D:\81910712.doc 12. Indicators We have not provided commentary on each of the indicators, just the indicators that those we engaged with thought need to be changed or considered in a different way. A narrative of the areas to consider under each outcome in relation to people with disabilities is included in appendix 1. Indicator 9 - Improve support for adults with care needs. The first concern is similar to that of the outcome about caring for others in that it only considers 'care needs' which is paternalistic and not rights based. The second concern is that is only relates to adults - why are children not included? We feel that the indicator needs to better reflect the definition of independent living as outlined previously (page 3) and should include children as well as adults. Improve the choice and control for adults and children who may require practical assistance to live independently. This would align this indicator to Strategic Priority 7 in the Disability Strategy and Strategic Aim 3 in the Active Aging Strategy. The measure under this indicator would not show any outcome, it is just an output measure. The number of people receiving personal care at home or self-directed support as a % of the total number of population does not tell us anything about the impact that it has had on their lives. There are much better measures that could be used that could actually measure the success (or otherwise) of the input. For example, under Self Directed Support the HSCB will be using the ASCOT (Adult Social Care Outcomes Toolkit) measure which is designed to capture information about an individual's social care related quality of life (SCRQoL). The benefit of this tool is that it also takes into consideration the carer and the impact on their quality of life. 5 D:\81910712.doc This would be a much more appropriate measure as it is outcomes focussed and can be used across a range of service users and care and support settings. It could also be used as another measure within indicator 42. A similar outcomes model would need to be identified for children with disabilities. Indicator 10 - Improve Support for Looked After Children This indicator is welcome, however the measure only considers the position of children in care at age 19 and should be changed so that the measure can reflect their outcomes during care, not just on leaving. Indicator 11 - Improve Educational Outcomes There is concern that the measure for indicator 11 is too restrictive as it only focuses on GCSE results. In the more detailed indicator measurement annex it states that there may be an opportunity to measure SEN outcomes for people with learning disabilities. We are concerned that these measures will not reflect the educational outcomes for children with disabilities. Firstly, would be GSCE data be able to be disaggregated for children with disabilities? Secondly, it should not just be about academic results. Educational outcomes should be measured much more broadly and centre on the individual outcome. There should also be consideration on how vocational qualifications can be used as a measure for those who do not undertake academic qualifications. Indicator 12 - Reduce educational inequality The measure is too restrictive and only considers those who get free school meals and achievement at level 2 English and maths. Educational inequality does not just exist due to income level, it exists due to a wide range of circumstances. For children with disabilities the inequality can be because of lack of access to appropriate levels of support in school or other barriers. The measure should reflect the broad range of inequalities experienced by children and young people in education. 6 D:\81910712.doc Indicator 14 - Improve the Skills Profile of the Population We welcome recognition in Indicator 14 of the importance of up skilling at level 1 to balance the inordinate emphasis on levels 2 and above in other strategies and initiatives. Disability Action concurs that the labour market will still require significant numbers of workers across the whole skills spectrum. This is an issue for the economy – not just social inclusion. It is important that this is considered as part of mainstream Government training for young people and that they are not excluded from vocational training provision by a focus on level 2 and above. Indicator 15 - Improve Child Development The measure does not include any indication that it will measure child development for children with disabilities. As this will be a new measure the Executive must ensure that the measure can include data for children with disabilities and evidence the early intervention measures that are vital for children with disabilities and their families. Indicator 16 - Increase the Proportion of People in Work Indicator 17 - Reduce Economic Inactivity The measure for indicator 16 will not reflect success or failure in employment outcomes for people with significant disabilities. The Disability Employment Strategy targets this group and therefore the measurement needs to be aligned to this indicator. The measure for indicator 17 also needs to ensure that disaggregated data is available in relation to disability. However, further measures need to be considered that focus on the outcome rather than just the output. During discussions people thought that indicator 16 & 17 could be aligned together but with having more than one measure. It is essential that these indicators and measures are aligned with the Disability Employment Strategy that was recently published. It is vital that going forward the PFG action plan embraces and resources the actions of the Disability Employment Strategy. These include: 7 D:\81910712.doc Theme 1 - Empowering and supporting people to secure paid employment – PfG needs sub-targets to drive and resource this work. Outcome 1 should include measures to make sure growth benefits all people – potentially through increased engagement with employers/use of social clauses. Theme 2 Job retention and career development – The PfG does not address issues of retention or progression. PfG needs to acknowledge the value of retention of employment both to the disabled employee and the employer who retains an experienced member of staff. The challenges facing people with disabilities in employment have been documented. Theme 3 Working with employers – the PfG engagement with employers is largely focused in growth and inward investment. The PfG focus noted above on geographical deprivation needs to be challenged to ensure that work with employers promotes equality of opportunity for disabled people across NI as a disadvantaged community of interest. Theme 4 Research and development – obvious need for baseline measures highlighted in the DES strategy should be addressed by PfG Theme 5 Strategic partnership and engagement – PfG should adopt the partnership approach embraced by DEL/DES in the development of the Strategy and in the make up of the stakeholder forum. All departments need to be working in collaboration and should learn from the mistakes of previous executives. Efficient and effective partnership with relevant departments should be a strategic demand. Indicator 25 - Increase the use of public transport and active travel The concern with this indicator and the measurement is that it does not reflect that for some people with disabilities the only transport option is the car. It does not reflect that people with disabilities still face significant barriers in accessing public transport and active travel. The Accessible Transport Strategy needs to be considered within this indicator and the measures set out within it. The measurement Annex describes that data is available for people with disabilities as an estimate. This is not acceptable. 8 D:\81910712.doc Any data set that is to be developed or used must ensure that there is significant data that can be disaggregated to measure the outcome for people with disabilities. Indicator 28 - Increase the confidence and capability of people and communities. The indicator is welcome, however, there are concerns about the measurement and how effective this would be me about providing and opportunity to measure against peers. Any data must be able to be disaggregated to measure outcome for people with disabilities. 9 D:\81910712.doc 13. Indicator 42 - Increase Quality of Life for People with Disabilities Disability Action welcomes that there is a specific indicator for people with disabilities. At the engagement events specific time was set a side to discuss this indicator. The first issue is does it mean children and adults with disabilities? It is vital that it includes both and not just adults. The proposed measure outlined does define this and the suggested survey to be used for the measure appears to only consider adults. One of the key questions was what does 'quality of life' mean and how will it be defined within the measure. The discussion focused that it would mean different things to different people depending on their individual circumstances. In terms of the title of the indicator it was felt that the language needed to change so that it read: 'Improve the Quality of Life of People with Disabilities'. People felt that this was more appropriate as it would better reflect individual outcomes. Discussion took place on whether this was the right indicator at all or should be more about measuring social inclusion and the current indicator doesn't seem to reflect the structural and environmental barriers that people with disabilities face. However, both groups felt that there needed to be clarification on the definition and that it should be co-produced with disabled people so that everyone was involved in developing the measure. Both groups also felt that there would be a requirement for more than one measure for this indicator, that they needed to be more outcome focused and that it should be developed with people with disabilities. 10 D:\81910712.doc We asked the question about what quality of life would mean to people with disabilities and how they would measure it. Below is a list of key areas people discussed: □ Access to housing, employment, leisure activities - if you have access you have better quality of life. □ Provision and uptake of timely, appropriate and effective services. □ Social inclusion measures □ Cost of living measures □ Poverty measures □ Independent living measures □ Impact of government policy on quality of life - i.e. welfare reform, social care, disparity of disability legislation in NI compared to GB. Link to Existing Strategies and Policies There is concern about how existing and new strategies will work within the new framework. For example, the Disability Strategy, the Disability Employment Strategy, the Accessible Transport Strategy. A significant amount of work an engagement has been undertaken with these and people are seeking reassurance that the PFG model will ensure that any actions are still taken forward and integrated with the action plans for each indicator. We need to ensure that disability is not just included in an action plan for indicator 42 but across all of the indicators. There is a need for the indicator to be aligned to the government responsibilities under human rights conventions. In particular the UN Convention on the Rights of Persons with Disabilities (UNCRPD) and UN Convention on the Rights of the Child (UNCRC). Both these conventions provide an opportunity to provide a model for measurement against a variety of rights. 11 D:\81910712.doc Measurement / Data The Disability Strategy already has a range of indicators against each of the strategic priority and the work that has been undertaken on this should be considered as additional measures that could be used, There is also significant data within the Northern Ireland Survey of Activity Limitation and Disability (NISALD). Although this data is over 10 years old, it would provide a baseline that would be used. OFMDFM did commit to re-running this survey in 2016, however this has not materialized, therefore should this be considered as a more detailed measure that could be used? What is clear from our work on the UNCRPD is that there is not enough data in Northern Ireland that can be disaggregated to a level for people with disabilities. It is vital that any measure, across any indicator, can be disaggregated for people with disabilities. It is vitally important that the measure can reach people who live in different types of households. The measure as it stands would not reach people with disabilities who live in supported living, residential or nursing care. We cannot measure the quality of life of people with disabilities if we don't include all people with disabilities. The measurement must include children with disabilities. At present it does not appear that there is any measure that will provide any indicator of outcomes for children with disabilities and their families. All the measures that are developed must be available to provide comparison with others in society, for example, can the indicator be measured against the quality of life of those without a disability. Should consideration also be given to how it could be benchmarked against other countries and nations? So should an international quality of life indicator such as the World Health Organisation WHOQOL measure be applied? 12 D:\81910712.doc Engagement The process going forward must ensure that it directly engages with disabled people and their organization to ensure that the indicator and measurements are co-designed with people with disabilities. It is our lived experience which will help ensure that the indicator, measure and any subsequent action plans will actually deliver real change for disabled people. One of the failures of the current disability strategy is that it has not engaged disabled people or involved them in developing real actions that can deliver. It is imperative that the Executive learn from this and truly engage with disabled people, throughout all areas of society. 14 Equality Screening Comments Disability Action notes that in the first instance the Northern Ireland Executive has not applied the 4 screening questions recommended by the Equality Commission for Northern Ireland.1 The ECNI2 also recommends that in order to answer the 4 screening questions public authorities should consider the implications of the policy being screened and gather information/evidence to inform the policy. These omissions render the screening process seriously flawed from the outset. Disability Action would ask if the 4 questions, as outlined, where applied individually to each of the 9 groups listed under Section 75, if yes, the NIE should have supplied the background evidence to enable informed comment to be made. If no, then again, this renders the process seriously flawed. Regarding the 4 questions used, each of them are different so it would be reasonable to assume they would provide different answers however the NIE present the same answer to questions 1 and 2 and questions 3 and 4 respectively which raises concerns. 1 Section 75 of the Northern Ireland Act 1998 Equality Commission for Northern Ireland: A Guide for Public Authorities, Appendix 1, page 54 2 Ibid, page 54 13 D:\81910712.doc Disability Action would seek information on the consultation process which highlighted “a range of potential policy issues potentially impacting on relevant groups” to enable informed comment to be made. (Question 3) The NIE would appear to be stating that the Programme for Government Framework will be formally applied across all 9 categories. Disability Action would point out that Section 75 is about more than treating everyone the same as some of the 9 categories, in particular people with disabilities, will not be at the same starting point as others and may require alternative policies and/or mitigation to ensure equality of opportunity for all. (Questions 1-4) The NIE states that the PfG has identified a range of positive policy issues impacting on relevant groups and good relations and these will be dealt with as appropriate at a lower level. Disability Action would advise that Section 75 requires a proactive approach to policy making and where, through gathered information, adverse impacts identified on any or all of the 9 categories, mitigating factors and/or alternative policies should be applied to alleviate the impact or, if necessary, progress to an EQIA. The NIE therefore can’t opt out of its Section 75 obligations by delegating its statutory responsibility to lower level organisations or agencies. (Conclusion) In general, this screening process only considered the “proposed outcomes” rather than the proposed actions impact on equality of opportunity. Additionally, the process did not provide evidence across the 9 Section 75 categories to substantiate in an adverse impact exists or not. The current economic and austerity position makes equality of opportunity more relevant in regard to those most disadvantaged in society. As this PfG places an emphasis on the economy Disability Action believes that those currently disadvantaged, in particular, people with disabilities will potentially be disproportionately affected by the PfG. Given these and the comments made at paragraphs 1-8 above Disability Action believes this screening process to be 14 D:\81910712.doc unacceptable and recommends the NIE to redraft the screening process. OR Given these and the comments made at paragraphs 1-8 above Disability Action believes that the screening process requires significant redrafting. 15. Concluding Comments This is very much a new way of working for everyone, but the process needs to be made much more accessible to people and the Executive need to ensure that everyone can be involved in the process. This means going out and talking to people over a longer period of time and providing more opportunity for engagement. We are aware that this is the first step and that subsequent action plans will be developed, disabled people must be engaged with this process. Disability cuts across all the outcomes and indicators and this should be recognized in the measures and action plans. There are concerns that this mandate will be about setting baselines - we want to see the use of available data or early baselines set so that we can start to see progress going forward. Disability Action welcomes the opportunity to respond to this document, and would like to thank all those who took part in engagement events to help inform this response. We will continue working with disabled people and their organizations to inform the PFG process going forward. 15 D:\81910712.doc Appendix 1 - Direct Notes from Engagement Events 1. We prosper through a strong, competitive, regionally balanced economy Apprenticeships for people with disabilities Skills development for people with disabilities Flexibility of the workplace and economy ie greater support systems and recognition of the contribution that disabled people can bring to the workplace Develop understanding of decision makers to allow for individual needs of pwds to ensure inclusion in a competitive economy Education of employers/staff in regard to disability issues Programmes to build the confidence of pwds Implementation of the Disability Employment Strategy which should be fully funded 2. We live and work sustainably – protecting the environment We have an interest in the environment and policies etc government should look to ensuring full accessibility for pwds eg fishing, country walks, birdwatching etc 3. We have a more equal society Implementation of significant strategies eg disability, gender, sexual orientation. The Disability Strategy must be fully resourced and the implementation process must include the voice of pwds in developing the action measures and in monitoring and evaluation Multiple identity issues must be addressed People live in fear – there is a lack of understanding, misconceptions and stigma around pwds Politicians think equality is done and dusted but more needs to be done to accomplish an equal society If OFMDFM as the lead and equality officers within government don’t do it right, then no one else will Pwds need to bring the issues to politicians and start to breakdown the boundaries We need to do more to ensure the voices of pwds are heard Address the disparity in equality legislation between NI and the GB Equality Act 2010 Concerns regarding Brexit and impact of Welfare Reform 16 D:\81910712.doc 4. We enjoy long, healthy, active lives 5. Cost of gyms is a problem for people on benefit and low income Disability Training of leisure centre staff Access to suitable sport and accessible facilities Promote the mental health benefits of exercise Less focus on the negatives and promote engagement in leisure activities for better outcomes Health screening not offered to pwds Scoping of accessibility of leisure facilities A gym can be a safer, healthier environment Children with disabilities – early years and inclusive activities General health can be neglected as disability can be the primary focus GP referrals - public health awareness around issues such as 10 week sports voucher Look at the individual rather than the collective need regarding activities Leisure centres can be institutional Pwds require obstacle/barrier free/concessions We are an innovative, creative society, where people can fulfil their potential Back to outcome 1 to fulfil our potential The Disability Employment Strategy – what will happen now for its implementation with no prospect of funding from Europe Being innovative and creative for pwds and giving us the opportunity to do something Pwds not given equal opportunities because viewed as dependent and can’t demonstrate their experience Children with disabilities may not take exams, however reaching their full potential is not about academic qualifications Early diagnosis for children with disabilities is required and the supports they need to achieve their own potential Childcare and nursery places especially the recent media coverage on cuts in nursery places for cwds Carers and parents are often forgotten about - in some cases a parent has to give up work to care for their child. The impact on the whole family should be addressed. 17 D:\81910712.doc There are geographical disparity implications to a range of services ie rural areas lack the services that urban dwellers have There needs to be a priority of individual need, not priority of need with a set budget Regarding transitions more needs to be done to ensure an efficient transfer from children to adult services for young people with disabilities Impact of closure of some local services eg library closures 6. We have more people working in better jobs Pwds tend to occupy lower quality jobs. Such prejudicial judgement on dp’s ability goes beyond equality and diversity and is institutional within public and private employers There is an argument for better jobs for pwds Part time work for pwds carry less entitlements ie pensions etc The onus should be on government to ensure that employers support pwds employment programmes Clarification on qualifications for jobs versus the educational outcome for pwds. Alternatives – as work is not always an option for some pwds 7. We have a safe community where we respect the law and each other After a hate crime police focus on prosecution never on the victim Police do not feed back to the victim and therefore no court case which impacts on your mental health There should be robust monitoring of hate crime on pwds as the emphasis is on race/sectarian crime Community policing has improved Focus should be on proper policing and not the two communities How this outcome is termed will result in policies to protect the two traditional main communities in NI and not the other Section 75 groups Pwds can be identified through external housing adaptations to their home so this requires more creative design 8. We care for others and we help those in need This outcome is medical model orientated. 18 D:\81910712.doc There should be a measurement within the PfG on social housing and segregated disability communities The effect of cuts on people living independently and the non introduction of Transforming Your Care Carers’ needs must be taken into consideration Housing Associations should build to the same rules as the NIHE The indicators for this outcome need to be re-done 9. We are a shared society that respects diversity Hate crime has already been covered at 7 above. Media coverage in GB regarding Welfare Reform has resulted in an increase in hate crime towards pwds Pwds need respect and given the same life chances as everyone else because perceived lack of qualifications and economic status influences non-disabled peoples’ perspective and attitude towards pwds The government should take on best practice examples from the community/voluntary sector and how they work with and for a diverse population 10. We are a confident, welcoming, outward-looking society Regarding a confident, welcoming, outward-looking society really how visible are pwds? Has this outcome been dented by the UK’s exit from Europe? How will this outcome be achieved without the aid of European funding? 11. We give our children and young people the best start in life This PfG has not considered children with disabilities at all Early diagnosis is key to a best start for c&ypwds A huge area of need for funded learning disability programmes and past underspend must to be rectified ie the WH&SCT cuts to learning disability programmes There are no mental health services for c&ypwds and this must be addressed The medical model of disability and children’s services ensures a negative delivery of services. Departments with responsibility of c&ypwds should adopt a human rights model 19 D:\81910712.doc Families have to continually fight and advocate in order to get minimum services. There should be more support for parents and they shouldn’t be ignored or patronised The whole family should be assessed in regard to services The lack of positive role models for c&ypwds limits c&ypwds potential to achieve Doctors and other health professionals should get training on families experiences Recommend CDSA Manifesto as a way forward 12. We have high quality public services There should be a measurement of quality services for pwds This should include access to transport, education, housing, health – all high quality Public services should be flexible to accommodate individual needs – not one size fits all. This outcome requires political engagement to inform public services 13. We have created a place where people want to live and work, to visit and invest Again, this has an economic focus and it would be hard to see where pwds fit in By getting it right for pwds who live here it might also encourage visitors with disabilities 14. We connect people and opportunities through our infrastructure This should include digital inclusion – more high speed broadband Upgrade the road between Derry/Londonderry to Belfast 4G training Affordability of technology – the cost excludes some pwds More utilizing of technology to support pwds in education and health etc. Access to social, leisure activities and opportunities will improve health and wellbeing 20 D:\81910712.doc Indicator 42 Increase quality of life of people with disabilities This indicator must be underpinned by the UNCRPD in particular Articles 4.3, 5, 6, 7, 19 and 28 The impact of Welfare Reform and specifically fear of cuts and pressure of constantly needing to prove yourself Freedom from fear, worry, anxiety replaced by a reassurance of an adequate level of economic security and adequate standard of living Measurement – research the higher cost of living with a disability Social measure – independent living research what this means and baseline what is currently happening Disparities in legislation within the UK ie GB Equality Act 2010 Access to training, employment and alternatives Underrepresentation in public appointments of pwds Social housing – all (public, housing associations and private) should be built to a disability quality standard Changes in policy such as repayable loans for adaptations results in fear of debt The PfG should have defined what is meant “quality of life” so that we could make an informed response General comments This document is written in a vague manner with no concrete actions which can be seriously measured All outcomes and indicators have an economic focus which will be the main thrust of this Framework Disability issues cut across all 42 indicators and this should be recognised Highly recommend that the outcomes are re-worded, using positive equality language and accompanied by correct and realistic indicators which will ensure achievement of the PfG 21 D:\81910712.doc
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