Cynulliad Cenedlaethol Cymru
Nid yw’r dudalen ar gael yn y Gymraeg

EOC(3) MW 24

Equality of Opportunity Committee

Inquiry into Migrant Workers  

Response from Welsh Local Government Association represents the 22 local authorities

Introduction

The exact numbers of migrant workers in Wales is unknown. The Welsh Local Government Association (WLGA) has found that all local authorities in Wales have experience of A8 economic migration.  Some areas have experienced economic migration on a relatively small scale with minimal impact on service delivery, whilst others have experienced profound demographic change as a result primarily of A8 economic migration. The problems that local authorities encounter in delivering and planning services for migrant workers hinge upon the absolute dearth of information on the number make up and trends of migrant workers in their areas.  Local Authorities experience difficulties in planning and delivering appropriate and high quality public services without a clear picture of the migrant demographic profile.  Financial allocations to some local authorities are currently based on inaccurate statistics and local authorities are working with little or no additional resources delivering services to a community they know little about.

In addition, little is known about the intentions of migrant workers; if they will stay in Wales for a short period of time, or settle in Wales indefinitely. Identifying economic migrant population trends is difficult for Local Authorities and the impact on specific areas of service delivery (e.g. education, housing) is profound. In some instances services are delivered on a reactive basis as a result of the inadequate measurement of the A8 economic migrant population.  

Experiences of migrant workers and their families

Barriers experienced by migrant workers and their families in accessing public services

Migrant workers and their families are experiencing difficulties accessing basic public services such as housing, health care and education.  The following provides an overview of some of the barriers that migrant workers can face when accessing public services in Wales.

Health and Health Services  

Migrant workers are not a homogenous group as and such their health status and needs do vary. There is little evidence that explores the experiences that migrant workers have when accessing health services.  

The North Wales Race Equality Network has explored the effects of rurality and isolation on the health and social care needs of BME people in North Wales.  They note that many migrant workers did not register with primary care providers with many returning to their country of origin for treatment.  Language was a major barrier, in many cases migrant workers do not access health care despite being entitled because they do not feel that the health care system will be able to adequately deal with their needs.  

At a recent migrant worker event organised by Race Equality First and the WLGA health care professionals considered issues relating to migrant workers.  Some of the issues highlighted included barriers to accessing interpretation and translation facilities, and anecdotal evidence of GP’s refusing to register migrant workers and their families despite full entitlement to free primary health care.  

Poor housing is a crucial determinant of health and consistent evidence shows that ill health is exacerbated and can be caused by poor housing conditions.  Anecdotal evidence backed up by a recent report from the Wales TUC suggests that many migrant workers are living in private rented homes that could be damaging to their health; 'experiences range from homes that are damp, unheated, severe overcrowding of houses, accommodation in tents or caravans.’  (TUC Wales, 2007:25).  Migrant workers are particularly vulnerable to housing that could be damaging to their health and well being.    

It is important to recognise that migrant workers are an important staffing resource for the health and social care sector in Wales. In Rhondda Cynon Taff a large proportion of the economic migrant population are from the Philippines and are working as nurses in the local hospital. However little is known about how this section of the health and social care workforce particularly in respect of how they are integrating into the local communities in which they live and work.

Although the ultimate aim of providing health care to economic migrants should be through mainstream services, a model of care to facilitate integration may initially be appropriate that tackles the barriers outlined above. This model should consider ongoing training and development of health care professionals that recognises the specific needs of economic migrants, and appreciates cultural differences. Ultimately, increasing resources available to health providers for translation and interpretation services is the most pressing area for change and is critical to enable equal and fair access to health care for economic migrants and their families in Wales.   

Education and Children’s Services

In several areas of Wales schools are experiencing a high number of admissions of children from eastern European countries (Carmarthen, Wrexham and Cardiff.) Little work has been carried out to determine how schools are dealing with the rise in numbers or how the parents and children navigate and interact with children’s services, particularly schools.   A review of the Foundation Phase in Wales (W.A.G, 2007) identified 'multiculturalismto be an area 'poorly developed in the majority of schools and often misunderstood by practitioners’. Anecdotal evidence from one area in South Wales suggests that migrant worker children are often put into Special Educational Needs (SEN) and the lower academic teaching sets because teachers misunderstand their poor language skills as SEN.  There are some reports that migrant worker children are sometimes prevented from attending school because they are carrying out caring roles for younger family members.  Some children’s practitioners have expressed a desire for training for teaching professionals to learn more about the social and cultural backgrounds of the economic migrant children coming to the schools.  

It is crucial to develop better understanding of how practitioners are managing diverse change and the experiences of migrant ethnic minority children/families in classrooms that have traditionally consisted of predominantly White English or White Welsh speaking pupils.  

Adult Education and ESOL

Educational and training barriers for economic migrants are based on the shortage of appropriate vocational based ESOL courses; in Cardiff there are approximately 600 people currently on the waiting list for ESOL classes.  Many migrant workers report a need for flexible ESOL courses that fit around their long and sometimes erratic shifts patterns.  Most ESOL classes however are a 'one size fits all’ service and some are unable to meet the specific needs of economic migrants.  Language acquisition is critical to the integration of economic migrants.  Lack of ESOL provision means that economic migrants cannot access some public services effectively and it can have knock on effects in other areas, such as health and safety in the workplace.  An appropriately funded strategy and programme of delivery is urgently required to English language needs of economic migrants.  As the major beneficiaries of economic migrant labour, employers should be involved in this strategy and good practice employers who are providing ESOL classes free to employees should be highlighted through a programme of awareness raising and promotion.  

The North East Wales Institute of Higher education undertook a research project to identify adult educational needs from BME communities.  It found that in addition to language barriers the perceived main barriers to undertaking education/training include financial cost, and lack of information about available courses.  There is a need to support adult education providers to target their services and understand the needs of economic migrants.

Progressing in the labour market and utilising the skills and qualifications that some economic migrants have is crucial to the health and growth of the Welsh economy. However, many economic migrants are unable to progress in the Welsh labour market because their qualifications are not recognised by employers; they are consequently working below their skill level and capability.  The NEWI report found that many migrant workers in Wrexham had attained degree qualifications in their country of origin (NEWI, 2006:4).  A key project in England the 'Progress GB Development Partnership’ states; 'the consequence of the barriers to progress in the labour market by refugees and some migrant communities is that the UK is failing to fully benefit from their talents; and while those groups fail to make their way in the labour market, they are less likely to fully integrate into the wider UK society.’  (Progress GB, 2007:4.)  If Wales is to capitalise on the skills of migrant workers, and for migrant workers to integrate and fulfil their potential a method of validating and recognising economic migrants existing qualifications and skills must be addressed and a straightforward system developed.  

Housing

Housing is a key area where economic migrants face significant barriers and problems.  Migrant workers are not generally aware of their rights and many report not having written tenancy agreements.  Race Equality First also present evidence of unscrupulous landlords;  'we found many cases where tenants did not receive any documents from the landlord, including rent books, contracts and bond receipts, which often resulted in problems and confusion.  Withheld bonds are also commonplace.’  (Alicja Zalesinska, Race Equality First, 2007:5.)  There is also a general lack of awareness of council tax processes and liability for bill paying.  

Some employment agencies and employers tie workers into poor quality housing at sometimes extraordinarily high rents. Almost a third of people responding to one recent survey lived in accommodation that came with the job.  The TUC Wales report notes that evidence of poor quality accommodation is typified by damp, unheated and overcrowded conditions that could lead to hazardous conditions such as fire risks were widespread.  (TUC 2007:25).  Race Equality First note that in Cardiff overcrowding in tied accommodation is predominately experienced by Czech and Slovak Roma families, where it is often the case that 2 or 3 families lived together under one roof.  Anecdotal evidence suggests that economic migrants living in these poor conditions felt unable to speak out and assert their housing rights; fear of being sacked and therefore made homeless cited as the most common reason for not complaining.  In addition, local information and advice providers need better resourcing and training to help equip economic migrants with the necessary knowledge and support to challenge the exploitative and vulnerable situations some may find themselves in.  Overall the complex relationship between supply, demand entitlement and need poses short and long term challenges that must be addressed urgently particularly in light of the health and safety risks that are posed by some of the conditions that economic migrants are living in.  

Homelessness

In some areas of Wales there has been a notable increase in the number of people from the A8 countries who are homeless and destitute.  Current policy regarding economic migrants is complex however overall most economic migrants are not entitled to housing benefits until they have lived in the UK for at least 12 months and are registered with the workers registration scheme.  In Cardiff one homeless charity reported that more than half of the people attending a breakfast run were from Poland.  The charity reported a typical scenario that they are increasingly watching unfold with economic migrants from eastern Europe whereby a migrant worker loses his/her job, may have drink or drugs problems, does not possess the WRS or other Home Office documentation and therefore has no recourse to public finds.  Hostels, local authorities and some charities are not able to support those who are destitute and living on the streets.  The workers from this charity described how these individuals are often lured into illegal activity and exploitative situations to make ends meet.  An emergency fund for these individuals who are not entitled to housing support from the Local Authority through the usual WRS and NINo mechanisms should be considered by central government.  

The provision of information and advice

Migrant workers generally find it difficult to access basic advice; they work long hours and have limited knowledge of where to go for advice.  Lack of English language skills makes it difficult for migrant workers to resolve the problems themselves or to seek advice.  In Wales, the particular issue of rurality and access to transport also impacts upon a migrant workers access to information and advice.

Discrimination

Migrant workers are facing many types of discrimination including racial discrimination in some areas of Wales.  However, instances of racial discrimination are notoriously underreported and it is extremely difficult to gain a clear picture of the extent and nature of the discrimination that migrant workers are facing.  The Flintshire 'Open Door’ project reports and increase in the number of migrant workers who use their service who have experienced racial abuse.  Wrexham CBC has been proactive in this area and is currently formulating a community cohesion strategy for the borough.  A proactive strategy to tackle the discrimination and abuse that is increasing in number within some areas of Wales targeted at migrant workers is urgently needed.  

In summary the experiences of migrant workers when accessing public services is diverse and no comprehensive survey or analysis in Wales has been undertook to date.  Evidence available is therefore mainly anecdotal, a key theme however is that the lack of English language courses pose the biggest barrier to accessing public services. There is a severe unmet need for translation services and this makes economic migrants particularly at risk of exploitation, and discrimination.

Some local authorities are playing a key role in helping to protect and support economic migrants from exploitation and below is a summary of some of these activities.   

Examples of innovative practice in ensuring that public services are accessible and barriers can be overcome

Several local authorities run multi agency forums for migrant for example, Flintshire, Wrexham, Rhondda Cynon Taff, and Merthyr Tydfil.  The forums provide strategic management at the local level and involve cross agency stakeholders.  These forums are characterised by good leadership and effective local partnerships, for example, in Merthyr Tydfil, the need for English language classes that catered specifically for migrant workers was highlighted in the forum.  In partnership with other service providers such as local colleges, ESOL classes are running twice a week in the evening.   Funding for initiatives that result from the partnerships is generally relatively small and short term.  In Flintshire the 'Open Door’ project provides a drop in centre for A8 economic migrants and functions on £3200 a year. In 6 months the project has had more than 350 visitors.  

Efforts have been made by local authorities to improve ESOL provision, for example, in Flintshire the local authority partnership and the TGWU are working together to deliver a 20 week English language course.  Flintshire are supporting a research initiative entitled 'promoting the ethically diverse classroom’.  The research aims to develop an understanding of the challenges encountered by primary school teachers and inform teacher training in this area.  (Hamilton, 2007).  

Welcome Packs have been produced by a number of authorities (Wrexham, and RCT).  These give basic information in a variety of language on local service and provision. The Welcome Packs have been very successful in helping to support the integration of economic migrants into the community.  

A report commissioned by the Reaching Wider North Wales Partnership at NEWI acknowledged that the primary concerns of this new community were for housing, food and employment; the long term needs included successful integration into the community and education system allowing for utilisation of existing skills and improvement of employability with the UK. In response to these long term needs, NEWI in 2006/07 with funds from the Reaching Wider Partnership, designed and delivered four short modules in British Culture, Communication and English for Academic Purposes.  This project was a success and is now into its second year and moving into Flintshire

In England NIACE have led an innovative project 'Progress GB’ with 11 partner organisations the project aims to pilot new approaches to improve lifelong learning and employment opportunities and enhance the careers and integration of refugees and migrants in the UK labour market and wider society.  Recognising the skills and qualifications of economic migrants is critical and the project has worked with the Centre for Urban and Regional Studies at the University of Birmingham to develop models to support recognition through skills auditing, work experience and top up training.

Finally, a major project that has impacted upon work targeted at economic migrants is the Curiad Calon Cymru - which is the co-ordinator for the EQUAL project, funded through the European Social Fund.  Fourteen partner organisations in Wales participate in this project.  The cluster revolving around issues concerning economic migrants has 5 development workers in Wales which are based in Bangor (the North Wales Race Equality Network, one worker), Abercynon (The Valleys Race Equality Council, two workers) and Newport (The South East Wales Race Equality Council, one worker) and Cardiff (Race Equality First).  The funding for the project and the project officers will end in December 2007 with the exception of VALREC who have secured funding until March 2008.   To date none of the participating Race Equality Councils have been able to secure continuation funding.  The work carried out by the REC’s has been substantial and have been captured in reports available from the respective REC.  

Examples of good and poor working and housing conditions

There is a need to develop partnerships with those employers who are developing good employment practices for economic migrants.  Wrexham CBC has held several seminars with local businesses that employ migrant workers to begin this dialogue.  Poor working conditions are generally underreported by economic migrants because of fear of reprisals, similarly there is no authoritative evidence of poor housing conditions rather what is emerging from recent reports such as the TUC Wales (echoed by evidence gathered by the local Race Equality Councils and others) is a high incident rate and pattern of poor housing typified by overcrowding.  An urgent review of current employment legislation should be undertaken and the position of tied accommodation employment contracts revisited.

Examples of the English and Welsh language provision for migrant workers and their families

Local authorities are working to improve ESOL provision, for example, in Flintshire the local authority partnership and the TGWU are working together to deliver a 20 week English language course.  The course will take place in the local police station.  Delivering this course in the local police station will help to alleviate the mistrust that some of the migrant worker population have shown towards the police and it is hoped will help build closer community relations between the migrant worker population and the police service.  

Similarly in Llanelli the Polish Mutual Association delivers ESOL training to local economic migrants which is aligned to the specific needs of this group, and is very much vocational based tuition.

Opportunities for migrant workers and their families to build friendships and social networks between themselves and within local communities

Opportunities to socialise with each other and the local community are limited for migrant workers and isolation is a major problem for migrant workers.  There are a number of groups across Wales that do provide leisure and social opportunities but these are limited in number and capacity.  In Gwent the SEWREC development officer has helped to establish several community groups African Roots Alive, Haweenks Somali and the Russian Speaking Women's Association. The Gwent Association for Voluntary Organisations (GAVO) provide support to the Somali and Russian community groups.   

There are three established groups in Cardiff that provide social networking opportunities to Polish economic migrants; the Central and Eastern European Association of Cardiff, the main aim of the group is to develop a drop-in support and advice centre and to represent migrant workers issues on local forums. Race Equality First is regularly assisting the group in planning and making contact with community development support organisations.  The Polish House, Newport Road is owned by the Polish Diocese they run social evenings for polish people living in the area.  In Carmarthen the Polish Mutual Association has been critical in developing links amongst migrant workers themselves and the indigenous community.  

The resource implications of economic migrants for public service providers

The following is a general overview of the impact that economic migrants have had on public service providers in Wales.

Health and health care services

Health services are generally reporting that migrant workers are making little impact on health services; this is because economic migrants are generally young and healthy, typically aged between 18 and 34, and as discussed in point 1.1 economic migrants will return to their country of origin for treatment, and are generally not aware of the health services that are available to them.  Health service providers are cautionary and believe that there could be a marked increase in demand for services as more migrant workers bring their families to Wales.  

There have been some particular instances of impact on health care services in some areas.  In Carmarthen and Flintshire there have been reports of inappropriate use of accident and emergency hospital facilities as many A8 migrants are not familiar with the UK system that separates primary and acute care. In addition, a critical lack of appropriately skilled and trained interpreters that are available in health care settings is one of the most crucial barriers for service providers to be able to meet the health needs of migrant workers and their families.  Health professionals also point to economic migrants generally lacking documentation or historical health records.  Migrant workers need clear information on how they can access health services and health service staff needs better information available to them about their health history, needs and entitlements to services.  

Education and Children’s Services

A recent report 'Estimating the Scale and Impacts of Migration at the Local Level’ (LGA, 2007) highlights the impact on schools, pressures include translation services, understanding cultural differences, mid-term arrivals, numeracy and literacy and the lack of records and assessments.  Translation support from teaching assistants with language skills in A8 languages are severely lacking; Conwy and Flintshire report a significant shortage of translators to meet the specialist language needs of migrant worker children in schools.  Child protection teams also report a lack of understanding and support of current complex legislation, in addition it can be highly complex to investigate a family situation of transient families, including language and cross cultural issues to ensure effective safeguarding.  Training and guidance for front line children’s services staff is needed to address these issues.  

Adult Education and ESOL

There is insufficient ESOL provision and part of the problem is that there is a severe shortage of ESOL teachers.  ESOL funding arrangements are also restricting Local Authorities ability to provide appropriate ESOL classes.  ESOL classes are funded based upon the number of course completers and this arrangement is not suitable for securing funding to meet the needs of migrant workers who are generally a transient population.  A review of current funding arrangements should be undertaken in light of these issues.   

Housing

Housing alongside education is one of the key service areas where migration has impacted the most.  In respect of private rented accommodation local authorities report in some areas growing pressure on regulatory and enforcement services e.g. inspecting housing of multiple occupation and there is a clear need for more resources in this area to help prevent the types of exploitation discussed previously.  As described by the TUC Wales, the Gang Masters Licensing Authority has not been able to enforce reasonable accommodation standards.  In addition, the potential negative effects that housing allocation has on community cohesion have been reported by one local authority who described how relations between economic migrants and the indigenous community were volatile because previous council owned housing had been bought by private landlords and rented to the migrant worker communities.   There was an assumption amongst the indigenous community that the housing was still council owned and that the migrant communities were being given special access to social housing and  'jumping the queue’.  This example highlights how the provision of services to new economic migrants must be anchored within a community cohesion context. It demonstrates the difficult role that local authorities play in balancing the need to deliver specialist services (such as ESOL classes) and aligning mainstream services to meet the needs of all members of the community including migrant workers that they have very little or inaccurate information about.  Overarching this delicate balancing act performed by local authorities is the need to construct positive community relations and promote the benefits that economic migration brings to the community.  

It is important to note that in one area economic migrants are helping to bolster the private rented housing sector.  In Cardiff there has been a saturation of student rental properties due to the Talybont student accommodation development.  Economic migrants are reported to be filling empty private rented accommodation.

In relation to social housing, stock is shrinking due to Right to Buy and new investment via registered social landlords (RSL’s) is not sufficient to replace lost stock. This is compounded by reduced levels of tenancy turnover due to the limited alternative housing options and therefore a reduced level of re lets available each year. Waiting lists are very long and only the most desperate can be housed. (e.g. in Cardiff 50% of lettings available are to homeless households.)  Although migrant workers are not yet showing up to any great extent on waiting lists, there are concerns that as new households/families are formed that they will increase pressure on social housing stock.

Information and advice

A report by the Audit Commission found that there is widespread confusion about entitlements amongst migrant workers and those who try to help them.  Voluntary sector agencies in particular the Citizens Advice Bureau record an increase in migrant workers presenting to them with problems typically relating to employment and accommodation.  CAB and other information and advice providers highlight the large resource implications dealing with an economic migrant who does not possess basic English or Welsh language skills, and CAB state the it take three times longer to deal with an economic migrant than an English or Welsh speaker.  The need to adequately finance information and advice providing bodies is paramount.  Comprehensive guidance on the legal positions of different categories of migrant workers is also needed.  Currently Local Authorities have to take separate legal advice when questions about entitlements arise, this is costly and time consuming for local authorities.  

Advantages and challenges for people in local communities in which migrant workers live and work

Without economic migrant labour many local businesses in Wales report that they would not be able to continue production in Wales.  Obvious advantages are therefore focused on the business benefits of economic migrants.  Migrant workers bring with them skills and experience, however, many economic migrants end up in low skilled jobs.  This has a double deficit in that their valuable and much needed skills are not utilised and in some cases they may be perceived to be competing with the lower skilled jobs, causing resentment and tensions. Measures to make it easier for economic migrants to utilise their skills and contribute to the local community are needed.

Rapid and unexpected change in local demography’s can be unsettling and bring about local tensions challenges and concerns about competition.  Local resentment towards new communities can be fuelled by what are generally minor problems that can be straightforward to resolve.  For example, in Wrexham tensions were rising because the local economic migrants did not understand recycling or refuse systems.  The Local Authority quickly responded by producing information to migrant workers households explaining the refuse collection systems.  Noise and disruption as migrant workers leave for work early in the morning, and tensions over car parking are also reported in some areas.

The regulatory framework - Current legislation; the Gang Masters Licensing Act 2005

The remit of the GLA is currently limited to agriculture, horticulture and food, drink and shellfish processing and packaging.  However, many gang masters are now employing migrants on other sectors such as construction and care homes.  In Wales the major work delivered by migrant workers is in industries that are not covered by the GLA such as hospitality and catering.  The TUC Wales report states that four out of ten workers are working in administrative and management services which include employment agencies, and a further 18 per cent working in hospitality and catering, and 15 per cent in manufacturing.  These industries are not within the GLA’s remit; these leave economic migrants in Wales particularly vulnerable to exploitation and abuse.  Extension of the GLA remit so that it is aligned with that of the Health and Safety Executive and covers all sectors where migrants are at risk of exploitation.  In addition, the capacity of the GLA is severely limited in Wales; there is no enforcement staff despite 34 gang masters registered in Wales.  

It is important to note that there is an international framework in place to protect and promote the rights of economic migrants; in particular the 1990 United Nations Convention on the Rights of Migrant Workers and Members of their Families.  However, the UK has not yet ratified this Convention and a rights based policy framework is missing from current policy development concerning economic migrants.  The WAG could lead the UK in adopting this international framework as a starting point for strategic development for migrants in Wales.

Examples of community relations employment policies and workplace initiatives good practice

Examples of community cohesion initiatives can be found at local and national government levels in Wales.   At a local level, Wrexham CBC is developing its own community cohesion strategy and as heard at previous evidence session has implemented the 'One Wrexham’ initiatives to foster good relations.  Cardiff City Council is one of two UK cities to be invited to participate in the British Council 'Open Cities’ project.  The project will consider ways in which immigration can significantly contribute to city success; other partner cities are Madrid, Bilbao, Belfast, Dublin Cologne and the Hague.  

In relation to integration in Cardiff Race Equality First organised a trip to St Fagan’s National Museum for migrant workers.  The trips seem to have provided the migrant workers with the opportunity to learn about welsh history and culture increased confidence to integrate within the city was noted as an additional benefit; 'the very positive impact seems to be the fact that this group of people seems to have gained a lot of confidence in getting around Cardiff and the local area and they are organising local trips on their own.’  (zl:2007:8).  In Merthyr Tydfil VALREC have supported the establishment of the International Club which is fully constituted and run by local economic migrants. The Club organises social events which are attended by a large number of the local economic migrant population.  These types of initiatives are rare and most migrant workers do not for a variety of reasons integrate with the local indigenous community.  

In Wrexham the Local Authority has organised two seminars for local businesses to discuss economic migrants in the area.  

Suggestions

The WLGA believe that development of policy and services in relation to migrant workers should take a rights based approach; this approach recognises the rights that migrant workers have to live and work in Wales as equal citizens.  Individuals who come to Wales to work and/or live have a contribution to make and stories to tell.  However, without accurate figures and corresponding fair and realistic funding some authorities could struggle to provide the services that meet the needs and fulfil the rights of migrant workers.  A sensible informed debate beginning from this rights based premise will help to balance the negative context in which much of the discussion concerning migrant workers is taking place at the moment.

There is room for far greater coordinated activity between UK Government, the Welsh Assembly Government and local government in Wales.  As the major provider of public services for economic migrant’s local government must be consulted and their experience drawn upon when developing policy relating to economic migrants in Wales.  

Extra funding should be given to areas in Wales that experience rapid population change and the system for measuring migration must be radically overhauled.  The numbers of migrants in many areas of Wales has been significantly underestimated.  For some areas the issue of migration is a relatively new one and a funded programme of support should be considered to enable the sharing of good practice, and encourage the cross fertilisation of ideas. Some innovative work is already happening in Wales in partnership with other agencies such as the police and the local voluntary sector.  Better knowledge and more funding will help to ensure that all local authorities are appropriately equipped to respond to the diverse needs of Wales’ new communities.

For further information please contact:

Maria Allen
maria.allen@wlga.gov.uk
Welsh Local Government Association
Local Government House
Drake walk
Cardiff  CF10 4LG Tel: 029 2046 8631