Appendix 1
Argyll and Bute Council · 21 August 2025
Back to Policy and Resources Committee — 21 August 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
Appendix 1 Responses received to consultation April 2025 to June 2025 and feedback on those responses 1 There is no guidance as to how, and on what basis, the CC accounts should be prepared. Response: The Best Practice Agreement sets out the example layout for income and expenditure accounting. In most cases this form of accounting will be adequate and subject to scrutiny by the independent examiner. The public can also question spend allocated at meetings, or when the accounts are presented at the AGM. It does not preclude a more detailed audit of accounts, or a different layout being prepared. It is best, however, to leave this to choice and simply set out the minimum standard of accounting that is required. 2 Appropriate independent review and sign-off is a function of 1 (see above). Meaningful review requires a standard against which to review the presented financial statements. Response: The minimum standard is as set out in the Best Practice Agreement. Any additional funding received by community councils is often by their agreement with the provider of the funding. It may be beneficial for those community council to arrange with that provider how to account for the funds it receives and distributes from them. If this is not stipulated, it could be suggested that those providing funds are content with the provisions within the Scheme and Best Practice Agreement. 3 Small charity rules under OSCR Regulations are permitted for annual Receipts or Payments under £250K. These include a definition of appropriate criteria for Independent Examiners. The concept of Restricted Funds is equally valid for CCs, who often hold funding with strings attached, that ought to be disclosed as such. I accordingly suggest that the OSCR Regs should be adopted for CCs, modified to remove the "charitable purpose" provisions. Response: It should be a matter for individual community councils to determine how their accounts are best laid out. The minimum criteria is as per the Best Practice Agreement but that does not preclude any individual community council from taking the view that they would like to base their accounts on the OSCR Regs, per the suggestion. This should, however be a choice, not a requirement laid out in the governing documents. 4 Renewable Energy Community Benefit funding has the potential to dominate CC finances, so a reasonably rigorous framework for accounting for such large flows needs to be put in place as part of this Review Response: As above. If funders provide alternative funding, they should also have a level of scrutiny attached to that funding stream that gives an ongoing account of how funds are being allocated and accounted for.
Page 2
Appendix 1 5 I do not agree with the view expressed by elected representatives in public CC meetings that the sole concern is to account for what happened to the modest funding by Argyll & Bute, and the rest is up to the CC itself. That will not pass any test of public credibility once the renewables community benefits start to flow at scale. Having a Scheme requires meaningful oversight to be exercised by the local authority. Response: See comments above. 6 OSCR does not require Audit ( which has a technical and rigorous specific meaning in this context ) for entities under £250K. Independent Examination is a sufficient level of scrutiny. Response: Independent examination is the standard we are seeking in terms of accounting. 7 It may be that for annual flows under say £1000, the current "relaxed" regime might suffice. A balance sheet net asset criterion might also be considered, say £10000. Response: The majority of community councils receive less than £1000 per annum and do not hold assets of any value. 8 It is not fair to the reviewer if these issues are not nailed down properly, there might be a mismatch of complexity and capability. Response: The independent examiner is being asked to review income and expenditure accounts and vouch that these accord with the bank statements and receipts they have been provided with. It could be argued that putting in place a tiered approach to account would be complex and confusing given the majority of community councils manage funds well below £1000. 9 I have not studied your proposed amendments in detail, but having quickly scanned your suggested amendments, I wonder if there should be a further amendment at Appendix 5 where, in the 2nd line of the first paragraph you refer to "approved audited accounts" As you are proposing to soften the minimum requirement from "audited" to "examined", I would suggest that the word "audited" should be deleted from Appendix 5 which would then simply read "approved accounts". This would cover both situations where accounts are either "examined" or "audited". Response: The proposal is to amend all mentions of requirements to audit to be independently examined. The document mentioned is included in the draft amended Scheme attached at Appendix 2 and does not included any reference to “audited”. 10 One significant point emerged, concerning the timescale for the production of minutes - Page 5 section 3.7 (b). We suggest part of the difficulty faced by community councils in meeting the requirements as specified may be the lack of distinction in the text between Draft Minutes and final Approved Minutes. Three
Page 3
Appendix 1 weeks would be a fair time to allow for the circulation of Draft Minutes, but these do not normally become finalised until approved at the following community council meeting, when minor corrections may still be requested. This is despite the fact that in our case we circulate Provisional Draft Minutes usually within 7- 10 days for members to comment on before the formal Draft Minutes are circulated. Normally we have sent you both the Draft Minutes and the Approved Minutes separately - I assumed without causing confusion. Response: There is no confusion caused as documents from this community council are clearly marked “draft” and “final”. The scheme calls for minutes to be provided “more specifically to the CCLO within 14 days of the meeting taking place”. The assumption, due to timeframe, is that these are in draft format but there is no objection to this being reflected in the Scheme and this has been added at to the attached draft Scheme at the clause mentioned above. 11 I give notice that I object to the financial arrangements for funding community councils. The objection applies to 1. Community council areas that are partly on maonland and partly on one or more islands, and 2. Community Council areas that cover two or more islands. My objection is that there shoud be special funds available to individual community council members to pay travel and hotel expenses where an overnight stay is necessary. In the case of cimmunity councillors who are too disaled to drive they should be entitled to a refund of taxi fares where there are no buses available. [sic] Response: It would be a matter for agreement of elected members to determine final grant levels. At present, the budget provided is sufficient to pay the existing grant levels set and therefore officers cannot recommend any increase to budgets. Regarding payment of expenses, that would be a matter for the community council to agree to pay those expenses, having regard to funding at their disposal. 12 Our discussions have led to the opinion that better and closer contact with the elected ward Councillors would enhance the relationship with the council and within the local community. There should, we believe, be an expectation for co- operation between the Community Council(s) and elected officials and that this should be recorded and monitored for evaluation purposes to gauge the efficacy of both. We do not believe that this should be created as a mandatory requirement , but the establishment of a formal covenant to bond together and form a cohesive and progressive partnership for the benefit of all concerned. This is apparently lacking in the present relationship. Regular face to face meetings at mutually agreed locations would be the main feature of such an arrangement. Response: While attendance by elected members at community councils can be beneficial, this does require to be balanced with other responsibilities that members have. Receiving minutes and agendas keep members informed on what is happening locally. Engagement by email in terms of assisting or signposting is achieved out with
Page 4
Appendix 1 meetings, and members are also accessible at surgeries and meetings such as area committees where public question time routinely features. In terms of the suggestion made, if the desire is more connection with elected members, this is perhaps one that politicians might explore independently from the governance framework review. 13 Argyll & Bute Council proposal for the administration grants which are detailed in appendix 5. Two issues arise: 1. Helensburgh is the only Community Council in Argyll & Bute with an electorate in excess of 10,000. Oban and Dunoon are the only other Community Councils with an electorate in excess of 5000. The proposed level of administration grant for these 3 community councils remains at £700 a year – no increase on the 2022 level of grant. All of this means that Helensburgh continues to receive far and away the lowest administration grant per elector of any Community Council in Argyll & Bute. 2. For approximately the last 15 years the administration grant has been topped up by Argyll & Bute Council with a discretionary grant of 10p per elector. This still leaves Helensburgh Community Council with far and away the lowest total grant per elector in Argyll & Bute. As this grant is (I believe) still discretionary, I believe that it and the administrative grant should be merged. Response: There are no proposals from officers to increase any of the administration grant levels because the budget received to support community councils would be insufficient to offer an increase. The discretionary grant does enhance the annual payment made to all community councils in effort to address what is potentially seen as an imbalance due to the size of electorate represented by larger community councils. However, it has very limited impact on smaller community councils with the smallest grant being an additional £11.40 on top of the £400 administration grant. Any decision to increase grant provision would need to come with additional budget. On the point about the discretionary grant being made more permanent – that again would be a political decision and would see funding being necessary on a rolling 4 year period to tie in with what would then be a commitment to provide this within the Scheme. 14 Following circulation of the documentation relating to the above review, it was considered by Oban Community Council at its last meeting held on 26 May. It was universally agreed that the proposed changes were fully acceptable. Response: It is anticipated that the majority of community councils have taken the view that the proposals are acceptable to them as others have given verbal feedback indicating much the same sentiments as offered by this community council. 15 Page 4, amend paragraph 3.7 to add the sentence from the Model Scheme “Good Practice Guidance has been produced to help Community Councils to deliver on these responsibilities.” Content Clarity needed here. Where is this to be inserted so the paragraph makes sense? Response: Please see attached document for clarity 16 Page 5, 3.7(b) increase the timescale for production of minutes to within 21 days after the meeting – Previously this was 14 although was 20 days in the Content but should perhaps also indicate the ‘publication’ for the
Page 5
Appendix 1 2013-18 local Scheme. The 2023 model Scheme specifies that minutes should be submitted within 30 days. On the basis that we do see some capacity issues in smaller CCs, 3 weeks is not an unreasonable period, and it is proposed to meet in the middle of the requirements from the Model Scheme and our existing Scheme. community as well within the 21 days. Whilst covered in standing orders could to re-iterated here. Response: See previous comment, proposals have been updated to clarify that these relate to draft minutes. 17 Page 5, 3.7 – add an additional clause (g) “Respond to enquiries and feedback from the community” adopted from the model Scheme 2023. Content but need means for enquiries to be submitted and a timeframe for responses. Has cost implications for a CC in relation say to a web based email address. Response: It could be restrictive to set out how an enquiry should be received (not all community councils will even have online presence) or how long a community council might take to respond. There is no need to overcomplicate and set out unrealistic target dates when this could be subject of a local agreement, tailored to the needs and wants of each community and how they want to, or already do, link in with their community council. It is also possible that a draft guidance document for local amendment, similar to those which exist for complaints and declaring interests can be prepared by the CCLO, if the proposals are agreed. 18 Page 5, 4.1 – Make clear boundary maps are online accessible through the link ArcGIS Web Application. Content – however there may be cost implications for CC to have access to ARCGIS in a usable format for mapping / planning e.g. Parish Online (very useful) Response: The link provided is free to access and will allow a view of the boundaries to aid community councils establish the exact boundary line. 19 Additional point: Page 5, 5.1 age of CC members Given the new Disclosure Regulations where Children are classed as under 18 has any consideration been given to possible implications for CCs. Will all members need to be PVG checked as it may dissuade people from standing and has an explicit cost – will this be borne by A&B Council or the CC itself? Response: No, this query has also been picked up in a separate response to the CC who raised with the Team. There is no requirement for community councillors to be
Page 6
Appendix 1 20 disclosure checked. If there is a change in this position then advice on this would be given. Page 6, 6.2 – add that “interim by elections will take place in year 2 of the 4 year term, on a date specified by the Returning Officer, in respect of all vacancies, including those currently filled by co- option”. There has not been a situation where there has not been a requirement for the interim by- election. Provision being inbuilt will allow for staff to consider timing of elections against other electoral events earlier, and for community councils to have adequate time to locally promote the by-election. Content Clarity needed here. Is this a new paragraph or sentence addition? Response: Please see the attached draft Scheme. 21 Page 10, 8.1 – amend to use full wording from the 2023 model Scheme. This reads “The Equality Act 2010 makes it unlawful to discriminate against persons or groups on the grounds of the protected characteristics of race, sex, gender recognition, disability, age, sexual orientation, marriage and civil partnership, pregnancy and maternity, and religion or belief. Content Clarity needed here. How is this to be amended? Are all 3 paragraphs just replacing what is there? Response: Please see the attached draft Scheme. 22 Pages 10 & 11, 9.5 – add wording in from the 2023 model scheme re the best practice about recordings (audio or video) and expand regarding the duration that these will be retained for in line with ICO guidance. Can this be made absolutely clear as recording, including of inputs from the public, can be a contentious issue. Clarity needed here & be aware that consent is needed. What are the provisions in the case consent is not given? Response: Please see the attached draft Scheme. 23 Page 11, 10.4 – update to reflect that minutes should be submitted to the Community Council Liaison Officer within 21 days of the meeting taking place (as set out above). Content – but also be clear about the publication for the public as well. Response: Please see comments above. 24 Page 12, 11.5 – Remove reference to Audited accounts, the required minimum level of scrutiny is for the accounts to be independently examined (as previously agreed). This section should reflect this. Also update the first bullet point to make clear that audit fees can be paid from the administration grant, should a community council prefer a higher level of scrutiny of their accounts to be applied. Given the size of the administrative grant and audit costs – would this only apply should a CC be in receipt of funds from other sources over a certain level? Then the audit costs could be drawn from those funds overheads? Needs further
Page 7
Appendix 1 clarity on the scope & scale of a requirement / choice for audited accounts. If remove need for audited accounts then should audited fees be deleted or left in case a CC decides (or is required by a specific grant) to have audited accounts? Response: The base level is that an audit is not necessary, but to give the flexibility of choice mentioned in previous feedback in this appendix, leaving the costs of an audit within the approved use of the admin grant may be useful. This may also prove useful if the community council have a one off need to have accounts audited because they have successfully obtained grant funding but the costs of an audit cannot be met from those funds. 25 Page 13, 13.3 – Complaints received should be subject of a “sift” process to determine whether, on the face of it, there is a competently stated complaint. It would be appropriate for this to be delegated to the relevant Executive Director in consultation with the Chair of the PPSL Committee who will rule on matters of competency. That decision will be full and final and will either result in the complaint being rejected or a complaint being referred by the CCLO to a Conduct Review Panel for consideration. Can there be clarity around receipt of anonymous complaints. That might be in the ‘sifting’ but would be good to be clear about this. There may be times when a complaint is confidential (harassment issues for example) but completely anonymous are hard to address. Please define ‘competently stated’. Response: Anonymous complaints in general should not be accepted. If there is a request accompanying a complaint for anonymity, then that should be discussed with the CCLO before progressing any further. It’s not possible to issue one size fits all guidance on this. Competently stated would mean that nature of the complaint constitutes a breach of the Scheme. A complaint must tie back to the Scheme (including constitution and Standing Orders) or the Code of Conduct. Where this is not evident, the complaint is not competent. 26 Page 13, 13.4 – Clarify that the term vexatious is a complaint is one that is made with the intention of causing annoyance, frustration, or disruption rather than addressing a genuine grievance. Remove the word ‘vexatious’ as a cause of much concern if a complaint is found to be ‘vexatious’'. Perhaps just use ‘founded / unfounded’ complaint or something else more suitable and less ‘litigious’ sounding? Response – it is important to retain the use of “vexatious” as this has different meaning than founded/unfounded and we are content that the explanation of the term is sufficient.
Page 8
Appendix 1 27 Page 14, 13.5 – Add provision for mitigating circumstances to be taken into account and where these are evident, and the breach is minor, an acknowledgement that the breach is de minimis but decision to take no further action is a permissible outcome. Perhaps make the language more user friendly. Most community councillors are not lawyers! Plain English! Clarity is needed here. Is this another point being added i.e. 13.5.5? Response: Please see attached copy of the draft scheme for clarity. We have amended the Scheme to provide further clarity “the breach is of such minimal significance and materiality (de minimis).” 28 Page 14, 13.7 – Add word “competent” for consistency with amendments to 13.3 and that decision under paragraph 13.5.5 can also be referred to a Conduct Review Panel. Content Where is paragraph 13.5.5? Response: Please see attached copy of the draft Scheme. 29 Page 15, 13.12 – Add additional provisions for where there is mitigating circumstances and a breach is minor to recommend a community council issue and acknowledge this but otherwise to take no further action. Enhance the range of sanctions available to include formal written warnings that can remain in place for set durations, up to a maximum of 12 months; invite a community council or community councillor to participate in training on mandatory skills such as community engagement, planning training and/or governance training. Content Clarity is needed here – the actual text needs to be presented. Also, has another point been created? This should be explicitly stated. Response: Please see attached copy of the draft Scheme. 30 Page 16, 13.13 – remove 13.3 and replace with paragraph 13.5.5. Amend the reasons to redirect a complaint to the community council for consideration which will now be based on clauses 13.2, 13.4, 13.5 and 13.6. Content Which is 13.3? Is it 13.12.3? Where is 13.5.5? Clarity is needed. The actual text should be presented. Response: Please see attached copy of the draft Scheme. 31 Page 16, 13.15 - paragraph 13.12.5 is renumbered as 13.12.7 Content This is unclear. Where is 13.12.7 now? Response: Please see attached copy of the draft Scheme. 32 Page 20, 12(e) – for consistency, update the timescale for production of draft minutes to 21 days (per comments above). Plus issue of publication for public. Response: Please see earlier comments. 33 Page 4, 12 – Removed reference to audited accounts and replace with independently examined, in accordance with the Scheme. Also make clear it will be draft AGM minutes that require to be submitted as part of the request to release an administration grant. Perhaps provide some guidance on when CC accounts need to be audited e.g. if in receipt of grants above a certain level or where this is a requirement of the grant giver. This would
Page 9
Appendix 1 provide some confidence to non-financial CCs that following appropriate regulations. Response: Please see previous comments regarding a tiered approach to financial accounting. 34 Page 4, 14 – Remove provision for printing as this is used infrequently due to the use of email etc and puts CSC budgets under strain if large volume prints are suddenly requested. Administration budgets can be used to purchase print equipment and printer consumables. Given the size of the administrative grant (see below) then costs may not be covered properly and Community Councillors bear the costs as ‘donation’. Response: There are no other comments suggesting that the costs of print etc are being met by individual community councillors and we often see purchases of toners or paper within the income and expenditure accounts suggesting that there are many who do have print resources or use their own and reclaim for consumables. 35 Page 4, 17 – Add that recordings of area committees will be available. Will this include Community Planning Group meetings? Response: At present, those meetings are not recorded and accordingly have not been included. 36 Page 7, 10 – Make clear that having agreed priorities for the CC to achieve may encourage more people to become involved in the community council as there is clear purpose about what the CC want to achieve during the electoral term. Seems back to front! The elections will determine the members and their priorities – need to be clearer about the purpose but priorities rest with the elected CC members and not necessarily bound by prior decisions. Clarity is needed here as this makes no sense. Response: This section refers to priorities being set early in the electoral term. Those can then be used as a mechanism to encourage other members during by-elections to stand for election as the aims of the community council are clearly established. 37 Page 7, 13 – clarify that minutes should be displayed in accordance with Constitution. Put in time frame (21 days) and also identify good practice for displaying minutes – accepting that over time this may change (website / library / social media). Note there is nothing about archiving minutes or does this rest with A&B Council?
Page 10
Appendix 1 Response: There is no objection to clarifying timescale for consistency. Minutes of community councils should, once approved and signed by the chair, be held in perpetuity by the community council themselves. Many will retain scanned documents on memory sticks which should be passed on per the requirements of the Scheme to any subsequent office bearer. 38 Page 10, 3.1 – Update to reference changes to the “Customer Service Charter”. Content Clarification of the text is needed. Response; Please see the attached documents for clarification of changes. These reflect the information on the “contact us” section of the website. 39 Page 11, 6.1 – Remove reference to the Complaints process as the complaints process is only accessible to a “member of the public”, as defined by Section 5 of the Scottish Public Services Ombudsman Act 2002. This does not preclude a community council from raising issues with Service Manager where they are not satisfied with the action taken or response to an enquiry, or from acting on behalf of a member of the public or helping a person complain. In this case the person’s written consent for the community council to act on their behalf would be sought. Content Wording is actually ‘complaints procedure’ not ‘process’, which is different. Again, clarification of the text to be used is required. Response: Please see attached draft Best Practice Agreement 40 Page 14, 4.1 – Remove reference to the person examining the accounts being “preferably a qualified accountant” to be consistent with provisions in the Scheme which read “examined by a person of good standing appointed by the community council, who must not be a member of that community council” Content – but as suggested above something about the size of the CC funds and when a more formal audit is required might be helpful. Response: Please see earlier comments about a tiered approach to accounting. 41 Administration Grant In accordance with the Scheme for the Establishment of Community Councils, Argyll and Bute Council, upon production of the approved audited accounts (OR IF THIS IS NO LONGER A REQUIREMENT THEN NEEDS TO BE CHANGED), and subject to the community council ensuring they have brought the Council up to date with recorDs of meetings, may provide an administrative grant to community councils to assist with the operating costs of the community council. (Why is this ‘may’ rather than a requirements) Administrative grants are as follows: Number in Electorate Grant Payable (£)
Page 11
Appendix 1 Up to 600 400 601 - 1000 400 1001 – 5000 500 5001 + 700 C&K Response: 1. The document needs to be amended re ‘approved audited accounts’ to be in line with the Scheme and Best Practice 2. Grant Payable – this is a reduction in the grant from 2024/25 (£626) and doesn’t reflect the reality of expenditure by a CC. For instance issues of website fees / access to mapping tools for LPP and other place based work / room hire for meetings / consultations / inflation……. Suggest that the figures for each ‘tier’ are doubled! Response: The expression “may” is lifted from requirements set out within the Local Government (Scotland) Act 1973. In regard to the discretionary comments and request for the grant figures to be doubled, please see earlier comments. 42 We think that the Financial Guidelines contained in the Best Practices Agreement 2022 need to be reviewed, especially sections 4 and 5 Response: It is not clear what we are being asked to review here. The only proposed change was to remove reference to the person examining the accounts would preferably be “a qualified accountant” for consistency that the person conducting the examination could be “a person of good standing appointed by the community council …”. It does not mean the sections were not reviewed. It would be helpful if the respondent could have said what they don’t feel is appropriate in those sections to be in a position to offer feedback. 43 It should be made clear that if the changes are made in these documents then it is likely that Community Council Constitutions (and standing orders) may also need to be updated. Providing good templates for this for new CCs in later 2026 could be helpful. Response: The purpose of the review is to amend the governance framework for the post-election period from 20 August 2026 to 2030. New constitutions etc will be based on any updates agreed during this review and presented to community councils at their inaugural meetings, which will be arranged by the Returning Officer, following elections on 20 August 2026. 44 Document control. There is a need to carefully date / paginate documents and, if revised this is made clear. At times it was not clear whether material already with CCs and with A&BC were the same making this task more difficult. Response: Agreed, and this is why we have not produced a revised draft Scheme until proposals had been consulted on. Not all changes may be progressed until views are sought.
Page 12
Appendix 1 45 A request for the future is that when amendments to the text are being proposed the ‘actual effect of the amendment’ be presented to ensure clear interpretation / understanding by the reviewer. Response: We will consider going back to a tracked change document, in addition to the list of changes necessary to meet with accessibility needs, if this might be more helpful. 46 Proposed Amendments to Current Scheme • Page 21. Section 14c. This should be amended to cover the requirements when Internet Banking is used. Response: Agreed. Wording from the Best Practice Agreement has been incorporated into this part of the Scheme, 47 Proposed Amendments to the Current Best Practice Agreement 6. Issues About Service Responses 6.1 Where a community council is not satisfied with the action taken or response to an enquiry, the community council may raise the issue with the management of that service in accordance with the council’s published complaints procedure. The Community council should outline its views on the response, which has been made by the council department and shall state the action, which the community council considers, should be taken. Proposed change Page 11, 6.1 – Remove reference to the Complaints process as the complaints process is only accessible to a “member of the public”, as defined by Section 5 of the Scottish Public Services Ombudsman Act 2002. This does not preclude a community council from raising issues with Service Manager where they are not satisfied with the action taken or response to an enquiry, or from acting on behalf of a member of the public or helping a person complain. In this case the person’s written consent for the community council to act on their behalf would be sought. Query – as CCs are not ‘members of the public’ how do we lodge a complaint? Response: The complaints process can only be utilised by individual members of public. Nothing within this precludes a matter from being raised with the manager, it just cannot be formally recorded as a complaint as there is no right to a review via the Ombudsman. This is not a matter which can be addressed as part of this review. It would require a change in legislation. 48 Existing (and Proposed ) Administration Grants The existing grants are not listed. It is very disappointing to see such a large reduction in the grant. In our case £667 80 down to £500 Response: Appendix 5 listed the existing and proposed grants. Officers do not have any additional budget to recommend any change to the grant levels. In addition, there is no proposal to remove the discretionary grant but provision for this is not within the Scheme and out with the scope of the review.
Page 13
Appendix 1 49 1) The proposed amendment Page 10, 9.2 Response 12 weeks is long enough for any competent Community Council to prepare their accounts, audited or otherwise. Therefore, this clause should maintain the status quo. Response: Respectfully, an audit, in some cases, may take a number of months to conduct and this proposal provides a flexibility to address this. Many CCs will likely continue to hold an AGM in June. In all cases, appropriate notice should be given to ensure the community are informed 50 2) The proposed amendment Page 11, 10.4 – Response Efficient Community Councils should be able to complete their Minutes within the current time span. Minutes should always be finalised as soon after the meeting while their notes are still fresh in their minds to ensure accurate recordings. Therefore, this clause should maintain the status quo. Response: The proposal offers less time to submit minutes that other local authority schemes, or indeed the National Model Scheme provides. It recognises the voluntary nature of community councils and that the some community councils can legitimately operate with as few as 4 members, reflecting the issues they could have in terms of production of a draft minute within 14 days. In most situations we would still anticipate receiving draft minutes as early as possible. 51 3) The proposed amendment Page 13, 13.3 Response A capable, effective and efficient CCLO is in situ . Therefore, this clause should maintain the status quo. Response: Complaints which can demonstrate a breach of the governance framework would not be jeopardised by this. This only impacts on complaints which cannot demonstrate a breach of provision and in allowing this, it would misuse the process. 52 4) The proposed amendment Page 14, 13.5 Response No breach Is minor. Therefore, this clause should maintain the status quo. Response: Feedback from those who have served on complaints panels is that where a breach has been found, the necessity to sanction was seen as being too harsh for the nature of the breach. In allowing a decision that the breach is minor (in the view of the decision maker) this would allow the breach to be recognised but dealt with more appropriately for the circumstances.