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Clinical Commissioning Group (CCG) Governing Body

Date of Meeting: 21 September 2012

Agenda Item: Di 17

Subject: Performance Report

Reporting Officer: Sandra Croasdale (Head of Performance)

Purpose of the Paper:

The purpose of this report is to update NHSHMR CCG Governing Body on NHSHMRs performance the Operating Framework requirements for 2012/2013. Performance against the 2012/2013 Business Plan is also included in the report.

Governance:

Link to PCT Strategic Objectives

Performance reporting, and more importantly monitoring, is key to enabling the organisation to achieve its objective to becoming a high performing organisation and ensures delivery of the Strategic Objectives.

Resolution:

To approve To support

Recommendation To review performance against the Operating Framework targets and support ongoing workstreams to drive improvements in this performance. To note the organisations performance against the business plan

Key implications for the following:

Financial

Key Financial Implications:

Has this paper been approved by the Finance Department?

Yes / No / N/A N/A

If YES: Name and Job Title of member of the Finance Department

If NO what process has been agreed for financial sign off?

Value for Money

N/A

Risk Potential risks of not achieving specific targets are detailed in the report

Legal N/A

Workforce N/A

Equality Impact Assessment:

Included in Paper

yes no n/a

Comments

Patient & Public Involvement

Clinical Engagement

Parties/ Committees consulted

Business Intelligence Indicator and Action Plan owners

Performance Report

September 2012

Version 1.0

Author Sandra Croasdale, Head of Performance

Contents

1. Executive Summary ........................................................................................................ 1

2. Performance against Integrated Performance Measures ..................................................... 1

3. Performance against 2012/13 Business Plan ..................................................................... 7

4. Recommendations .......................................................................................................... 7

Appendix 1 ........................................................................................................................ 8

Appendix 2 ...................................................................................................................... 13

Appendix 3 ...................................................................................................................... 16

Appendix 4 ...................................................................................................................... 17

Appendix 5 ...................................................................................................................... 21

Performance Report September 2012

1

1. Executive Summary

1.1 The purpose of this report is to update the CCG Board on NHSHMRs performance

against national and corporate priorities. It covers performance until end July

2012, unless otherwise specified within the body of the report. The date shown for

each indicator in Appendix 1 is the date of the latest available data.

1.2 An “at a glance” Executive Summary shows performance against all Operating

Framework targets on one page. Where indictors are underperforming, and

exception report is provided in Appendix 1.

1.3 Performance to date against the 2012/13 Business Plan is also included in this

report, along with an Equality Impact Assessment of the Plan shown in Appendix

5.

2. Performance against Integrated Performance Measures

2.1 The following are presented:

Figure 1: Executive Summary of performance against Operating Framework

2012/13

Appendix 1: Operating Framework targets by exception (12 month trend)

Appendix 2: NHS North of England scorecard

Appendix 3: RTT report

2.2 The Executive Summary against all Operating Framework targets is shown in

Figure 1 (see page 2). Key changes since last reported in July are improvements

in cancer performance which is now Green and Health Check performance

reducing to Amber. It should be noted that the Q1 2012/13 Health Checks

achieved 4.96% against a target of 5%. This equates to 23 health checks being

offered behind trajectory. NHS North of England (NoE) are reporting this

performance as Green in the NHS NoE Scorecard given in Appendix 2.

2.3 The NoE Scorecard (Appendix 2) shows significant improvement in NHS HMRs

performance. NHS HMR is rated as Green for all key performance areas, one of

only six NoE CCGs in this position.

2

Figure 1


3

Key performance areas:

2.4 Referral to Treatment Times

The Operating Framework for 2012/13 requires that RTT targets are monitored

and met at specialty level from April 2012. PAHT have continued to make

significant improvements in performance against this target.

Appendix 3 provides a summary of the performance as at July 2012 at both

aggregate and specialty level. Target is achieved at aggregate level (92.9%

against a target of 90%) and only two specialties are now failing – T&O (88.7%)

and General Surgery (89.7%). Agreement has been reached that delivery at

specialty level will be in place by 1 October 2012. There are robust systems in

place around each specialty. Early indications suggest RTT by specialty may be

achieved ahead of this date; however sustainability continues to be an issue and

RTT will continue to be closely monitored.

NHS HMR now has 70 patients in the backlog at PAHT, 2 of which have waited

longer than 52 weeks. This situation continues to improve and is being closely

monitored.

This target continues to carry significant risk and therefore is reviewed at the

weekly Executive Performance meeting. In addition a joint operational meeting is

held bi-weekly between PAHT and NES CCGs.

2.5 Cancer Targets

Quarter 1 2012/13 and June 2012 performance data is now available which shows that NHS HMR achieved the core 62 day target from GP/GDP referral and is displayed below.


4

Network wide provider performance is displayed below for 2012/13 Quarter One. This indicates an improving picture of performance at PAHT.

To ensure that this level of performance continues the NHS GM Clinical Strategy

Board and GMCCN have identified funding to support a proposal by the Greater

Manchester and Cheshire Directors of Operations group to oversee the

implementation of optimal care pathways in tumour specific areas; Urology, Lung,

Colorectal, Upper GI and Head and Neck.

Work continues locally across the NE Sector to improve and sustain performance

against these cancer standards including:

The development of a breach indicator tool which is utilised at the weekly

performance meeting where solutions and resolutions are explored at an

individual patient level

Weekly joint meetings with Sector commissioners and PAHT

Embedding of redesigned pathways including audit/breach analysis process

Design of a best practice „Cancer Waiting Times‟ upload process to facilitate

the early estimation of cancer performance across the Network

Feasibility study to assess whether network wide electronic tracking is

possible

2.6 A&E

PAHT as of 04.09.2012 are achieving the 4 hour wait target (96.5%) and are

continuing to achieve the high levels of performance set earlier in the year.

Performance during 2012/13 has been good, consistently achieving in excess of

96% each week (year to date result 96.42%). Winter resilience meetings are now

underway to ensure this high standard is maintained.


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2.7 CAT A 8 and 19 Minute Ambulance

NWAS has achieved both the 8 and 19 minute performance target for July 2012.

8 min (July 2012) 19 min (July 2012)

HMR 78.70% 94.62%

GM 77.24% 94.87%

Northwest 77.94% 95.11%

At local level NHS HMR achieved the 8 minute target but under performed against

the 19 minute target. It is worth noting however that 94.62% is a significant

improvement against May‟s performance of 92.45%.

A GM Urgent Care transport group has been formed and had an initial meeting to

begin to have overview of both the local and GM Ambulance performance has

taken place with performance being a standing item on the agenda. These

meetings currently take place monthly and are led by NHS GM.

High turnaround times continue to have an adverse effect on NWAS‟ ability to

deliver the performance standard and are coming under increased scrutiny by

NHS North of England. Turnaround times are influenced by both NWAS and acute

providers, therefore reciprocal penalties on handover and turnaround were agreed

and supported by the SHA. The penalty clause is now included in both the NWAS

and acute contracts. There will be a phased approach to implementing the penalty

in 2012/13 to take account of Hospital Arrival Screens (HAS) being installed and

reporting systems being developed. Detailed reports on handover will be provided

to commissioners and acute trusts in Q1 and Q2 2012/13 with full implementation

of the penalty commencing in Q3.

NHS HMR met with NWAS and PAHT to discuss HAS screen compliance and

turnaround times and is assured at this point that the 2 trusts are working closely

to improve both compliance and turnaround time. PAHT are currently on track for

delivering 50% compliance by the end of Q2 and 95% compliance by end of

2012/13. NHS HMR will continue to attend the meetings and support the providers

where possible.

2.8 Clostridium Difficile

Current performance against trajectory places NHS HMR 2 cases under the year-

to-date plan.

There have been 8 cases of CDI in July; the eighth case has not yet been entered

correctly onto the national HCAI data collection system and therefore this has not

been incorporated into the table below. This means that the real position for NHS

HMR is 1 case under the year-to-date plan as of the end of July.

To date, only 1 case has been reported for the month of August. This data is

provisional.


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A detailed recovery plan is in place which is monitored fortnightly. Key Issues and actions are shown below:

Restricted access and delays of information from PAHT to the PCT

Infection Prevention Team due to restrictions applied at PAHT from the

Governance/Data Protection Department. This issue has been worked

through at NE Sector level and is nearing conclusion.

Restricted access and delays in obtaining information from GP Practices

particularly due to a Data Protection issue which is now near resolution. The

PCT has sent a letter out to all HMR GP Practices outlining the legal

justification for sharing patient identifiable information with relevant PCT

staff.

Recruitment is underway to increase capacity to deliver the Recovery Plan

Monies have been approved to commence a publicity and education

campaign regarding CDI and antibiotic use

Medicines Management Team are monitoring a Prescribing Incentive

Scheme for GPs

There have been 38 GDH positive toxin negative cases reported since this

began in April. Investigation of risk factors is undertaken in the same way as

for toxin positive cases. For these patients it may be possible to reduce

morbidity and mortality by proactive management.

NHS Heywood, Middleton & Rochdale - Clostridium Difficile

2011/12 Apr-11 May-11 Jun-11 Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 YTD Total

GP 3 2 6 3 3 4 1 1 2 4 1 3 33

<48 Hrs 4 1 2 2 4 1 4 4 3 4 6 4 39

>48 Hrs 1 3 4 4 1 2 4 4 3 2 1 1 30

Total 8 6 12 9 8 7 9 9 8 10 8 8 102

Plan 8 8 7 7 7 7 6 6 6 6 6 6 80

2012/13 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 Jan-13 Feb-13 Mar-13 YTD Total

GP 3 3 0 3 9

<48 Hrs 1 1 2 3 7

>48 Hrs 5 3 2 1 11

Total 9 7 4 7 #N/A #N/A #N/A #N/A #N/A #N/A #N/A #N/A 27

Plan 8 8 7 6 6 6 6 6 6 5 5 5 74

YTD 12.50% 0.00% -13.04% -6.90%

0

2

4

6

8

10

12

14

Apr-11 Jun-11 Aug-11 Oct-11 Dec-11 Feb-12

2011/12 HMR Clostridium Difficile Infections

2011/12 Plan

-

2

4

6

8

10

12

14

Apr-12 Jun-12 Aug-12 Oct-12 Dec-12 Feb-13

2012/13 HMR Clostridium Difficile Infections

2012/13 Plan


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2.9 Summary Care Records

The current trajectory for delivery of SCR is given below and is based on

achievement of 5 uploads per month.

HMR are currently behind this trajectory. Work is ongoing to try and recover this

position. There are a number of issues that are ongoing:

Specific clinical system issues at three practices. These are being

progressed with individual practices/clinical system providers.

Compliance of EMIS Web is now delayed until October 2012. This affects

8 practices which are ready to upload once the system is compliant.

EMIS PCS practices migrating to compliant EMIS Web is dependent on

EMIS for migration dates.

It is expected that these issues can be addressed and with the exception of one

practice, which cannot go live until end of January 2013 due to patient consultation

timescales, all practices will be complete by end of December 2012.

3. Performance against 2012/13 Business Plan

3.1 Performance against the Business Plan is reported by exception in Appendix 4.

The commentary provided is written by the individual objective owners and details

reasons for milestones not being achieved.

3.2 Whilst there are a number of milestones that have been missed there are no key

issues.

3.3 An Equality Impact Assessment for the Business Plan is included in Appendix 4.

4. Recommendations

4.1 To review current improved performance against Operating Framework measures

and to support ongoing workstreams to drive further improvements going forward.

4.3 To note the delivery against the 2012/13 Business Plan.

0

5

10

15

20

25

30

35

40

45

Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12

Cumulative total SCR trajectory Total booked Total created

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Appendix 1

13

Appendix 2

16

Appendix 3

17

Appendix 4

21

Appendix 5

Equality Impact Assessment Template & Human

Rights Screening

March 2011

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Equality Impact Assessment Form Section A:

General Details (Please refer to your guidance notes)

1.

EIA Author’s Name

Samina Arfan

Sponsoring Director’s Name

Karen Hurley

2.

Directorate/ Commissioning/ Team

Performance , Directorate of Operations and Engagement

3.

What is being screened?

Strategic Objective Business Plan 2012-13

4.

Aim, Purpose and Outcomes of what is being screened

(please include intended and differential outcomes) The operational framework 2012/13 clearly states that the NHS must continue to meet both the general and public duties under the Equality Act 2010 and to utilize the NHS Equality Delivery System (EDS) as a ready-made approach to deliver outcome based compliance in the Health Sector. The Public Sector Equality Duty requires that CCGs take account of the needs of disadvantaged individuals, both as employers and in the development, commissioning and delivery of public services. The CCG are committed to embedding ED in its core business including the business plan. This approach will add value for money when staff delivering the Business Plan ensures the health outcomes for all the population are considered in commissioning processes and will promote patient access and safety, drives quality standards and contributes to reducing health inequalities. The aim of the Business plan 2012-13 is to translate the organisations Plan on a Page and Strategic Objectives into directorate and team objectives, with clear lines of accountability, to ensure organisational delivery.

5.

Implementation Date

6.

Stakeholders Who does it affect?

Patients Yes No Indirectly

Carers/family Yes No Indirectly

Public Yes No Indirectly

Staff Yes No Indirectly

Partner organisations

Yes No Indirectly

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7.

Consultation Process

Consultation on the business plan has taken place with the following: CCG Governing Body Executive Management Team Locality Leadership Team Clinical Leads Staff Patient Experience Assurance Sub Committee Voices 4 Wellbeing (LINks) Rochdale and District Disability Action Group (RADDAG) Rochdale Metropolitan Borough Council Public Health Mental Health and Wellbeing Commissioning Core Group PALS/Complaints Manager Head of Patient Experience and Engagement, Claims and Legal Services Patient and public engagement/involvement is integrated into the commissioning process and is therefore fundamental to the Business Plan ensuring the core business of the CCG reflects the healthcare needs of local communities.

8.

Communication and Awareness

There has been wide internal communication amongst staff of its Organisational Objectives and business plan 2012-13 development. In addition there has been wide internal and external engagement with protected groups with the development of the NHS HMRs/CCGs Equality Objectives 2012-16 as required by the public sector duty and EDS. This includes :

BME Health & Social Care event

Equalities Big Listen

Involving & Engaging Communities

RADDAG Event

BME Dementia „Have your Say‟

EDS Grading Event with Voluntary Stakeholders

BME Health and Well being Forum The Equality Objectives 2012-16 are:

1. Improved data monitoring, collection & usage 2. Joined up approach to complex care 3. Information and engagement 4. Engaged and fully equipped staff

These equality objectives where ratified by the CCG Board May 18th 2012 and it was agreed that an action plan would be developed to support the delivery of the equality objectives 2012-13. From a performance perspective this EIA will support aligning the Equality Objectives with the business plan 2012-13 and identify Strategic Objectives/ Milestones that require an Equality Input, thus providing assurance to the CCG Board that ED is at embedded at the core of its business. In addition plans related to EDS goals and outcomes can be easily access at a corporate level.

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Section B

Initial Screen (Please refer to your

guidance notes)

Protected Characteristics

Positive Impact

Negative Impact

Rationale and explanation

for decisions made

Place an ‘X’ against the appropriate box below

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Age:

Children/Young People/ Older People

Yes x Yes The Borough has an older and younger age profile with more people in between 40-64 and 10-29 years old. The diversity of over 65‟s population will increase. With the non-white population expected to be 2.5 times larger than 2001. 57% of the older residents are living with long term illness. The Business Plan 2012/13 is an opportunity to have a positive impact on age and to ensure any potential issues around age discrimination are minimised through effective EIAs in the areas identified.

No No x

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10

Disability:

physical, mental health & learning disabilities

Yes x Yes The instances of disabilities rise significantly with age. As life expectancy increases, so too are the numbers of people with Complex care needs. 2001 census and 2001 white paper „valuing people‟ estimates show there are around 6000 people with learning disabilities in the Borough of which 870 are severe and profound. It is predicted this will increase by 9% by 2021. Locally rates of morbidity and mortality in relation to LTC are high. Overall we know that levels of death and disability in the 3% most deprived areas are significantly worse than in the other 97%. The most common LTC diagnosed by GPS in the Borough as of March 2011 are: Hypertension; diabetes; asthma; CKD & CHD. Engagement with the voluntary sector during the development of the Equality Objectives 2012-16 indicated that there is much concern around the impact of changes to services for those who are disabled and their carers. For example reducing death rate for CHD will need to include people with LDS of severe mental illness who are less likely to be on chronic disease registers as demonstrated by the closing the gap report by the Disability Rights Commission. Also the feedback of EPIT 2 from the SHA and Voluntary stakeholders included to improve disability monitoring of service uptake, and communication of mainstream services to disabled people. The Business Plan 2012/13 is an opportunity to have a positive impact on Disability and to ensure any potential issues around disability discrimination are minimised through effective EIAs.and engagement with disabled people.

No No x

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11

Gender Reassignment:

The process of transition from one gender to another

Yes x Yes There is no local data around gender reassignment however it is estimated 1 in 4000 in the UK population seek to support to change gender. The Business Plan 2012/13 is an opportunity to have a positive impact on Gender Reassignment and to any potential issues around discrimination are minimised through effective EIAs in the identified areas.

No No x

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Marriage & Civil Partnerships

Yes x Yes N/A this applies only to workforce.

No No x

13

Pregnancy & Maternity

Yes x Yes Although this characteristic is focused on the workforce, with the recent reconfiguration of maternity services, The Business Plan 2012/13 is an opportunity to have a positive impact on residents who use these services and to ensure any potential issues around discrimination are minimised through effective EIAs in the identified areas.

No No x

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Race and Ethnicity: including: Gypsies, Travellers, Refugees and Asylum Seekers,

Migrant Workers, Other racial/ethnic/cultural /nationality

group

Yes Yes The Borough has a rich diverse BME population of around 14.22%, which have a much younger profile. In addition the borough has a number of emerging communities mainly coming from Eastern Europe; small number from the African continent. This presents potential complex unmet need that can impact on local health take economy. The country of origins may present challenges to the Borough will potential high levels of HIV Incidence, lower levels of health literacy, unmet mental health needs for those moving due to war and conflict and different routes of accessing healthcare. Evidence suggests that there are patterns of inequalities among BME communities health conditions include south Asians at greater risk of CHD; Afro Caribbean‟s have less risk of CHD but greater risk of hypertension and stroke; Bangladeshis have highest rates of IHD. Differences by ethnicity are controversial in mental health with higher rates of admission for Black African/Caribbean/other groups and

No No

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more likely to enter psychiatric care through the criminal justice system. The Government review „No patient left behind‟ 2008, showed a widespread dissatisfaction with Access to GP services and made recommendations for improvements. BME engagement during the equality objective development indicated that ethnicity monitoring needs to improve to be able to demonstrate that BME communities are equitably access services and that future needs can be met. In addition better communication about how they can improve their health. The Business Plan 2012/13 is an opportunity to have a positive impact on Race and to ensure any potential issues around Race discrimination are minimised through effective EIAs in the identified areas.

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Religion and Belief - Faith Groups

Yes x Yes Most people in the Borough follow a religion, around 75% are Christian, around 10% are Muslim and around 7% state they have no religion. The Muslim population reports poor health in line with the national picture. The Business Plan 2012/13 is an opportunity to have a positive impact on Religion and belief and to ensure any potential issues around religious/belief discrimination are minimised through effective EIAs.

No No x

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Sex:

Man/Woman

Yes x Yes The Borough has estimated 50.6% female and 49.4 % male population. On average men and women in the Borough live shorter lives that in the NW. The JSNA shows that the biggest killers for men are CHD, respiratory disease and digestive disease including cirrhosis; for women it is CHD, digestive disease including cirrhosis and lung cancer, it is understood that better treatment, earlier detection and risk management, prevention will positively impact on these outcomes. Such intervention will need to also consider barriers because of cross cutting issues such as age, race, and disability. The Business Plan 2012/13 is an opportunity to have a positive impact on gender and to ensure any

No No x

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potential issues around gender discrimination and cross cutting issues are minimised through effective EIAs.

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Sexual Orientation Lesbian/Gay

/Bisexual /Heterosexual

Yes x Yes Based on government estimates round 14-20,000 people are lesbian, gay or bisexual in the Rochdale Borough. There were 29 civil partnerships in the Borough between April 2010- 31st March 2012. National data demonstrate higher incidence of substance misuse especially related to alcohol among LGBT groups. Locally the LGBT health and well being forum are concerned with improving the experience of local LGBT residents in mainstream health services and there is national pushes for better monitoring of service take up by LGBT. The Business Plan 2012/13 is an opportunity to have a positive impact on LGBT and to ensure any potential issues around LGBT discrimination and cross cutting issues are minimised through effective EIAs

No No x

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Vulnerable Groups

(including homeless people)

Yes x Yes Homelessness does exist in the Borough. The Business Plan 2012/13 is an opportunity to have a positive impact on homelessness and issues are minimised through effective EIAs

No Yes x

Carers

Yes x Yes The Borough has a number of identified carers and hidden carers. National evidence suggests that the impact on carer‟s health when caring for other can be significant. NHSHMR/CCG has a joint strategy with RMBC to support identifying the health needs of carers and LES‟s. The Business Plan 2012/13 is an opportunity to have a positive impact on carers and issues are minimised through effective EIAs

No Yes x

19 Human Rights – Refer to the Human Rights Flow chart and the

Human Rights Screening tool before you answer this section

Yes x Yes Some areas of health care will impact on Human Rights The Business Plan 2012/13 is an opportunity to have a positive impact on human rights and issues are minimised through effective EIAs

No No x

Following completion of Section B have any negative impacts been identified and transferred to an Action Plan?

Yes Negative impacts will be identified with further EIAs being undertaken within in the relevant strategic objective plans and milestones. No x

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Date Completed: 28th June 2012 Signature of person completing EIA and Human Rights Screen: Sandra Croasdale

Please send a copy of all completed Sections A & B and any supporting evidence and/or policy to the ED Program Manager for scrutiny and audit purposes

Date received by ED: 28 June 2012

Signature of Senior manager or Commission lead or Executive Director: Karen Hurley

EIA Action Plan

Insert question numbers highlighted Red/ Amber below

State what actions are required to reduce any negative/ adverse impacts on Protected

Characteristics: By whom By when

Please state any

implications on resources

1 The work areas within the Business plan 2012-13 have been highlighted where further EIAs or equality considerations are required. These areas need to be incorporated as part of the performance reporting systems within the organisations

CCG to agree

July Board meeting

2 Identified staff responsible to deliver the business plan milestones, where an EIA /equality consideration has been highlighted, are required ensure they report through performance manager the progress of the EIA, and to seek support from the Equality lead if required.

Identified action Plan leads

Dates identified within the business plan

Upon undertaking an EIA it may be identified that support measures may need to be included to ensure potential challenge is avoided and that due regard is given to protected groups. For example communication plan for a service redesign and or decommission

3 EIAs are not a tick box exercise but a tool to improve health outcomes, quality, access and experience of users from protected groups, EIA action plans need to be adequately completed and forwarded to the equality lead for quality assurance and or for further support.



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4 Some EIAs which may have an adverse impact on some protected groups for example disabled people the CCG/PH will need to ensure that due regard has been given to the protected groups by involving them. Local engagement arrangements will be required to support this. Further advice should be sought from the equality lead/ head of engagement to develop a model to support the CCG/PH.



The local arrangements may have financial implications, CCG‟s/PH will need to be assured that the views of protected groups can be accessed easily in such cases. A patient rep on a committee/group may not suffice due regard if that rep is not able to reflect the views of protected groups as described in the Equality Act 2010

5 All identified EIAs and equality considerations to be included within the Equality Objectives 2012-16 action plan 2012-13

S Arfan Upon ratification of the business plan

no

Insert extra rows as required

Themes/Organisational Priority Activities

Are there any themes here that need to be reported back as corporate issues? (Please state) Please state date reported back Please state to whom these themes have been reported to …………………………………..

Good Practice

Are there any examples of good practice that should be shared widely? (Please state)

Integration of EIAs into core commissioning

Monitoring & Review

DD/MM/YYYY

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(a) How will the implementation (proposed) and delivery (existing) of the service be monitored? Through performance indicators and patient experience evaluation/provider service evaluation

The implementation will be monitored by performance manager system and the mitigation action plans of the EIAs will be monitored by the Equality Assurance Committee. Identified leads will monitor the impact of any mitigation

plans they put in place.

Final Sign of by Commissioning Lead or Ex Director Karen Hurley

Date Equality Impact Assessment started: March 2012

Date completed: 28 June 2012

Summary of outcome of Impact Assessment Adverse effect not found [ x ] Please ‘X’ adverse impact can only be mitigated with further EIAs undertaken as identified within the Business Plan Adverse effect found [ ] Please indicate with a ‘X’ Are the proposed changes adequate to mitigate any adverse effects?

Date due for review: April 2013

Type of review: Full EIA/Action Plan only Action plan review

Person responsible for arranging review: Samina Arfan

Date: 28 June 2012

Initials: SC

Yes

Yes

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