Consultation on the plan, which was introduced in July this year, ended last week. The organisation has branded the plan a missed opportunity that "does little to address the high use of custody for children and young people."
The plan also fails to tackle problems for young people leaving custody and lacks details about issues such as resettlement and how services can better support ex-offenders, the association claims.
The association says a green paper on youth offending services would give issues such as resettlement greater priority. It is calling for a further policy document from government offering firm proposals for improving services for young offenders.
Despite its concerns the association welcomes the plan's focus on child welfare and cross government action to address youth crime.
The plan includes £56m of funding over the next three years to spend on council run schemes such as detached youth workers, after school police patrols and activities for young people in the evening.
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