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14/01/2011
SNAG calls for Consultation action


The formal consultation process is as little as 4 weeks away and we are all outraged that we are being kept in the dark about the process and content of consultation. There is a Government Code of Conduct that should be observed http://www.bis.gov.uk/policies/better-regulation/consultation-guidance but you can draw your own conclusions about that. The opening words are:

“On-going dialogue between Government and stakeholders is an important part of policy-making. This dialogue will, at times, need to become more formal and more public. When developing a new policy or considering a change to existing policies, processes or practices, it will often be desirable to carry out a formal, time-bound, public, written consultation exercise. This kind of exercise should be open to anyone to respond but should be designed to seek views from those who would be affected by, or those who have a particular interest in, the new policy or change in policy. Formal consultation exercises can expose to scrutiny the Government’s preliminary policy analysis and the policy or implementation options under consideration.”

There are 7 criteria for consultation laid down in the code and some of these are clearly not happening:

Criterion 1  Formal consultation should take place at a stage when there is scope to influence the policy outcome. Some of the recent statements by government members including Mr Cameron have said HS2 WILL GO AHEAD. They are clearly giving NO SCOPE for influence. This could be viewed as an abuse of the process.

Criterion 2  The process should normally last for at least 12 weeks.  Don’t console yourself with the view that it might last at least 6 months and this will give plenty of time for things to happen. It won’t, it will be a short, and highly focussed. The supporting road show will probably continue to denigrate the action groups in the process.

Criterion 3  Consultation documents should be clear on process, the proposal, the influence, costs and benefits. The process is opaque, the proposal keeps changing (eg. the freight issue) and the likely influence on the outcome appears to be close to zero. Again you might think that this also an abuse.

Criterion 4 Should be targeted at and accessible by the intended audience. An issue of this magnitude should by now have resulted in a clear and widely distributed prospectus for all stakeholders but this has not happened. Interestingly however, there have been secret briefings for certain local authorities on the process, make of that what you will.

The remaining 3 criteria are in a similar vein on Burden, Responsiveness and Capacity and the conclusions are just as unsatisfactory.

Overall the process to date has been dismissive and obfuscatory  (hiding the truth). The signs are that the politicians simply want to use the exercise to campaign among their sympathetic stakeholders.

 

So what do we do?

Get prepared.  However angry you might feel about the government’s tactics so far, you have 4 weeks before the process is scheduled to start.

  • 1.       Make sure that all groups and individuals in your areas are registered as stakeholders via HS2 Ltd. They cannot refuse you if you might be affected, and the whole country is affected!
  • 2.       Work with the national campaign bodies to gather and deliver high quality rebuttals to the HS2 principle as well as Route3.

Shout about the grubby treatment so far

  • 1.      Demand your MP challenges Mr Hammond on his adherence to the Consultation Code of Practice
  • 2.      Above all remind Mr Hammond that it should be constructive engagement. It is not his money, his network, his environment to play with as he wishes.
  • 3.      You might also want to remind him that, however he gets the public to pay for this white elephant, the pain of public spending cuts will not allow us to forget this matter; we will remember at the elections this year and in the future. He chose to be insulting with his NIMBY remarks, remind him of the consequences.

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