Object

Representation ID: 18570

Received: 11/10/2021

Respondent: Dudley Labour Group

Agent: Councillor Qadar Zada

[Consultation Process]

Consultation Documents and Consultation process

There have been ongoing issues with the consultation process which have caused confusion and frustration for residents and councillors alike.


Timing and Duration of the consultation process


We have taken issue with the choice of date to announce the start of the consultation and the length of time residents have had to respond. It is
important to make the point that at no time before the consultation was announced have residents been officially informed which sites are at risk. The formal consultation that took place previously only developed policies that would determine choices and did not name specific sites. A number of committees held in public have discussed the plan and there have been various reports which have given an indication of which sites might be at risk but this information could not be relied on until the plan was signed off. Ahead of the consultation there are examples of councillors trying to alert residents near some of those sites that those sites are at risk, only for residents who have then enquired with the Tory
Councillors and/or their MPs that this is scaremongering, and those sites wouldn’t be in the final proposals, only then to find that the sites made it to the final consultation document. The consultation was then launched under the radar, during the summer months, omitting any direct communications with those affected so that many residents were not aware that those sites were at risk until weeks into the consultation period.


The Council has indicated that the standard consultation period of 6 weeks has been extended to 8 weeks, however this still gives insufficient time for residents with limited resources and often without access to IT and social media to get themselves organised and to mount an effective opposition to the plans. Councillors have seen those residents, especially those near to the affected sites, placed under extreme duress trying to organise campaigns during a period of the year where they are still battling with the impact of Coronavirus, are apprehensive about returning to “normal activities” and might still be working whilst also
trying to take holidays as well as having other pressing responsibilities such as childcare.


This unacceptable worry and pressure for residents could have been averted if the council had, in the first place, adopted a transparent process that was fit for purpose and had actively engaged with those residents most affected ahead of the publication of the proposals.
The online consultation and related errors


The existing online and hard copy versions of the consultation were confusing and contained numerous errors. The online response documentation was also difficult to navigate and resulted in many residents abandoning their efforts to make a response. Examples of errors included;



• Conflicting information in documents about which sites are affected
• Difficulty in finding information about sites within the documents that councillors and residents understand would be affected
• Lack of clarity about which sites are ruled in and ruled out


Also, while green belt sites at risk have been highlighted, equally important green spaces at risk have been difficult for residents to identify. The quality of maps has been poor and in many cases it has been difficult to pinpoint the exact locations of some of the sites. Many residents were also deterred from continuing with their response when required to provide an electronic signature. Some residents expressed this at the public meeting that was organised, and despite hearing this the Council has decided to continue – with no change at all.

Early in the process, including the day of the publication of the consultation, councillors received many enquiries relating to these errors. Consequently, a request was made to the Leader via the Chief Executive that the process should be paused then restarted when all were confident that the consultation was fit for purpose. The Labour group also proposed an extension to the consultation period of 4 weeks
to allow sufficient numbers of residents to respond and to be informed of any new information that might arise through the scrutiny process which
did not begin until September. The decision to extend the consultation needed the approval of the Conservative Cabinet and we are disappointed but not surprised that this request was rejected.


Finally, in regard to the online consultation we heard from CAPA at the scrutiny committee last Wednesday that just 10,000 unique visits were made from across the four Black Country boroughs to the online consultation. Considering this was their primary tool for collecting comments, it is another demonstration of how ineffective the Council has been in engaging residents.

In person consultation


Until the first scrutiny meeting took place which highlighted issues with the consultation process, there had been no in person consultation conducted with affected residents. Consequently, almost halfway into the consultation period, ‘drop in’ sessions were hurriedly arranged by Dudley Council, most taking place during office hours when the public were not available and therefore not surprisingly, attracting just 99 visits in total. Public meetings were better attended, but most of these were organised by residents and campaigners themselves, with differing degrees of formality, structure and support.

Other communications


Following the first scrutiny committee, one of the measures proposed was to alert members of the public to the fact that the BCP proposals had been published and to encourage them to respond. Just 2 weeks before the closing date for the consultation, an A5 leaflet was posted to households, many wrapped in other unrelated commercial materials delivered at the same time. An opportunity had also been lost through the way in which the issue featured in the August edition of My Home magazine. CAPA explained that the magazine had to go to print before the consultation was launched which is why it didn’t contain much detail about the BCP. However, this does not explain why the article did not feature more prominently in the magazine, which on page 14, half way through, risked most readers not reading it.