Appendix 1: Draft East Suffolk (Local Government Changes) Order 2018; Draft West Suffolk (Local Government Changes) Order 2018, and related instruments
Additional information from the Ministry of Housing, Communities and Local Government
East Suffolk SIs
Q1: As regards the East Suffolk SIs, the Explanatory Memorandum says: “8.1 Following the decisions of the councils to proceed in principle with the proposals to merge, the councils undertook a programme of engagement with residents and stakeholders. The engagement programme was comprised of the following activities: an independent, weighted to be representative phone poll; open public consultation, with comments invited via a dedicated email address or by post; press releases and articles in the local press; outreach events with community groups; banners promoting the merger at council offices and libraries, and on-going website and social media promotion … 8.4 Of the consultation responses from the public, 114 were against and 17 were in favour. Of the 114 residents who objected, a recurring concern was that a single council covering a larger geographic area would weaken local democracy. There were also concerns around certain areas being under represented. Following the consultation, a ‘myth-busting’ document was published on the councils’ shared website to address the principal concerns raised during the consultation process.”
Have the councils published a summary of consultation responses? If not, why not?
A1: The councils have published the results of the consultation, which can be found via the following link:
http://www.eastsuffolk.gov.uk/assets/Your-Council/Consultation-Responses-merger-proposal.pdf.
This information was submitted to the Secretary of State prior to taking his decision to proceed with the merger.
Q2: Have the councils offered any evidence that the “‘myth-busting’ document” was widely read by local residents, in particular by any of the 114 members of the public who were against the proposals?
A2: The myth-busting document was provided to all respondents to the original consultation who provided details for further contact to be made. Therefore, though it may not have been provided to all individuals who objected, it would have been made directly available to those that expressed an interest in further information. It was also freely available on the East Suffolk website. In short, the councils made every effort to ensure the information was available. It may be the case that one of the impacts of the myth-busting document was to result in few people feeling the need to make representations during the period for representations, see below.
Q3: The EM also says: “8.7 After the Secretary of State announced his initial decision that he was minded to implement the proposal, there was a period for representations lasting from 7 November 2017 until 8 January 2018. 20 representations were received. Of these 17 were supportive of the proposal, one was neutral and two were opposed.” The EM makes it clear that only 2 of these 17 responses were from members of the public. Have the councils offered an explanation for why so few members of the public responded at this second stage?
A3: These representations did not form part of the council-run consultation but were submitted as a result of the opportunity provided by the Secretary of State to any interested party to send to him directly any representation regarding his initial minded-to decision to proceed with the merger. The Council did make clear locally that there was a period of representations by informing local stakeholders, parish councils and other interested parties directly. As mentioned above, it may be that the intensive distribution of the myth-busting document reduced the need to make representations at that point.
Q4: Have the councils any evidence that this “silence” meant “assent” by local residents, or is there any evidence of ongoing local concern at the proposals?
A4: There is no evidence of ongoing local concern regarding the proposal and it is apparent through the representations made that the majority of stakeholders are supportive. The Department has not received any further communications from members of the public suggesting that concern is ongoing. Moreover, perhaps the best indication of local views are the views of those who have been democratically elected to represent the area. Both Councils are strongly supportive of the merger.
West Suffolk SIs
Q5: In section 8 of the Explanatory Memorandum there is no reference to “open public consultation” (which is stated in the Explanatory Memorandum to the East Suffolk SIs): was no such open consultation held and if not, why not?
A5: The consultations undertaken by West Suffolk councils are described in paragraph 8.1 of the Explanatory Memorandum. These consisted of a survey phone poll; a media campaign; publicity packs; a dedicated webpage and online survey; formal communications to key stakeholders; presentations and talks; and staff briefings. The councils received 88 responses through the dedicated webpage and online survey, and all contributors who supplied an email address received a full response from West Suffolk. The outcomes of the public engagement process were reported by the councils (section H of the business case and the contributions and the responses are included in full in Appendices D through to H) and published in full on the dedicated webpage: https://democracy.westsuffolk.gov.uk/documents/s22109/COU.FH.17.026%20Appendix%202%20-%20Final%20business%20case.pdf
Opportunities to provide input were also provided for those unable or unwilling to contribute online feedback. These methods are outlined in paragraph 8.7 of the Explanatory Memorandum.
This is the equivalent of the public consultation referred to in the East Suffolk EM.
Q6: The EM also says: “The majority of town and parish councils that sent representations in response to the proposals were supportive. Seven responses were received from the eighty-five town and parish councils - four were supportive and three raised concerns. The primary concerns were for local decision making and service delivery. However, the West Suffolk councils do not expect there to be any negative effects on local decision making or service delivery as a result of any implementation of their proposals.” In other words, almost as many parish councils had concerns (three) as were supportive (four). What evidence have the West Suffolk councils offered of no “negative effects”?
A6: The councils’ aims for the single council arrangement include an ambition to “[make] sure things are done at the right level (subsidiarity), including a greater role for town and parish councils in truly local matters”. All parish councils were provided with an information and publicity pack, discussions were held at town and parish forums and town and parish councils were contacted individually and encouraged to comment.
As stated in paragraph 8.3 of the Explanatory Memorandum three parish councils raised concerns mainly around local decision-making and service delivery.
The councils are confident that the proposal would improve local services. The two councils already operate on a fully shared service arrangement which has so far saved £4 million and seen savings invested back into high quality services. Becoming a single council is estimated to generate a further £0.5 million of annual cashable savings, help develop ways of working focusing on prevention rather than crisis interventions, and release some capacity by introducing a more simple and effective way of working.
Another concern raised was around local decision-making and fewer councillors. A full review of ward arrangements is expected to be carried out by the Local Government Boundary Commission of England which will ensure that councillors can effectively represent their ward areas. The councils’ view is that a “new single council with a unified democratic leadership gives members the opportunity to drive real improvements for their localities while attracting investment and championing them nationally.”
Other concerns raised focused on potential staffing reductions. As the councils already have shared service delivery and a single Chief Executive they do not anticipate staff changes directly related to the single council proposal.
Q7: The EM also says: “8.7 The councils took steps to ensure that all residents, including those who were less likely or not able to engage via the dedicated website, were able to share their views on the proposals.” What was the outcome of all these “steps”? Have the councils published a document setting out the results of this “engagement”, in terms of views expressed and the councils’ response? If not, why not?
A7: The ComRes polling referred to in paragraph 8.6 of the Explanatory Memorandum found that 50% of residents were aware of the proposals when they were contacted. In the view of the councils, these findings show that the forms of engagement that they had undertaken were highly effective, especially as awareness levels are usually lower for local government structure related proposals and that the ComRes work was carried out early on in the engagement period.
The councils also believe that as the engagement was about explaining the proposal, the fact that some people did not reply is an indication that they had enough information or did not wish to add anything further. Reminder letters and e-mails were sent reinforcing the deadlines and the offer of further information if needed.
The full results of the public engagement which took place between May 2017 and August 2017 were included in the proposal submitted to the Secretary of State. This information has been published on line in Appendix D: Stakeholder engagement of the final business case here:
https://www.westsuffolk.gov.uk/Council/single_council/index.cfm
The full report on engagement, including the views and the councils’ responses, was also published as part of the Council agenda pack for the St Edmundsbury Council meeting on Tuesday 26 September 2017 and the Forest Health District Council meeting on Wednesday 27 September 2017 and this informed Councillors discussions at those meetings.
In addition, the councils replied directly to stakeholder organisations and members of the public (these replies are set out in Appendices D-H of the final business case referenced above), and a list of answers to address common queries and concerns was consolidated and published online here: https://www.westsuffolk.gov.uk/Council/single_council/singlecouncilquestions.cfm
5 April 2018