121.As described in Chapter 2, several EU Member States have consulted widely on the proposed abolition of seasonal changes of time, and the results have informed the positions of these Member States at Council. We asked whether the Government should also consult on the proposal’s implications for the UK—including in circumstances where the UK was under no obligation to implement the proposal after it had been adopted—and, if so, when consultation would be appropriate and how it should be designed.
122.We heard conflicting views. While Mr Edelsten and Susan Hedley were unequivocally in favour of consultation, the Scottish Government saw no “obvious or compelling” rationale for a public consultation, given the “ongoing uncertainties” around the proposal’s implications for the UK. RoSPA questioned the appropriateness of consultation on this matter, noting that the Government’s decision “should be led by evidence rather than public opinion”. Mr Lloyd from RoSPA elaborated: “We have to think carefully as to whether consultation is the correct way forward, unless there is clear information that sets out carefully what the positive and negative effects would be”.
123.Other witnesses, while recognising the need for input by the public into the decision-making process, expressed a range of views on the format and timing of any consultation.
124.Several witnesses questioned the suitability of an open consultation—such as that conducted by the Commission in the summer of 2018—for surveying the public on the abolition of clock changes. Mr Pearce, a historian of seasonal changes of time, observed that open consultations were more likely to engage “people with stronger views” on the matter, possibly “boosting the percentage” of responses in favour of discontinuation. Dr Rolfe of Demos agreed, and also argued that consultations tended to fail to reach certain groups, such as the disabled and those without an Internet connection—the latter, she told us, accounted for 10% of the population in the UK and 14% in Northern Ireland. Similar concerns were raised by Ms Hedley, who noted that those at risk of being excluded from an online consultation on clock changes would also be among the most affected by their abolition—for example, people living in the northern parts of the UK.
125.According to Dr Rolfe, opinion polls would offer a “much better” alternative to open consultations, especially if conducted on a “sample of the public” randomly selected from a panel. She argued that panels had the advantage of comprising “thousands of people” who had volunteered “to answer questions on a particular issue”, and therefore did “not have a vested interest”. As in open consultations, however, participants of panels were “not necessarily informed about the issue” and might not consider its “wider implications”.
126.To avoid the risk of a “knee-jerk response” based on uninformed preferences, Dr Rolfe proposed a third way: citizens’ assemblies where representative samples of the population are “presented with evidence from experts” to consider, before coming to an informed view. She saw this as “a much better way of coming to grips with” the issues.
127.The format of questioning can also have a considerable influence on the outcomes of consultation. Dr Hayward told us that the Irish government’s opinion poll, which she called “carefully conducted”, asked respondents “whether they would be willing to see two time zones on the island of Ireland”; 82% opposed the idea. By contrast, she and Mr Rosher noted that, in the Irish government’s public survey, participants were asked for their views on the potential for different time zones through an open-ended question, and 67% of respondents did not report any impacts. They suggested that the method chosen meant that the latter figure could “only be considered indicative rather than conclusive”.
128.The Centre for Cross Border Studies suggested that any consultation “should be targeted at relevant representative business and civil society bodies, as well as major public service providers”.
129.Witnesses expressed different views on the most appropriate timing for consultation. Dr Rolfe highlighted the risk that, if a consultation were held imminently, its results could be “clouded” by tensions around Brexit. Any sample survey conducted now would need to select participants not only according to their views on clock changes, but also “on the basis of leave or remain”, which would make the process “much more muddied”. She suggested instead that, in the shorter term, the Government could initiate a “public information campaign” to raise awareness and set up the consultation process, which would take “a matter of months”. In their joint submission, Dr Hayward and Mr Rosher also observed that the “lack of urgency around the proposal” allowed the Government “time to plan and consult”.
130.On the other hand, Mr Cleppe of Open Europe argued that, if the proposal progressed more swiftly than expected, the lack of polling evidence would make it far more difficult for the Government to decide. He considered it preferable to “have some evidence and data ready to present”.
131.The Government stated that it “would not make changes to the current daylight saving arrangements without a full public consultation”. Since, however, the Government did not intend to implement the Commission’s proposal, it also had “no plans to launch a consultation on this matter”. The Minister made the further point that the Government had “a duty … to make sure that we do not concern people about something that may never happen”. She indicated that, once it was clear “when [the proposal] was to be made law”, the Government would “need to go away and look” at the possibility of a public consultation.
132.Should the EU pass legislation discontinuing seasonal changes of time, the Government would be faced with two levels of decision making: whether the UK should also abandon the biannual clock change, in line with its EU neighbours; and if so, which permanent time zone it should adopt. At present, the Government has little evidence of the views of the public on either issue.
133.We accept that there is no urgency for the Government to conduct a full public consultation at this stage. But there remains a possibility that the proposal will resume progress in the Council and ultimately be agreed, and it would therefore be prudent for the Government to initiate consideration of how a future consultation exercise might be designed. In so doing, it should take account of the lessons that can be learned from previous EU and national consultation exercises, as well as of the specific suggestions made by our witnesses, such as the use of citizens’ assemblies or sample surveys.
134.The need for the devolved administrations to be involved in any future decision on the UK’s time arrangements was undisputed by witnesses. The Centre for Cross Border Studies argued that the devolved administrations should not only contribute to “the preparation of any UK Government consultation”, but also be “kept closely informed of any proposed UK Government policies”. It concluded that any decision should reflect “the maximum level of agreement”. The Scottish Government asked that the Government commit to not considering any changes to clock-change arrangements “without the specific approval and support of all of the devolved administrations”.
135.Dr Hayward told us that the Joint Ministerial Committee would have the “means” to “co-ordinate input from the devolved nations … and respond to what is coming from them”. Mr Edelsten, on the other hand, suggested “a working party”. Dr Rolfe indicated that, if the Government were to use a citizens’ assembly process, assemblies should be established “in different parts of the UK, obviously including Scotland”.
136.Witnesses also highlighted the importance of the English regions. According to Mr Edelsten, “the requirements and priorities from the north east, north west, south east and south west” of England were “likely to be quite different”. The Centre for Cross Border Studies recommended that regional bodies be involved in the design of any future consultation, as “a cooperative approach” was “more likely to include questions attuned to the different regions’ particular contexts”.
137.The Minister assured us that the Government was “engaging with all the devolved Administrations to understand the impact [of the proposal] in their areas”. In particular, it was “working and communicating” with the Scottish Government “on both a formal and informal basis”.
138.Witnesses drew attention to the specific challenges associated with consultation in Northern Ireland while the devolved institutions were suspended. The Centre for Cross Border Studies noted that it would be difficult for the Government to lead on consultation in Northern Ireland, given that time was a devolved matter. It proposed instead that the Government “should support the creation of a mechanism or employ an existing body to undertake consultation”. As noted in paragraph 81, Northern Ireland devolved institutions have been restored since we took evidence for this inquiry.
139.Commenting on the design of any future consultation, the Centre for Cross Border Studies argued that “questions should be framed in order to offer the appropriate weight” to the unique implications of abolishing clock changes for Northern Ireland. Dr Hayward noted that the inclusion of a question on the possibility of two time zones on the island of Ireland meant respondents to the Irish government’s opinion poll “completely changed their mind” on the desirability of discontinuing clock changes.
140.The Minister told us: “While we may not be undertaking formal consultation at this point, that does not mean that we are not engaging, listening and talking to people [in Northern Ireland]—mainly listening.”
141.The implications of the proposal to discontinue seasonal changes of time and the considerations involved in choosing a permanent time zone vary significantly across different parts of the UK. It is essential that the Government closely engages with the devolved administrations and regional bodies, including on the design and conduct of any consultation.
142.We welcome the Government’s informal engagement with stakeholders in Northern Ireland to understand their specific concerns. We encourage it to continue this engagement. We note, however, that the Irish government’s comprehensive consultation exercise offered Northern Irish stakeholders an opportunity to articulate their views formally.
143.Appearing before us on 17 October 2019, Mr Ireland, Mr Lloyd and Dr Andrews told us that their organisations had had no formal engagement with the Government or regulators on the proposal’s implications for the UK. Mr Ireland signalled that airlines “would be very keen to feed into” any future assessment of the proposal.
144.SONI Ltd, the electricity System Operator for Northern Ireland, stated that consultation with the SEM and market operators in the all-island energy market “would be beneficial”. It recommended that this should follow “existing regulatory channels”. In particular, the SEM Committee, the decision-making authority for the SEM, “should advise on any input to the Government’s approach”.
145.The Minister confirmed that the Government was “not carrying out formal stakeholder engagement” given its position against abolishing clock changes in the UK. Asked how the Government had reached such a position without consulting with stakeholders, the Minister reiterated that “without a full impact assessment” there was no evidence to support the need for a change to time arrangements.
146.We reiterate our view, set out in our Subsidiarity Assessment report of October 2018, that the issue of clock changes does not warrant action at EU level. Nevertheless, we have examined the European Commission’s proposal to discontinue seasonal changes of time closely, and our inquiry has demonstrated that any such decision at EU level would have implications for the UK, notwithstanding UK withdrawal from the EU. The nature and significance of such implications is not, however, well-understood—not least by the Government.
(a)To review the research landscape, including any research carried out where non-alignment on clock changes exists, either within or between countries, and develop an evidence-based approach to the broader question of whether the UK should retain seasonal changes of time; and
(b)To carry out further work to identify the possible implications of a change to our time arrangements for business, nationally and internationally, working with the devolved authorities to better map and understand distinct regional issues.
145 Written evidence from Duncan Edelsten (), Written evidence from Susan Hedley ()
146 Written evidence from the Scottish Government ()
147 Written evidence from the Royal Society for the Prevention of Accidents ()
148 (Nick Lloyd)
149 Written evidence from Chris Pearce ()
150 (Dr Heather Rolfe)
151 Written evidence from Susan Hedley ()
152 (Dr Heather Rolfe)
154 (Dr Katy Hayward)
155 Written evidence from Dr Katy Hayward and Ben Rosher ()
156 Written evidence from the Centre for Cross Border Studies ()
157 (Dr Heather Rolfe)
158 Written evidence from Dr Katy Hayward and Ben Rosher ()
159 (Pieter Cleppe)
160 Written evidence from the Department for Business, Energy & Industrial Strategy ()
161 (Kelly Tolhurst MP)
162 (Kelly Tolhurst MP)
163 Written evidence from the Centre for Cross Border Studies ()
164 Written evidence from the Scottish Government ()
165 (Dr Katy Hayward)
166 Written evidence from Duncan Edelsten ()
167 (Dr Heather Rolfe)
168 Written evidence from Duncan Edelsten ()
169 Written evidence from the Centre for Cross Border Studies ()
170 (Kelly Tolhurst MP)
171 Written evidence from the Centre for Cross Border Studies ()
172 Written evidence from the Centre for Cross Border Studies ()
173 (Dr Katy Hayward)
174 (Kelly Tolhurst MP)
175 (Philip Ireland)
176 Written evidence from SONI Ltd ()
177 (Kelly Tolhurst MP)