Letter: Concerns Over Consultations

Dear City of York councillors and officers,

We are writing to raise York Cycle Campaign’s concerns about the Council’s consultations on transport and related matters. We believe that the Council’s approach to, and use of, consultations has been, and continues to be, deeply flawed and is resulting in decisions that are not in the public good. 

Consultations are not a substitute for vision and strategy 

The starting point for transport decisions should not be a consultation but instead an agreed vision and strategy for transport in York. The Council must prioritise the production of a robust Local Transport Plan and a Local Cycling and Walking Infrastructure Plan that are aligned with national policy and guidance – e.g. that prioritise active transport – and relevant local decisions, including the City’s commitments to be carbon neutral and to limit car journeys within the city centre.

Consultations should not ignore national policy and guidance

Transport plans put forward for consultation should, as a matter of course, comply with the expectations of the Government’s vision for cycling and walking (Gear Change) and its guidance (LTN 1/20) on cycle provision. Those responding to consultations should not have to highlight deficiencies in the Council’s proposals.  

Consultations must be treated with care

The Council is reminded that consultations are not neutral: evidence suggests that they tend to attract responses from particular demographics (e.g. older residents who own cars) and favour the status quo over change, particularly radical change (the incumbency effect). 

We are also concerned about bias in the presentation and interpretation of data from consultations undertaken by, or for, the Council, notably the tendency to cherry-pick data that support the status quo or the Council’s desired outcome and to bury/under-represent/mis-represent data – including expert submissions from the likes of York Civic Trust – that do not align with the status quo or the Council’s desired outcome.  

For these reasons (see also below), consultations should not be treated as referenda: for example, a carefully designed scheme that complies with LTN 1/20 guidance should not be rejected on the basis of negative responses; conversely, a poorly designed scheme that fails to comply with LTN 1/20 should not be approved on the basis of positive responses.

Consultations need to be well-designed and well-executed

A poorly-designed and/or poorly-executed consultation is worse than no consultation, producing results that are at best meaningless and at worst deeply flawed. We contend that recent consultations on transport matters in York have been characterised by:

• a lack of clarity with respect to their aim and consequently their design and timing
• a focus on perceived problems rather than possible solutions and a clear presumption against cycling, portraying cyclists as problematic and failing to present the positives associated with cycling (as a low carbon, low pollution, low cost, active means of transport)
• attempts to pit interest groups against one another (e.g. cyclists vs pedestrians) rather than building consensus, moreover a failure to recognise that most individuals are multimodal in terms of transport use
• poor methodology, which has included:
  • a lack of thought in terms of reaching out to stakeholders to ensure that sufficient numbers, across a range of demographic groups, respond
  • a failure to engage meaningfully with stakeholders from minority and marginalised groups 
  • biased, ambiguous and leading questions
  • the over-use of technical questions and reliance on technical drawings (cf. more accessible visualisations), thus excluding members of the public who do not feel they have the expertise to respond
• a tendency to promote ‘all or nothing’ or ‘one size fits all’ outcomes when the best solution may be complex and ‘messy’.

York Cycle Campaign believes it is vital that the issues highlighted above are addressed as a matter of urgency to ensure that decision making on transport matters is in the best interests of the City. 

We therefore ask the Council:

1. To ensure that York’s LTP and LCWIP are prioritised and that they are aligned with national policy and guidance and relevant local decisions;
2. To ensure that all transport proposals put forward for consultation are designed in compliance with LTN 1/20;
3. To remember that consultations are not neutral, that data from consultations need to be treated with respect, and that consultations are not referenda: consultations should not be used to enable elected officials and officers to shirk their responsibilities and avoid taking controversial – but optimal and strategic – decisions; 
4. To ensure that all consultations are designed and executed in line with accepted good practice.

We look forward to hearing from you.   

Yours sincerely, 

York Cycle Campaign