Objection to the 20mph zone consultation process
15/02/2017 15:07:00......Posted by Mario Creatura
Below is my submission the the Council's extremly flawed consultation on 20mph zones in Croydon. I do not oppose 20mph roads where they are required or where residents want them, however, the way this consultation is being carried out degrades the democratic mandate of the Labour administration and weakens faith in the consultation process. I therefore write in opposition to this and not the principle of the policy:
I write to object at the process by this this consultation is being carried out.
1. The website does not allow respondents to 'support' the proposal for 20mph zones. As indicated by the text on the website and implied by the email address, only objections are sought.
One example of this can be found at the following web link.
The site says:
'The statutory consultation will close on 15 February 2017. Persons desiring to object to the proposed Order should send a statement in writing of their objection quoting PD/CH/A63 and the grounds thereof to the... or by emailing email@example.com quoting the reference PD/CH/A63 by 15 February 2017.’
Does this not imply that there is a presumption of opposition to the proposals? How will the Council assess support for the plans? If you received 1,000 objections and no statements of support, how can the Council proceed with the policy? If there are 2,000 supporters, for arguments sake, they have no formal mechanism to respond. This is undemocratic as it does not allow for an equal expression of opinion in the consultation. This implies the Council is not prepared to actually listen to the volume of opinion and so degrades trust in the consultative process.
2. No threshold for ‘objections received’ has been supplied. This is, to use the above example, mean that if you received 1,000 objections and no expressions of support that with 100% opposition the Council could still proceed with the policy. This will weaken the foundations of democratic accountability in Croydon, and not serve to bolster the administrations claims to be ‘open and transparent’. Why not have the threshold published and demonstrate a faith in the strength of the arguments provided?
With no option to ‘support’ the proposals, there is nothing to combat the narrative that ‘100% of respondents objected to the 20mph policy’ – it will be a matter of fact due to the Council not providing another option.
3. The Council is well aware that in Zones 1 and 2 that residents were given the opportunity to support or object in the first round of the consultation. This eventually resulted in the policy going ahead in those two zones. Given the success rate of this approach, it does not make democratic sense for the consultation to be amended for the 3rd, 4th and 5th zones.
The narrative that the Council treats residents in different parts of the borough differently, or at least that they do not care to listen to all residents equally, is entirely justified as it is literally what has happened with this consultation.
Many of my Residents’ Associations feel like their voices are not being heard equally or fairly by the administration: you’ll have seen objections to the consultation from Old Coulsdon Residents’ Association and East Coulsdon Residents’ Association, to name a few. It’s important to note that this is not a partisan point – the Chair of ECRA is a staunch Labour member and has run for the Labour Party in many different elections.
4. I do not object to the principle of individual roads being 20MPH, but I do object to the poor way that the Council has implemented this policy. If you are going to consult with residents, consult with them all consistently and with a mechanism by which you can guarantee you will hear the full range of opinions on a policy. The Council has not done that in this instance, has therefore weakened their claim to be open and transparent, has shaken faith in the principle of consultations and has silenced potentially thousands of residents who may wish to support the Council’s policy.
If the Council believes that 20MPH zones is the right course, then they should have the confidence to make the case firmly for them in public, provide evidence for their assertions and correct opposition, consult all widely and fairly, and then respond to the will of the electorate.
As it currently stands, the changes to this consultation over the previous months implies that the consultation is being treated as a formality and not as the vital democratic step that it is.
It is for these reasons, and these alone, that I object to the consultation process.