This is Blog No 16
Hundreds of public consultations are launched in the UK every week. Mercifully they are not all from Government departments. They come from your local Council, your local Health service, from Regulators like OfWAT or OfGEM, from property developers, theatres or even your local football team. Far too many!
You cannot respond to them all. So, how will you select which ones to prioritise?
Obviously, your circumstances will vary. An individual with time on his or her hands, and with an unsatiable appetite for completing online surveys can occupy each week with a never-ending stream of issues to consider. A business owner, on the other hand, may have hardly any time at all yet be significantly affected by decisions being consulted upon.
Last week I wrote about campaigners varying from massive trade associations or pressure groups to small local community or affinity groups that form a huge part of our vibrant civic society. Imagine such organisations each with a different mix of professional and volunteer resources, and having to decide which consultations they should respond to.
Here are six relevant questions they – and you - should ask. For these purposes assume that the personal pronouns – ‘I or you’ could equally refer to ‘you or your organisation’.
- How relevant is it to me?
There are issues that are go to the heart of an organisations’ entire raison d’etre. There are others which are barely significant, or maybe only peripherally applicable to you. Of course, you might wish to respond because you have a mild fascination (let’s avoid the word ‘interest’ in this context) for the subject-matter. By all means, indulge yourself, but it may not be a priority ….
- Am I expected to respond?
There are organisations who will be deemed not to be doing their jobs if they fail to respond. If you are the National Farmers Union, and you do not respond to a consultation on agriculture, your members will surely be upset. But you also need to consider the consultor’s perspective. Are you an individual or an organisation whom the consultation organiser expects to hear from? Would your absence be noticed, and might it signal that you are uninterested or unwilling to engage?
- Do I really understand what can be influenced?
Is this a meaningful consultation? Is it for real? Do you know enough of the backstory – what has already been decided and where there is an actual opportunity to influence the outcome? Sadly, you cannot always take the consultation document at face-value. So are you sufficiently au fait with the policy context or the process context to distinguish between those that are genuine and those tick-in-the-box exercises where they are just going through the motions.
- Have I got something distinctive to say?
It is true that there are some issues where the numbers responding can be significant. 100,000 people saying the same thing might count a lot more than 10,000, but in general the quantitative aspect of consultation is much exaggerated. You are more likely to be noticed if you have something different to say or can explain a more general argument in relation to your own experience or contribute qualitatively to a better understanding of the impact of proposals, or address costs and benefits in a very specific way. Saying something different adds value.
- Will my response be noticed?
It is often worth considering whether you are participating in a mass response consultation alongside tens of thousands of others, or whether it is a more specialist issue or one which has been overlooked. Many consultations have been so badly promoted that they attract far fewer responses than consultors wanted (or promised their bosses). If you think there will be a small response, you may be welcomed with open arms by frustrated organisers. But it may also depend upon what else you do. A charity that has a brilliant ‘Comms’ function and gets its spokespersons on the Radio 4 Today programme to explain their response – or gets quoted in the traditional or social media makes far more impact. So, what else you do to leverage the message of your consultation response matters.
- Do I have the skills/experience to respond?
Finally, even if all the other questions result in a YES answer, you should think twice if you lack the expertise to respond. Obviously, it depends how onerous the data gathering might be. Spending ten minutes rushing through a digital questionnaire is clearly no problem. But extensive ‘document with questions’ style consultations requiring extensive domain knowledge are quite different, especially if calling upon reasoned arguments on technical options. Although answering the stated questions is important (otherwise you affect the consultor’s analysis schema) you may wish to make a comprehensive submission that enables you to express a case that you might otherwise be unable to make. This is where having a ‘policy officer’ or research team matters. (I’d use the term ‘policy wonk’ were I not afraid of upsetting some dear friends)
SUMMARY
The best and most professional consultees will respond to the consultation in the way its data gathering has been structured. But they will also use the existence of the consultation exercise to lobby for their own cause by seeking meetings, using the media, and mobilising grassroots support to advance their cause. Linking such activity to an ongoing consultation requires more than skilled ‘Comms’ expertise, excellent though that can often be. It needs people with wide experience of the different ways that different consultations play out, and who know how to secure influence without antagonising those who organise the required engagement.
Every organisation’s culture is different. Some have a track record of responding to everything they can and risk becoming what is sometimes disparagingly called the ‘usual suspects’. Others hold their fire even when tempted, so that the full weight of their reputation and knowledge can have most effect on a small number of strategic occasions. They follow the mantra of Don’t say much, but when you do, say it loudly!
For both ends of the spectrum and for those in between, these six questions still apply, and are not always easy to assess.
And sometimes it is best to go outside your immediate environment and seek external advice.
Just make sure they know enough about consultations!
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