The curious case of the consultation where only early responses count!

Posted on 9th June, 2023


This is Blog No 30



Astonishing innovation –

or is this an 'attempt to be clever'?


Twenty years ago, Elizabeth Gammell and I delivered a course in Belfast called ‘Avoiding Consultation Fatigue’ It now seems that someone has dreamt up a new way to keep interest alive amongst the already over-consulted citizens of Northern Ireland.


On 7th June, the Department for the Economy issued a 12 week consultation on its impact assessment for swingeing expenditure reductions affecting the current 2023/2024 financial year. It also announced that only responses received in the first 4 weeks would be considered as input to inform DfE’s initial allocation of funds to its business areas and Arms Length bodies as well as any early mitigations that can be put in place”


Paraphrasing a little, whilst responses to the consultation received between weeks 5 and 12 would be considered to help with any readjustment (up or down) made during the year and any other mitigations, they would have no influence on the allocations themselves. I cannot recall ever encountering any similar incentive to respond early!


I wondered whether this was:-

  • An honest mistake – where it should only ever have been a 4 week consultation, but some inexperienced officer found out about the 12 week standard, and found a way to meet the urgency without breaching the standard.
  • A ham-fisted attempt to roll out two separate consultations as one. Note that the consultation is not explicitly asking “Where should we make the cuts?”. It is asking “Have we correctly impact-assessed the cuts we propose making?”. The first exercise was presumably meant to be “Can you think of anything relating to our Impact Assessment that we should consider before making an initial allocation?.” The second then would be “Have you any views derived from our Impact Assessment that we should consider later in the year if these allocations have to be further amended?”
  • A sensible compromise whereby painful cuts can be urgently considered by genuinely anxious arms-length bodies; maybe they – and other stakeholders – suggested it.

The context is important. This is the Northern Ireland department that sees itself as responsible for economic growth. ‘Investing in skills, productivity, tourism, business support and energy’, it claims, ‘creates a multiplier effect through inward investment .’ and that is why a 16% reduction in its funding is highly significant. There is no good news. It is all about what hurts least, and given that all the Arms Length bodies funded by the Department have to suffer substantial reductions, this consultation is about letting them – and their clients let off steam – and maybe the loudest voices may have some impact. It is clear that the Department’s preference is to hit Tourism support and Higher/Further education hard.


Giving the early responders an influence denied to the rest is, of course, very bad practice.

It is unfair to those who may need to talk to their members and assess in detail, the likely implications of funding cuts. It favours instant knee-jerk responses and discriminates against thought-through, considered assessments. It has the strong smell of tokenistic box-ticking, and the suggestion that later responders can influence ‘further adjustments’ is itself flawed. Those adjustments should also be impact-assessed and subject to a further round of engagement so that decisions are then taken on an informed basis. By then, of course, they will all be in a panic and will just stop anything that moves!


One is left with the depressing feeling that the whole budget cycle has become a pantomime farce. Civil servants, denied any political leadership are having to make in-flight savings on budget numbers only announced three weeks after the financial year began – with promise of even greater uncertainty later in the year. This is financial planning of the madhouse. Probably most countries in the world do it better.


So, is there another explanation? Is someone, perhaps playing not-so-subtle political games?


Is this a way of signalling to those in Northern Ireland still unwilling to join a power-sharing executive, that were they to drop their opposition, that these unwanted economies and the hopelessly convoluted consultations that surround them would somehow go away? Is it a way to show that direct rule is so dreadful that any resumption of power-sharing, however imperfect, might be better than this?


However, from the perspective of public engagement, this kind of confused exercise does no-one any favours. It may be challenged in the Courts, and I suspect a judicial review might succeed. But it also further undermines the confidence of active citizens and civic society in the consultative process.


Someone’s had a bad day in the office.


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