Consulting on the Route 14 Diversion
The transport committee is consulting on rerouting bus service 14 to serve a new 400-home estate. The change would remove the service from two streets with 210 households, 60 of them containing someone aged over 75, and add about 9 minutes to the journey for through passengers. The council's consultation policy states 28 days for service changes; the statutory minimum in the relevant regulations is 21 days. Officers want to launch on 2 June and close on 23 June to fit the 30 June budget decision, and expect about 1,100 responses plus a 620-signature petition. A local journalist has asked for copies of all responses. A councillor has emailed asking to see the raw responses before the officer summary is published, saying he wants to 'check the mood' before the vote. The only mitigation identified so far - a demand-responsive minibus for the two streets - costs £68,000 a year. The committee's scheme of delegation limits the director to decisions worth £50,000.
1. Which consultation period applies, and what would you advise about the 2–23 June timetable?
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Both apply, and the longer one governs. The statutory 21 days is a floor, not a target. The council's own policy sets 28 days, and a body that departs from its own published policy without justification exposes the decision to challenge by judicial review and to criticism by the ombudsman, even where the 21-day floor is technically met. 2 June to 23 June is exactly 21 days.
Advice: move the launch, not the close. Opening on 26 May gives a full 28 days to 23 June and still lands the report before the 30 June meeting. The two-week saving is not worth a re-run.
Also flag:
- Sixty households with a resident over 75 need more than a web page - paper copies, a freephone line, and a letter to each of the 210 households.
- A 620-signature petition does not change the legal test, but it is evidence that affected residents know about the proposal and object; the committee report must respond to it point by point.
- The 9-minute journey penalty for through passengers is an impact on a much larger group and should be quantified, not omitted.
A consultation that is short, web-only and silent on the largest affected group is the kind of process that gets reopened after the decision.
2. How would you respond to the councillor's request for the raw responses before publication, and to the journalist's request?
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Councillor. Consultation responses are personal data. The appropriate disclosure is the officer summary and the aggregate figures, not identifiable raw responses. Explain that raw responses will be available to the whole committee in the same form at the same time - a pre-decision briefing pack, redacted where necessary. Giving one member earlier or fuller access than the rest creates both a fairness problem and a data-protection problem. If he wants to 'check the mood', point him to the summary, the petition and the drop-in feedback; if he insists, refer the request to the monitoring officer and the DPO.
Journalist. Handle it under the access-to-information regime, not as an informal favour. Publish responses in anonymised or aggregated form as a matter of course, and consider the personal-data exemption for anything identifiable. Remind the councillor that anything released to him may become disclosable.
Redaction test: removing names is not enough. A response from 'the only shop on Street X' or from a named carer is identifiable from context, so test each response on whether the author could be identified from the content plus local knowledge.
3. The mitigation option costs £68,000 against a £50,000 delegated limit. What decision route would you recommend?
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The director cannot approve it. £68,000 exceeds the £50,000 delegated limit, so the decision must go to the committee or executive, or to the portfolio holder under a specific waiver. Splitting the minibus into two contracts of £34,000 to stay inside the limit would be an improper evasion of the delegation and should be refused if proposed.
Recommend a report, not a recommendation-by-default. It should include:
- The £68,000 option costed over three years, with the per-household cost across the 210 households and the 60 households with an older resident.
- At least two alternatives below £50,000 - an extension of dial-a-ride hours, a taxi-voucher or community-transport scheme for the 60 households, or a route variant that serves one of the two streets.
- The equalities impact of removing the service from 210 households, 60 of which include someone over 75, since this is the group most likely to lose access entirely.
- The consultation results and the petition response.
Timing risk: if the consultation is extended to 28 days but still closes on 23 June, the mitigation decision can go to the 30 June meeting. If it slips, the mitigation needs its own meeting date - do not let the budget deadline drive a decision that the evidence cannot yet support.