Clear and Accessible: Meeting Gunning Principle 2 in Public Consultations

Public bodies have a legal duty to consult fairly. Gunning Principle 2 requires providing consultees with “enough information to enable them to give intelligent consideration to the issue at hand.” In practice, this means consultation materials must be clear, accessible, and comprehensive—not dense jargon, but information the public can understand and use.

This article explores how public-sector communications teams can design consultation materials and response mechanisms that are inclusive, accessible, and enable intelligent public input.

What Gunning Principle 2 Actually Requires

Courts don’t just check whether you’ve published information—they ask: “Did consultees genuinely have enough clear information to respond intelligently?” The information must be digestible and balanced. As the Public Law Project states, consultation documents “must be available to all, in a language which is simple and clear and not bedevilled with jargon.”

You cannot expect citizens to wade through impenetrable technical language. The onus is on you to communicate clearly at source.

What this means in practice:

Use plain language. Explain technical terms in simple words. Avoid bureaucratic phrasing. An informed layperson—not just experts—should grasp the key points. If your draft reads like an academic paper, it’s not ready for public consumption.

Structure information well and balance it. Present your proposals candidly—the context, the reasons, the impacts. Balance means being upfront about trade-offs so the material doesn’t read as one-sided advocacy. If there are lengthy technical reports, provide plain-language summaries. Put yourself in a typical resident’s shoes: “Would I understand this well enough to give useful feedback?”

The Accessibility Imperative

Clarity alone doesn’t ensure everyone can engage—you must meet accessibility standards. Public sector bodies are legally required to meet Web Content Accessibility Guidelines (WCAG 2.1 Level AA) for online content. Following these guidelines makes content more usable for everyone, not just disabled users.

Design with accessibility in mind from the start:

• Ensure PDFs are properly tagged for screen readers or provide HTML versions
• Include alt-text for images and infographics
• Provide captions or transcripts for video/audio content
• Use readable fonts and sufficient color contrast
• Test with accessibility tools before publishing

Offer alternative formats proactively. Best practice: state upfront that Easy Read, large print, braille, audio, BSL video, and translations are available on request. Provide contact details for requests. Royal Berkshire Fire and Rescue Service explicitly noted their consultation was “available in EasyRead, large text and plain text form, as well as in a variety of languages” with multiple contact methods. This signals inclusion from the outset.

Easy Read uses simple language and supporting images to help people with learning disabilities—but it helps many others too, including those with lower literacy or limited English. Many PCCs and NHS bodies now routinely produce Easy Read versions of major consultations.

Designing Clear, Inclusive Materials: Practical Steps

1. Start with plain-English principles
Write in straightforward language. Use short sentences and common words. Define technical terms the first time you use them. Instead of “We propose modifying the IRMP as part of the NFCC community risk management framework,” say “We propose changing our Integrated Risk Management Plan (the document that guides local fire service priorities).” Break text into logical sections with clear headings.

2. Use a structured, balanced format
Begin with a concise overview. Use bullet points or infographics to highlight key facts. Organize logically: background, rationale, specific proposals, impacts, and how to respond. Present information neutrally—if there are options, describe each fairly without hiding drawbacks. Balanced information builds trust and passes the fairness test.

3. Apply accessibility checks
Before publishing, verify WCAG 2.1 AA compliance: alt-text on images, properly coded headings, descriptive link text, keyboard navigation. Test with a screen reader. Check color contrast. Offer content as both PDF and HTML.

4. Incorporate visual aids thoughtfully
Charts, maps, and infographics can clarify complexity—but provide text descriptions for those who can’t see them. Use clear labels and legends. Ensure visuals support rather than confuse.

5. Design clear, fair questions
Craft consultation questions in plain language. Each question should address one issue. Avoid leading or convoluted questions. Pilot test with a diverse group before launch to catch ambiguities.

6. Include assisted response routes
Provide multiple ways to respond: online form, paper form with Freepost address, email, telephone. Offer assisted digital support for those who need help responding. Advertise: “If you need help responding, call us.” Make participation possible for everyone.

Common Pitfalls to Avoid

Dense documents: If key information is buried or incomprehensible, people cannot give meaningful feedback. Edit ruthlessly. Provide plain-language summaries of technical annexes.

Unexplained jargon: Every unexplained acronym excludes people. Provide a glossary or use everyday language. “We are consulting on the HWB’s JSNA” becomes “We’re asking for your views on the Health and Wellbeing Board’s Joint Strategic Needs Assessment—the local health overview that guides priorities.”

Inaccessible formats: Don’t release consultations in only one format. Offer materials in multiple formats and test them. Ensure PDFs work with screen readers. Check online surveys work on mobile devices.

Leading questions: Questions that push toward a certain answer undermine credibility. Keep questions neutral, single-focused, and jargon-free. Always allow space for open comments.

Process barriers: Requiring logins, lacking offline options, or having unclear contact details all discourage participation. Make responding as frictionless as possible.

Missing context: Consulting without disclosing important information (savings, trade-offs, known drawbacks) leaves people responding in a vacuum. Be transparent. Give people the reasons behind proposals, including challenges.

Real-World Examples

Fire & Rescue: Royal Berkshire FRS produced Easy Read versions of their Integrated Risk Management Plan consultation, offered large print and translations, and provided multiple response channels (online, mail, phone).

Police and Crime Commissioners: Norfolk PCC created an Easy Read consultation booklet on their police and crime plan. The Electoral Commission provided consultations in Easy Read and British Sign Language video format.

NHS: NHS bodies routinely prepare Easy Read summaries for service reconfigurations, ensuring compliance with the Accessible Information Standard (braille, large print, audio as needed). Many produce plain-language summaries of technical business cases with supporting infographics.

Conclusion: Accessibility Enhances Quality

Designing accessible, clear consultations isn’t a trade-off; it enhances participation quality. When you remove barriers, people are more likely to respond thoughtfully. Accessible consultations foster trust, generate better input, and produce more robust decisions.

Meeting Gunning Principle 2 means making consultations easy to read, easy to access, and easy to respond to. No jargon. No barriers. Just a clear ask and an open door for everyone to have their say.