In July, we described the joint Mayor of London/Metropolitan Police Service consultation on Public Access and Engagement as the possibly the ‘worst consultation of 2017’. We now have the resulting decision in a document called the ‘Public Access Strategy’ approved by Sadiq Khan on 31st October – only 15 working days after the consultation closed.

First the good news:-

• It has been wise to separate the proposals to close police counters from the less specific ideas on future public engagement. Joining the two together was one of the major weaknesses of the original consultation
• There are a few improvements in the document. They have referenced the Tables and Charts and provided sources for the data
• They have clearly taken account of some local issues and withdrawn some of the proposed closures
• They have updated the Equality Impact Assessment

However, they have once again ignored best practice standards – this time in the transparency of their analysis and a failure to disclose who has said what in response to the consultation. The new document states that they received 1,687 online responses and 900 written responses. We have no idea who these people were. They could all live in Birmingham for all we know. Apparently 1,592 people attended public meetings and therefore MOPAC concludes that ‘over 4,000 people took the opportunity to give us their views.’ Wrong again. Any market research graduate trainee would guess that some of those who attended might also have completed an online questionnaire. Then they announce that 14,500 people signed 8 petitions, but we have not the faintest idea what they may have said. It’s two fingers to anyone who signed these; the Mayor of London won’t even publish the texts.

The lack of analysis may of course be because the Mayor was in a hurry. Or it could be that the leading questions we criticised, or lack of any demographic data collected might have made the normal professional analysis embarrassing. However, the outcome is that no-one knows who responded to a particular question or what the balance of opinion might have been. Neither do we know if sentiment was stronger in some areas or another, or among older people, or young people, or women, or disabled people or LBGT people. All we have are vague statements such as:

‘… many people were concerned that …. (p.10)
‘…we heard concerns that …’ (p.12)
‘…it was clear that the public want …’ (p.17)
’…many people expressed their concerns …’ (p.23)
‘…Concerns were expressed during the consultation process that …’ (p.25)
‘…some people expressed their concerns.’ (p.28)

The lack of precision is a shame because some of the qualitative arguments are important to appreciate. It would have been better also to have a record of the dialogues which MOPAC hopefully held with seldom-heard groups (They still use the term ‘hard-to reach’ despite best practice having abandoned this years ago).

In summary, this is an inadequate analysis of an important consultation. Worryingly, the published note of the Mayor of London’s decision suggests that Sadiq Khan was not provided with any analysis of the consultation – merely told that “All responses to the consultation were given careful consideration, and read and analysed. This analysis has then been taken into account in formulating the final Strategy.”

The law requires the Mayor to give the consultation ‘conscientious consideration’ (Gunning Principle Four). As it is his decision, he cannot delegate it. He cannot therefore escape his own legal responsibility to give that consideration. Without a proper analysis of the responses, we wonder whether he is not vulnerable to legal challenge on this point.

Last week, we commented on and recommended the Analysis Report published in Scotland about the Fracking consultation; it is a good example of best practice. The MOPAC exercise was poor from start to finish and the lack of transparent analysis stands in sharp contrast to the work of Dawn Griesbach and her colleagues in Scotland.

The Mayor of London and the Metropolitan Police really must clean up their act.

Our original critique can be found here.