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AIR QUALITY MANAGEMENT RESOURCE CENTRE

AQM CONSULTATION WORKSHOP REPORT 
15 OCTOBER 1998, UWE


CONTENTS

1.    INTRODUCTION

2.    CONSULTATION FOR LOCAL AIR QUALITY MANAGEMENT
       Tim Williamson, Policy Officer, NSCA

3.     LOCAL AGENDA 21 CONSULTATION
        Angela Mawle, Sustainable City Team Leader, Bristol City Council

4.     LOCAL DEVELOPMENT PLAN CONSULTATION PROCESS
        Gerard Philips, Co-ordinator Local Plans, Bristol City Council

5.     LOCAL ENVIRONMENT AGENCY PLANS - THE ENVIRONMENT AGENCY
        Peter Grigorey, Regional LEAPS Planner

6.     EXPERIENCES FROM ACROSS THE REGION
        Kathy Derrick, Bristol City Council & Kennet District Council

7.     SOME MODELS OF COMMUNICATION
        Jeff Hurran, Bristol Business School, University of the West of England

8.     WORKSHOP - A CONSULTATION EXERCISE

9.     CONCLUSIONS

10.    REFERENCES

        APPENDICES

        ACKNOWLEDGEMENTS


1. INTRODUCTION

As local authorities undertake air quality reviews and assessments, so the process of consultation with their communities and stakeholders begins. This workshop explored the very fundamental nature of how to consult, with whom, and how to deliver an effective consultation strategy with respect to the process of air quality management. Presentations by representatives from local authorities, the Environment Agency and the National Society for Clean Air and Environmental Protection (NSCA) reviewed statutory consultation processes required for other planning processes. This provided an introduction into the procedures and techniques considered necessary for effective consultation.

Seventeen local authorities were represented at the workshop, of which eight were from the South West (North Wiltshire District Council, Bristol City Council, Bath and North East Somerset Council, Devon County Council, Salisbury District Council, South Gloucestershire Council, North Somerset District Council and the Forest of Dean District Council).

Those represented authorities external to the region were Leicester City Council, Vale of Glamorgan District Council, Borough of Poole, Herefordshire Council, Oadby and Wigston Borough Council, Caerphilly District Council, Lewes District Council, Cardiff County Council, Weymouth and Portland District Council.

During the course of the afternoon session, delegates explored potential solutions to anticipated difficulties with the consultation process, through debate. Individual groups developed model consultation strategies, by consideration of relevant consultees, appropriate techniques for consulting, and timetable involved.

This report provides a summary of the outcomes of the workshop, and useful references are provided towards the end of the report.


2. CONSULTATION FOR LOCAL AIR QUALITY MANAGEMENT
Tim Williamson, Policy Officer, National Society for Clean Air and Environmental Protection (NSCA)

A paper entitled 'Consultation for Local Air Quality Management' (see appendix 1) was produced by the National Society for Clean Air and Environmental Protection (NSCA) in response to the concerns raised by the NSCA's Air Quality Management Committee. The paper aims to encourage debate on what constitutes good practice with respect to local air quality management consultation, and the paper was received by the newly formed National Air Quality Forum.

Consultation is a legal requirement for local authorities, and under the Environment Act 1995, the local air quality management process requires the local authority to:

(a) review the air quality within the local authority area
(b) assess whether the standards are exceeded
(c) identify the areas of exceedence
(d) declare an air quality management area (AQMA)
(e) carry out a further assessment
(f) report the results
(g) prepare an Action Plan for the air quality management area

Consultation is considered necessary for any review and assessment of air quality, and the designation of an AQMA. A list of statutory consultees is provided under Schedule 11 of the Environment Act 1995, but the question arises as to whether the list is sufficiently informative.

Partnerships are increasingly recognised as the way forward for effective consultation, and the development of partnerships is an important element of the air quality management process, helping develop community ownership of any potential actions plans to ensure that they are meaningful. Partnership also improves understanding between professionals within a local authority, and ensures that the widest range of perspectives on the problem is obtained. Once a successful mechanism for consultation is established, it can be used for future activities and processes requiring consensus.

Within the recent Local Government White Paper 'Modern Local Government: In touch with the People', chapter 4 (page 39, paragraphs 4.6 and 4.8) places a duty on local authorities to consult with their communities as well as providing the power to hold referendums. A further duty requires local authorities to promote sustainability (chapter 8 of the White Paper, page 80 paragraphs 8.8 and 8.9) and local scrutiny (chapter 8 of the White Paper, page 81 paragraphs 8.1 and 8.17).

Setting environmental standards is a further requirement of local authorities, as set out in the Royal Commission on Environmental Pollution (21st Report) on 'Setting Environmental Standards', published in October 1998. The inclusion of citizen's values when preparing and implementing environmental standards, and the new forms of consultation (for example focus groups, citizen's juries and consensus conferences) are discussed, together with deliberative polls.

There are many definitions and degrees of consultation. The first level of consultation is information, which is essentially one-way, with the consulter and consultee distinct and remote. A leaflet drop or planning notice are examples of this, and this form of consultation tends to gather extreme values. Consultation, however, is a two-way process and is a classic form of opinion gathering. There is no interactive involvement, with the consulter and consultee remaining remote. Voting is an example of this two-way approach. Finally, participation is a two-way, active involvement approach, whereby the consultee plays a part in determining the agenda, and direct contact with the consulting body is required.

The local authority should develop a clear consultation strategy at the earliest possible stage. The consultation process should be in proportion to the scale of the issue, and should be open and transparent, making full use of the expertise of those involved. Continuity of the process is important, and is should run in parallel with the technical aspects of local air quality management. Participatory techniques should be used, wherever possible.

In conclusion, local authorities need to develop a framework for consultation on air quality management, and to be more effective, the process must take account of local circumstances. Behavioural changes will be needed to ensure effective air quality management, and generic guidance may not be so effective. As the Royal Commission on Environmental Pollution (21st Report) suggests, standards should apply to the smallest possible area, with a flexible approach to consultation in a large area. The NSCA on 'Consultation for Local Air Quality Management' paper deals essentially with the aspects of why we consult and with whom, and we are all now developing ideas as to how to consult and the techniques to use. Today's workshop should assist in developing good practice for local authorities as they embark on consulting their stakeholders and communities.


3. LOCAL AGENDA 21 CONSULTATION
Angela Mawle, Sustainable City Team Leader, Bristol City Council

Consultation will underpin an effective Local Air Quality Management process in the same way that it underpins the Local Agenda 21 process operating in communities. In order for consultation to be effective, participation must be meaningful so as to motivate communities and individuals, and in multi-cultural communities, such as Knowle West in Bristol, using the right language to convey a message is fundamental.

When communicating with a specific group of people, who may naturally be suspicious and ignorant of the subject matter in question, a hook on which to convey the information is important. In Knowle West, a partnership has developed between the local community and a number of private and public sectors, which has brought out the local pride and identity of the community.

William Budd was a famous, pioneering doctor who lived in Bristol from 1842. He was particularly interested in infectious diseases and epidemics, and was one of the few people of his time who understood that these diseases are spread by germs, often in water. During the Bristol cholera epidemics of 1854 and 1866, he organised the disinfecting of drains, sewers, patients clothing, bedding and corpses. This had a significant effect on the spread of disease and helped to save lives. As well as being a physician in Bristol, William Budd's interest in water led him to become a founder director of the Bristol Water Company.

Subsequently, the local health centre is named after William Budd and is being rebuilt on the old site of Merrywood Girls school. It will be one of the buildings in the new Health Park. The Bristol Regeneration Partnership, City Council and Avon Health Authority, in partnership with the local community, have developed the Health Park Project as part of the overall regeneration package for Knowle West (see appendix 2).

The aim of the new Health Park is to offer facilities to encourage people to become involved in healthy activities, and help prevent disease. It will include sport and leisure facilities, play areas, a café, gardens, health promotion and education. It is a unique partnership between local people, health and local authorities to improve health in the Knowle West Community and south Bristol as a whole. The project has stimulated a great deal of interest, and has led to a new spirit of co-operation and understanding within the community.

Local Agenda 21 is a process, which aims to involve local people in decision-making, and in so doing, provide greater access to information. Simply writing and informing communities has not proved effective in engaging interest, and instead, developing local events which are managed and branded by individual communities has been far more effective.

A 'Festival for the Future' was held on 4 May 1998 in Barton Hill, Bristol, which launched a unique community consultation programme. There were street events, stalls, youth activities and shows, and the community centre was opened up for the occasion. A key feature of the event was the use of a video box, which involved the young people of the community writing a script, directing, producing and editing a video of life for young people in Barton Hill entitled 'Barton Hill - how good will it get?'. Children effectively filmed their peers, playgrounds and communities, and the idea really took off.

As a result of the festival, funding opportunities and networks have developed, with drugs, unemployment and youth found to be the issues of greatest concern in the community. Clearly, the processes to promote access to information and resources and access to decision-making had begun. Interaction is clearly effective and necessary for the community development process, helping to build confidence and a sense of pride. Focus groups and citizen groups are all good vehicles for consultation, but we need to make sure that all of the community has access to them, so as to avoid social exclusion from any decision-making processes.


4. LOCAL DEVELOPMENT PLAN CONSULTATION PROCESS
Gerard Philips, Co-ordinator Local Plans, Bristol City Council

Local authority planning departments have been conducting formalised consultation exercises as a statutory duty for some considerable time. Planning departments are obliged to inform people of Local Plan proposals and to provide people with the opportunity for commenting on the plans, thereby ensuring the process is democratic.

Reasons for consulting on the Local Plan are as follows:

  • improves the content of the Plan (learn from others - we have no monopoly on good ideas and knowledge)
  • it delivers development and can create consensus (dialogue can create partnerships and can reduce misunderstanding);
  • it saves a lot of time and money (allows for change and agreement outside of the Public Inquiry process);
  • Legislative requirements (Town and Country Planning Act 1990, and Planning Policy Guidance note PPG12).

Bristol City Council is currently in the process of consulting on the draft Local Plan for the City. The previous consultation exercise undertaken in Bristol in relation to the last Local Plan took six months (April-November 1992), and was undertaken to coincide with Environment Week. A media and publicity campaign involved 50,000 copies of 'Bristol Matters' being distributed, with information packs disseminated to 900 groups. As well as this, the following activities were undertaken.

  • summary video produced;
  • 17 exhibitions;
  • 73 meetings;
  • 2,500 copies of the Local Plan printed;
  • Press and media coverage (articles);
  • Concluding Conference.

With respect to the actual planning process itself, a review of the Local Plan was undertaken following a period of consultation, following which a deposit draft of the Local Plan was published. Objections to the Local Plan were then received, following which a Public Inquiry was held and an Inspector's report produced. The final stages of the whole process involved amendments to the plan and the incorporation of further objections before the Local Plan was finally adopted.

With respect to the current Local Plan consultation, the following consultees were targeted:

  • 900 special interest groups;
  • 168 community groups;
  • 27 public bodies and statutory undertakers;
  • 21 central government departments or organisations;
  • 8 local authorities;
  • 29 major institutions and professional bodies;
  • 15 media organisations.

To date, responses to the consultation has reached 3,700 individual comments. The majority of these comments are from Statutory Consultees and public sector groups, and indeed private sector organisations representing the development industry. A large number of comments have also been received from local voluntary and community groups and local residents.

Problems with the consultation process have arisen from the viewpoint of the planner and the consultee. The public view is often:

  • seen to be difficult to understand;
  • inaccessible to those uninitiated in process;
  • expensive in terms of time, money, resources, particularly with respect to the Public Inquiry;
  • biased in favour of major players;
  • 'Planners don't want to listen anyway';
  • what consultation?

Difficulties for the local planner include the fact that there are increasing numbers of objections (victims of their own success), and that people may object but they don't say what they want to see. Delays in the process of producing a Local Plan are therefore inevitable.

Solutions to improving the overall effectiveness of the consultation exercise include restricting the scope of consultation, although this, in reality, moves away from the principle of consultation. An alternative solution is to extend outreach to other consultation exercises, by perhaps linking into, for example, the Local Agenda 21 process operating within the authority, conducting 'Planning for Real' exercises or using 'Democracy Plan' focus groups or 2000 Panels.

Finally, other mechanisms to be explored and used in the consultation process, such as the use of local media, the internet and email. There clearly is scope for refining and improving the management of the process, though it may only make a marginal difference.


5. LOCAL ENVIRONMENT AGENCY PLANS - THE ENVIRONMENT AGENCY
Peter Grigorey, Regional LEAPS Planner

The Environment Agency is currently very much involved in the process of consultation with respect to the development of the Local Environment Agency Plans (LEAPs), which succeed the former National Rivers Authority's CMP Programme, or former river catchment management plans. LEAPs are therefore based on river catchments and assist the Environment Agency in identifying and solving environmental issues related to their functions, taking into account the views of their local customers.

Consequently, LEAPs can result in a local agenda of integrated action for environmental improvement over a five-year period. There are 129 LEAP areas across the eight regions of the Environment Agency (see appendix 3 for clarification of individual LEAPs), and in the South West region there are 25 individual LEAPs alone. The Environment Agency is committed to publishing consultation documents for all LEAPs by December 1999, which has significant resource implications for the Agency.

The Agency began a three-month period of formal consultation to identify environmental issues that the Agency had either direct responsibility for, or an interest in, and to propose potential options for action. If we consider the River Torridge Consultation Draft, one typical issue covered in the document was the impact of barriers on migratory fish. The text provided includes the following:

  • background to the issue;
  • identifies what the problems are;
  • where the problems occur;
  • what the problems are caused by;
  • what the Agency proposes to do.

A table summaries the above and:

  • identifies who the Agency would need to work with;
  • how much it would cost the Agency;
  • proposes potential timetable for implementation.

A LEAP Action Plan is published at the end of the public consultation period (3-6 months into the process), to take account of comment received in modifying the proposals set out in the consultation document. The plan confirms environmental issues through either including new issues or omitting old issues, and the plan confirms actions to solve identified problems, as well as clarification as to potential partners, costs and timetables.

Approximately 13 months after the Action Plan is produced, a LEAP Annual Review reports on progress with the Action Plan. The Annual Review creates the opportunity for identifying any new issues, through listing all issues outlined in the Action Plan, comments on progress, and highlighting new issues. Subsequently a five-year LEAP Planning Programme is produced, with four Annual Reviews, and a full review of a LEAP after 5 years.

In terms of the management of the process from the outset, an Agency Working Group was formed to identify problems and solutions and the LEAP team wrote the draft text for internal consultation, which was amended through a process whereby the Catchment Steering Group and the Area Environment Group of the Agency had an opportunity to make comment. A formal launch was then held, to which the Catchment Steering Group and the Area Environment Group of the Agency were invited to attend.

The Agency ran and chaired the formal launch, providing a buffet lunch, and between 100-200 individuals or representatives was invited, to include the press. The LEAP Consultation Draft was distributed amongst the audience, and key LEAP issues were highlighted, and a question and answers session held.

Positive aspects of the launch were considered as follows:

  • help public consultation;
  • TV coverage
  • forge partnerships;
  • promote Agency and education.

The negative aspects were however as follows:

  • expensive (£1500-2000);
  • time-consuming;
  • preaching to the converted;
  • little value added;
  • media - 'loose cannons';
  • timing can exclude.

In producing the subsequent Action Plan, the LEAP Team co-ordinated responses received as a result of the consultation process, and the Working Group proposed amendments as necessary. The Catchment Steering Group and the Area Environment Group of the Agency once again had the opportunity to make comment, before they endorsed the final copy which was then sent to stakeholders, respondents to the consultation document and individuals who requested copies of the Action Plan.

The following table typifies the reposes received:

Summary Responses:
 

 

Typical National Figures  

No. of LEAPs printed  

1000

No. on internal distribution lists (including Head Office)

100

No. on external mailing lists  

500

No. available for distribution / requests

500

No. of responses received  

20-80

% responses by questionnaire  

50-70%

The amount of response was low compared to the number of plans distributed, and the quality of response was varied, with many spelling errors found and new issues identified. In summary, smaller planning areas generate both a higher quantity and quality of response, and questionnaires generate higher quantities of responses generally.

With respect to the best practice examples for launch events, the following is recommended:

  • hold launch in plan area;
  • use an independent chair;
  • interactive presentations;
  • use range of different speakers and functional experts;
  • encourage partner presentations;
  • allow time for networking (over food and drink);
  • use display board around the room and promote issues;
  • use discussion groups;
  • open meeting to the public.

In terms of promoting consultation, examples of best practice are as follows:

  • one-to-one meetings;
  • target or mail shot populations near contentious issues;
  • piggy-back existing shows, fairs and events;
  • use existing networks (e.g. Area Environment Group);
  • use local media as consultation reminder;
  • advertise in local groups leaflets and flyers;
  • maintain database to maintain links;
  • roadshow static display boards highlighting key issues;
  • man roadshow for question and answer sessions;
  • leave boxes of plans local authority offices;
  • field staff to distribute and advertise;
  • extensive poster campaign.

 Examples or best practice for alternatives to launches are as follows:

  • general press release;
  • placing adverts in local papers;
  • use of photo opportunities;
  • TV, radio or newspapers interviews - be proactive;
  • public meetings, seminars, talks, question and answer sessions;
  • mailshot key stakeholders;
  • advertise on the internet;
  • use stands at County Shows;

Research has been undertaken to assess how the consultation process was conducted, and whether or not the process was effective. Key lessons to be learnt are firstly that there needs to be clear objectives for consultation. The Environment Agency view of LEAPs ranged from:

  • PR exercise;
  • educational tool;
  • demonstrating accountability;
  • genuine desire to build partnerships.

 Secondly, the Agency needs to be clear on the target audience for consultation, and the Agency view ranged from:

  • concentrating solely on principle consultees;
  • focusing on the man in the street.

The objectives for the Agency are to promote the aims of the Agency and to ensure importance is given to partnership building. With respect to the target audience, LEAPs cannot be 'all things to all people', and therefore the Agency needs to target resources effectively. Targeting the right participation level to the right group is of paramount importance and the table below summarises the lessons learnt in this respect:
 

Participation Level    

Examples

Direct   Partners

Participative Groups

Other statutory Agencies

General Consultees

  Acting Together

  • Equal decision making
  • Joint funding
  • Joint implementation

    Should do

    Might do

    Not normally

   Not normally

  Deciding Together

  • Defining issues
  • Defining joint objectives
  • Defining joint targets

    Should do

    Might do

    Might do

   Not normally

  Consultation  

  • Verifying issues
  • Finding out views of consultees

  Should do

  Might do

  Should do

 Not   normally

    Information  

  • Describing environ
  • Role of EA
  • Role of LEAPs
  • Promoting EA

  Should do

  Might do

  Should do

  Should do

Key lessons to be learnt from the research undertaken in respect of the target audience show that the key target groups are as follows:

(i) Direct partners:

  • Development Control interests: local authorities (forward planning and development control)
  • Water interests: plc's, major abstractors and dischargers
  • Nature Conservation interests: local authority, English Nature, RSPB, Wildlife Trusts
  • Other environmental interests: local authority, MAFF
  • Land use interest: agriculture, industry, mineral extraction, waste disposal interests

(ii) Participative groups and other significant groups: conservation groups, recreation groups (for example ramblers, anglers and canoeists).

(iii) Other statutory agencies: Emergency Services, Highways Agency, Government Departments, Navigation or Forestry bodies.

(iv) General consultees: residents associations, Business and Community groups, Town & Parish Councils, general public.

As a result of assessing the effectiveness of the consultation process and production of a LEAP Action Plan, the Catchment Steering Group and the Area Environment Group of the Agency are to be involved in shaping the LEAP from the earliest occasion. They are to be assisted by other stakeholders, and are to be used to promote the consultation process. With respect to LEAP Action Plans, the Catchment Steering Group and the Area Environment Group of the Agency are once again to be involved at a much earlier stage than has previously been the case, with assistance from key stakeholders, and a 'Statement of Public Consultation' to be produced and distributed with the LEAP Action Plan.


6. EXPERIENCES FROM ACROSS THE REGION

Two authorities of different sizes and experiencing different air quality management challenges were invited to present to the audience their experiences of local air quality management consultation in their authority.

6.1 THE KENNET EXPERIENCE
Kennet District Council, Wiltshire

The local authorities within the County of Wiltshire first collaborated on the issue of air quality management consultation through their newly established Wiltshire Local Air Quality Management Sub-Group. The Sub-Group meets on a frequent basis to discuss progress being made with air quality reviews and assessments across the County. It provides an informal forum to talk through concerns, to consider ways forward, and to ensure a consistent approach to local air quality management in Wiltshire.

The Sub-Group has a representative from each of the four district councils and one unitary authority within the County, together with a representative from Wiltshire County Council's Transport Planning Unit. The Air Quality Management Resource Centre, UWE, is also represented on the Sub-Group, to assist with aspects of the Group's work.

Group collaboration on the issue of consultation led to a comprehensive list of potential consultees being produced, which was then adapted to local circumstances. The list included tenant associations, local environment and transport organisations, institutes and agricultural organisations. Each individual authority then composed a standard letter to be sent to listed consultees, to include neighbouring authorities and the County Council. The Kennet District Council has already received responses to the letter, and responses have been mixed, and at times entertaining.

The Council recognises that it is at an early stage in its consultation process, and also recognises the need to ensure that no potential consultee is overlooked from the very start of the process, so as to avoid any accusation of exclusion further on into the process.

6.2 LOCAL AIR QUALITY - PRACTICAL CONSULTATION
Kathy Derrick, Senior Scientific Officer, Bristol City Council

Bristol City Council is embarking on their air quality management consultation, and has identified a number of key sectors to consult with:

  • The public
  • Non-Governmental Organisations
  • Industry
  • Government (Secretary of State) and local government
  • The Environment Agency
  • Councillors
  • Other local authority departments

With respect to non-governmental organisations, the Council has a detailed mailing list of organisations operating within the City, and in addition the following organisations are to be consulted:

  • Local Agenda 21 Forum
  • Western Partnership for Sustainable Development (WPSD)
  • Bristol and District Environmental Quality Panel

When embarking on a wide consultation process, it is important to try and utilise mechanisms and structures already in place within the Council so as to avoid wasting time through creating new mechanisms. Identifying exactly what your authority is already doing in respect to consultation is important, and the specific requirements for air quality management consultation can be build on what is already underway. Other important aspects to consider are the following:

  • divide the consultees listed into the sectors referenced in the guidance;
  • distribute draft air quality review and assessment widely;
  • invite responses to the draft;
  • build in a reply mechanism.

Effective consultation with the public is possibly the most difficult aspect of the process, and this is to be addressed through the following:

  • mailing lists;
  • Local Agenda 21 Forum;
  • Democracy Panel;
  • City newspapers;
  • schools;
  • libraries;
  • Housing Offices;
  • the internet;

Communicating with the industrial and commercial sectors of the community is to be addressed in much the same way as other sectors, with mailing lists, newsletters and use of the internet. Contact will be made through the Bristol and District Environmental Quality Panel and Western Partnership for Sustainable Development (WPSD), the latter of whom has a strong connection to and affinity with business and industry. Consultation with the various utilities in the area is also proposed.

With respect to central and local government, the following are to be consulted:

  • Department for the Environment, Transport and the Regions (DETR)
  • Government Officer for the South West (GOSW)
  • The Environment Agency
  • All adjoining local authorities
  • Local Health Authorities
  • Academic Institutes

With respect to Bristol City Council, the city Councillors & other departments of the authority are to be consulted, through mailing to named lists, presentations, the use of the Local Air Quality Management video produced by DETR, and the internet. Internal departments to be consulted with include planning & transport, leisure and highways.

Finally, attention is drawn to the dissemination of the information by internet. The Environmental Quality Team have been developing air quality management web pages on which to place the first stage review and assessment of air quality information. This will ensure that a potentially wider audience can review the information as part of the consultation process. The information will be sent out on CD-ROM also, and examples of the web site can be found in appendix 4, together with a leaflet designed for wide circulation.


7. SOME MODELS OF COMMUNICATION
Jeff Hurran, Bristol Business School, University of the West of England

During the course of the workshop lunch, Jeff instigated a short exercise, whereby workshop delegates were asked to consider the problems they envisaged with any aspect of the air quality management consultation process, for their local authority. The following responses were received from delegates, and Jeff alluded to these responses during his presentation, which immediately followed lunch.

Workshop delegate responses: perceived difficulties

  • Public ignorance of the subject;
  • How can you avoid the press branding Air Quality Management Area (AQMA) as "Asthmaville" and avoid claims that increased death rates etc will result in these areas?;
  • Councillors worrying about their elected seats;
  • Will the process be extended beyond the set dead lines?;
  • All local authority departments, organisations (Environment Agency, Highways, Planning etc.) working towards the production their own documents and plans; all are working to different schedules (i.e. a Structure Plan is in draft form currently; Transportation have submitted a plan to the DETR for 2011;We are working to 2005). Conflicting timetables have implications for consultation and finally implementation?;
  • Likely to be final PR exercise;
  • Eccentric people (usually with silver foil on their head and dozens of cats) will demand the unreasonable and expect the unacceptable! ;
  • Should Environmental Health actually be undertaking the consultation process?;
  • List of consultees too long to cope with;
  • Expect everyone will make mistakes. Likely poor outcome - need to feed back to public as one voice;
  • The first stage review and assessment report will invariably include jargon, which will be over the heads of most consultees;
  • Language of consultation document inappropriate for all groups;
  • Consultation will create tonnes of paperwork, requiring never ending acknowledgement and correspondence. Resource implications!;
  • Some interest groups may be missed by the consultation exercise, and they may subsequently demand retrospective attention;
  • Coping with numbers; the more effective the consultation the more responses you have to reply to;
  • Likely to attract the same respondents, not those who traditionally don't get involved;
  • Responses biased to those with extreme views;
  • Usual complainants have a different agenda;
  • Stage one of the air quality management process is essentially just compiling lists of sources of pollution. How do you consult on a straightforward yes or no type exercise?

Consultation in respect of the air quality management process is evidently a process of concern to the audience, with the above list constituting a wide range of problems anticipated. It is important to first consider why we take a consensus approach to decision-making, whether for air quality management, or indeed any planning process.

The introduction of local and wider skills, knowledge, experiences and resources underlies a more effective management process and improves the overall outcome, be it a better plan, project or policy. Other positive aspects from consensus, which may not have been alluded to already, include:

  • The potential to resolve conflict between parties;
  • The more effective use of often limited resources;
  • Added value with direct and indirect benefits;
  • Change feelings of ownership, so increased acceptability and commitment to the outcome, and far grater chance of successful implementation;
  • Increase involvement - enjoyment and mutual education, understanding and respect;
  • Build confidence, skills and trust for future consultation exercises.

The process of consultation needs to be understandable and independent, with commitment from all involved, as an effective process is a two-way process. A common information base will ensure a common level understanding of the subject matter, and to avoid conflicts the process must be as open as possible.

There is no one simple answer to effective and successful consultation, but if during the process you build from a common ground and celebrate in small steps, then you will ensure confidence and trust in your consultee base. Try to ensure that decisions are agreed and supported by all party to the process, and not just the majority, and more importantly is to ensure that there is shared responsibility for the implementation of outcomes from the process.

Useful reading on the subject of participation and consensus is referenced in section 11 of this report.


8. WORKSHOP - A CONSULTATION EXERCISE

Workshop delegates were divided up into four groups. During the workshop session, delegates were asked to consider solutions to two questions posed. Two groups considered the following questions:

Question 1
How to ensure that any feedback or comments received at any stage of the
consultation process are fed back into the air quality management process.

Question 2
Identify ways of consulting with the public at the different stages of the air
quality management process.

The remaining two groups of were asked to consider the following two questions:

Question 3
How to engage with a sector or consultee which doesn't want to be engaged with

Question 4
Mechanisms for reaching the community at large (for example participation
techniques, information dissemination techniques)

8.1 SOLUTIONS TO QUESTIONS POSED

QUESTION 1
How to ensure that any feedback or comments received at any stage of the consultation process are fed back into the air quality management process.

The following activities and techniques were suggested:

  • good record keeping;
  • filter replies and responses;
  • provide a statement of public consultation;
  • independent administration of consultation process;
  • clear strategic approach;
  • allocate responsibilities for responding consultees;
  • keep it simple;
  • categorise information received, use a log-in system;
  • criteria;ensure you can use data in future stages of the consultation process.

QUESTION 2
Identify ways of consulting with the public at the different stages of the air quality management process.

Early stage: mail shot to statutory consultees and other interested parties; use of the DETR video; use of local media and other events going on in the area; posters and liveries, web site.

Intermediate stage: letters to early stage respondents, followed by a public meeting, exhibitions, piggy-backing other events and activities, CTTEC Reports.

The following issues were identified as being important for effective communication:

  • Make public consultees aware of outcomes from consultation exercises;
  • Use simple, jargon free language to convey message;
  • Make the information 'attention grabbing', using free weekly newspapers and a web site to inform;
  • Provide information to the local schools in the area.

QUESTION 3
How to engage with a sector or consultee which doesn't want to be engaged with.

  • produce a clear consultation strategy;
  • Use timetables for consultation (documents deadlines, reminder deadlines, letters confirming they do not wish to be involved);
  • Highlight to individuals the concerns relating to air quality;
  • Use appropriate language.

A local authority needs to 'sell' the initiative to them, and so highlighting the benefits to be had with encouraging people out of their cars (particularly in relation to health benefits) is effective, together with suggesting alternatives. If they don't want to comply, then warn them of the potential restrictions. If the consultees chooses to ignore their requested involvement, warn them of the consequences of not being involved in the management process.

QUESTION 4
Mechanisms for reaching the community at large (for example participation techniques, information dissemination techniques)

  • Council newspapers, tenants newsletters, Local Agenda 21 newsletters;
  • Satellite centres, advice centres, medical centres;
  • newspaper supplements;
  • local radio and the media;
  • libraries and schools;
  • internet;
  • road shows;
  • Parish Council meetings, Joint Liaison meetings;
  • Local Parish church groups, local pressure groups;
  • alternative fuel cars - test drives;
  • back of parking tickets;
  • back of buses;
  • parents evenings;
  • public information leaflets;
  • Citizens Panel;
  • use Local Agenda 21 one-stop-shop
  • video Boxes

The need to target the message was emphasised, together with the fact that there are so many forums and consultation processes underway, that there is danger of 'death by consultation' and 'forum fatigue'.

8.2 CONSULTATION STRATEGY MODELS

In the second half of the workshop, delegates were provided with a flow diagram to illustrate the process of air quality management and corresponding stages of consultation (appendix 5, courtesy of Mott Macdonald, 1998).

Using the flow diagram, the workshop groups were asked to prepare a model consultation plan, considering the different stages of the consultation process in turn, with regard to the consultees, techniques for consultation and the time-scales involved. Three models were produced.
 
MODEL 1
The first model involved a three-stage approach, with the second stage divided into two parts.

The first stage of the consultation process (November 1998) requires an informative mail shot to all statutory consultees and other interested parties. During this first stage, use is made of the DETR produced video to highlight issues, together with the local press and other events taking place within the authority (piggy backing). Posters and liveries are to be devised and used at this stage, and the intranet and internet used to disseminate information.

Stage two involves two parts. The first part, part one (January 1999) requires correspondence to all respondents to the first consultation stage. Part two (March 1999) then consists of a public meeting with subsequent exhibitions staged in the locality, and piggy-backing of other local events and activities. The process concludes with a final stage three (April or May 1999), when the emphasis is placed upon consultation in respect of potential hot spots discovered in the course of undertaking reviews and assessments, and also specific industries in the locality.

MODEL 2
A three-stage approach to consultation is also adopted by the second model proposed.

The first stage involves priming the statutory consultees about the air quality management process through a written, detailed letter and follow-up responses to any comments received are subsequently written. This stage of the process is anticipated to take one year.

Stage two involves the same set of statutory consultees (taken from the Framework for Review and Assessment of Air Quality Guidance (LAQM.G1(97) section 4.12), together with transport user groups and providers, and sectors giving rise to potential air quality concerns, for example quarry operators. They are informed of the air quality management process underway, an invited to respond.

The public is brought into stage three of the process, to include resident groups, focus groups and also local Councillors. Schools and libraries are important locations for distributing information relevant to the process of air quality management. Feedback is once again invited.

MODEL 3
The third model incorporates a preliminary stage of information provision.

The preliminary stage is considered necessary prior to embarking on the formal first stage of the consultation process. At this stage potential partners are identified, and potential partnerships built for taking the process forward. This preliminary stage also sees general information on air quality disseminated to the public at large.

Following this, the first stage of the process starts with a document distributed to all statutory consultees, residence groups and Parish Councils. A leaflet or newsletter article with council tax bills may be a useful mechanism for getting the information across.

Stage 2 sees a more targeted approach, with a full, comprehensive report disseminated to Parish Councils, residence groups in affected areas, and statutory consultees. The DETR is sent a copy of reports from all stages of the process.

Information is finally distributed to schools and education establishments, together with pressure groups and non-statutory bodies, for example the local emergency services in the local authority and region.


9. CONCLUSIONS

Consultation must be clear and transparent if the consultees are to value the exercise, invest their time and energy in a response, and are to be seen to deliver an outcome. Experiences show that in order for the process to be useful for air quality management, information needs to be conveyed in a simple manner, using familiar language for a non-technical audience. Proposed action plans and the designation of air quality management areas will require the local authority to correspond with a wide spectrum of businesses, community groups and public bodies, and so a system for coping with a subsequent wide range of responses must be developed at the very earliest stage possible.

The variety of techniques for consulting with specific consultees and indeed the public, described by the speakers today, illustrate the scope for involving consultees and ensuring their interest and participation in the process. The opportunity for input and engagement in the interchange of ideas encourages stewardship of a consultation process. This was demonstrated in the community projects developed as part of Local Agenda 21 process, where the community consultation was interactive and thereby effective.

Participants expressed concerns about consulting on air quality management, ranging from the sheer volume of correspondence envisaged, to the effective management of extreme views and a potential lack of tolerance towards actions proposed. Whether the officers undertaking the technical aspects of air quality management are the most effective and best placed to manage the consultation process itself raises a further question, which can only be answered by individual authorities themselves.

Local governance is itself a problem in consulting on the issue of air quality management. Co-operation between departments and divisions of councils is imperative, and will ensure that all available mechanisms for consensus-building are utilised, and knowledge and experience across the authority incorporated into the process. With air quality being a likely sustainability indicator for most authorities, the use of Local Agenda 21 networks for consultation exercises is appropriate for many authorities. Likewise, the ability for neighbouring authorities to recognise the savings to be made in working collaboratively and consistently will ensure the deliverance of effective air quality management.


10. REFERENCES

Consultation for Local Air Quality Management; NSCA. Clean Air, vol. 28, No. 5.

Modern Local Government: In Touch with the People; Government White Paper. Royal Commission on Environmental Pollution, 21st Report on Setting Environmental Standards (October 1998).

Beyond Compromise; John Baines; available from the Environment Council, 212 High Holborn, London, WC1V 1VW.

A Methodology for Community Involvement in LEAPs; The Environment Agency’s R&D Report; Baker Associates (£35); available from the Environment Agency R&D Dissemination Centre, c/o WRc, Frankland Road, Swindon, SN5 8YF (telephone 01793 511711)

Participation Works; New Economics Foundation (£7.00 or £25 for 5); available from First Floor Vine Court, 112-116 Whitechapel Road , London E1 1JE (telephone 0171 3775696).

The Guide to Effective Participation; D. Wilcox (£9.95); available from Partnership, 13 Pelham Square, Brighton, BN1 4ET (1994).

Citizen Involvement; P. Beresford and S. Croft (Macmillan, London) (1993).

Collaborative Planning; Professor Patsy Healey (Macmillan, Basingstoke) (1997).

Community Involvement in Planning and Development; BDOR Ltd., Department of the Environment; available from The Stationary Office (1994).

Creating Involvement; L. Hart; available from the Local Government Management Board, Layden House, Turnmill Street, London, EC1M 5QU (1995).

Involving Communities in Urban and Rural Regeneration; Department of Environment, Transport and the Regions; available from The Stationary Office (1997).

Framework for review and assessment of air quality. Local Air Quality Management, LAQM.G1 (97), December 1997.

The Environment Act 1995. Chapter 25, Schedule 11. HMSO (1995).


APPENDICES

APPENDIX 1     Consultation for Local Air Quality Management; National Society for Clean Air and Environmental Protection

APPENDIX 2     Bristol City Council: Sustainable City Team project leaflet on the development of the Health Park in Knowle                           West.

APPENDIX 3     Local Environment Agency Plans (LEAPS) for England and Wales.

APPENDIX 4     Bristol City Council: Air quality management consultation leaflet and web site.

APPENDIX 5     Air quality management process: flow diagram (Courtesy of Mott Macdonald, 1998)


ACKNOWLEDGMENTS

The Air Quality Management Resource Centre wishes to express its gratitude to all of the speakers who took part in the Consultation Workshop, and who provided materials for this report. The conclusions drawn from the workshop are the views of the editorial team, and may not necessarily reflect the views and concerns of individual speakers, delegates or authorities represented at the workshop.


Copyright © 2002 by Air Quality Management Resource Centre, FAS, University of the West of England, Frenchay Campus, Coldharbour Lane, Bristol, BS16 1QY. All rights reserved.
Lasted up dated: 01/02/06.