Memorandum by the Welsh Streets Home Group
(WSHG) (LGC 18)
The Welsh Streets Home Group (WSHG) is a residents
organisation from Toxteth in Liverpool 8. We are writing to the
ODPM committee Local Government Consultation New Inquiry. We welcome
this inquiry which seems timely in terms of the national debates
around sustainable planning as well as hugely relevant to our
local situation.
We would like to present observations as highly
relevant to this committee and it's remit. We are not only a Pathfinder
area but subject to a high concentration of Urban Strategies.
The additional impact of the dual cultural accolades of City of
Culture and Unesco World Heritage Site in directing local authority
priorities has been felt keenly by the population particularly
in the urban heart of the city. As such our area is becoming a
crucible for policies and programmes who's success or failure
may pivot on the quality and status of public consultation. Thus
we feel our evidence should rightly inform this inquiry. It is
important to note that while highly critical about the way in
which public consultation is being delivered in our neighbourhood,
in particular the lack of relevant skills, resources or knowledge
amongst local government agencies, that the local authority is
working in partnership with the private sector and others. Since
this is often going to be the case we feel our experiences can
highlight areas for immediate action.
In particular WSHG would like to urgently request
training and resources for local government staff, and further
suggest stringent checks and balances need to be enforced to ensure
a voice for all concerned. The process we are currently witnessing
threatens to divide communities, manipulate evidence and produce
flawed results. It may not be wise for local authorities or their
partners to participate directly in the consultation process,
but preferable for independent consultancies to engage with the
public, that is if local views are genuinely sought and valued.
What follows is based on 10 months of detailed
consultation with key stakeholders, expert advisors and developers.
SUMMARY/RECOMMENDATIONS
(A) Access to the process of public consultation
needs to be widely available to as many kinds of people, in as
many ways possible for as long as possible.
(B) The process employed should not discount
or ignore contributors on account of their views.
(C) Those with vested interests in the outcomes
of the public consultation in question should refrain from delivering,
managing or assessing the process themselves.
(D) Particularly where housing is concerned
protagonists should be aware of the unique stresses associated
with threats to the home and attempt to be flexible and creative
in finding solutions of most benefit to most people.
(E) The criteria for funding schemes should
allow flexibility enabling responsive finance solutions to be
matched to situations. The manipulation of situations to match
outmoded policy ideas and finance criteria is unlikely to go unchallenged
which will merely result in delay and expense.
ABOUT WSHG AND
THIS SUBMISSION
1. The Welsh Streets Housing Group (WSHG)
is a resident group reflecting on arising from public consultation
around the redevelopment proposal being offered to the Welsh Streets
that sit within a Liverpool Pathfinder area.
2. This evidence presented in this submission
is based upon our direct experiences of this consultation process
and, as such, is highly relevant to the scope and remit of the
committee.
3. As residents, we believe we have invaluable
insights into and knowledge of the social, economic, environmental
and cultural value and potential of our district in ways which
extend beyond viewing it simply in terms of land values. In line
with Government planning policy and guidance, we also see residents'
needs and aspirations as being of equal if not greater importance
to those of the majority landowner in the area, the registered
social landlord (RSL), CDS Housing.
WHO AND
WHERE
4. We are reporting our experience of a
public consultation in which Liverpool City Council are the local
authority and the task in question is the delivery of a Pathfinder
Housing Market Renewal.
5. Include, Liverpool City Council, WDC
steering group and Gleeson's Developers jointly claim ownership
of the current and only proposal for demolition of 400 homes in
the Welsh Streets area. Responsibility and motivating rationale
for the proposal remains obscure.
6. The regeneration company "Include"
are a key participant and they are comprised of Liverpool City
Council with a registered social landlord CDS housing. Three city
councillors participate as board or steering group members for
Include. The high density of local authority involvement in the
scheme has lead to concerns that as the architects of the consultation
process they have sought merely to endorse their own intent, and
have no interest or use for the views of the public they have
consulted with.
7. Lack of access to decision making processes,
refusal to negotiate or explain decisions taken, or to reveal
who the decision makers are or what they are guided by further
reinforces this view and implies that independent agents are needed
in the consultation process if a range of agendas are to be allowed
to come to light.
8. In addition local authority officers,
elected representatives and residents need access to the skill
set which will allow then to recognise the scope and limitations
of public consultation.
9. A confusing combination of staff from
the partnering organisations delivered aspects of the public face
of the pathfinder scheme. Conflicting information has been provided
by partner organisations who often having scant awareness of each
others activities. This has lead to frustration and a loss of
trust in proceedings.
10. New forms of public/private partnerships
demand new forms of scrutiny if individuals are to be protected
from the imposition of flawed outcomes due to the excessive power
bases such partnerships produce.
11. The impact of organisational differences
and lack of parity between a small group of residents in an advice
centre, a commercial concern such as a property developer administrations
such as a local authority or a quango and a large land owner and
service provider such as CDS Housing appear to have reduced the
accountability which any of the above might normally be restrained
by in any of their activities.
12. Liverpool City Council are commonly
cited as the organisation who are defining the course of the project.
However when criticital view have been expressed for example in
the national press the Local Authority assign responsibility to
other organisations notably National Government or New Heartlands.
13. We have assumed, despite the lack of
clear information from Liverpool City Council, Include or WDC
steering group that New Heartlands are the managing body for the
process to which we are subjected. We understand that the board
of directors for New Heartlands comprises largely if not entirely
of Liverpool City Councillors.
14. Thus it has been concluded that this
is an instance of public consultation in Local Government and
note that the various and complex ways in which the local authority
are operating in this arena makes their role obscure, and on occasion
at odds with the best interests of residents or the built environment.
15. It is argued that Liverpool City Council
through their various agencies and partnership organisations used
an inappropriate organisation and venue for the main thrust of
the public consultation activity. The local authority along with
it's partners which included a small number of "the public"
essentially produced a regeneration proposal in private, announcing
periodically but often ineffectively in public that this was taking
place.
PUBLIC ACCESS
TO A
PRIVATE ACTIVITY
14. An existing tenants organisation had
extended into being a residents association on the sale of stock
to tenants through the right to buy scheme. Windemere Dovetail
and Camelot are names of three little districts, adjacent to an
area of streets with largely Welsh names now know as "the
clearance zone".
15. The three areas had a combined housing
office in a building owned by CDS housing on the corner of High
Park Street. Known as WDC this was to become the "private"
group amongst which apparently information was distributed and
decisions were taken. Because this took place in an essentially
private arena it is impossible to know where certain ideas and
assertions of dubious merit have arisen.
16. Many residents in the clearance zone
have had no previous relationship with the WDC office or it's
residents association, prior to the regeneration scheme.
17. This is because it did not provide across
the board services or resources to residents throughout the wider
area.
18. In particular owner occupiers, tenants
of private landlords, private landlords and peoples who's daily
route did not pass the WDC office were barely aware of it's existence.
19. It now seems likely that the WDC residents
association were involved in discussions with Include for some
time before the general public became aware they were living in
a redevelopment area.
20. It may be said that the interests of
those facilitators of the process were represented disproportionately
in relationship to the public whom the process might have been
intended to hear. For example CDS provided space in their building
for the WDC tenants and residents group making it difficult to
see how they could operate independently from their provider,
Liverpool City Council provided access to public funds, Gleesons
developers to Private funds etc. It is difficult to see how the
combined forces of these large organisations could have offered
a range of real choices to the WDC steering group.
21. It now seems likely that that WDC themselves
they were in contact only or mainly with those residents who have
regularly used their services.
22. Delivery of information lacked vigour.
Radio and broadcast media, local press and local resource centres
such as doctors surgeries, libraries were not exploited in the
delivery of information to the public. Limited strategies were
applied to communicating with a wider audience or attracting participation
from poorly representative groups.
THE CONSULTATION
PROCESS
23. Issues surrounding the accountability
and representativeness of the views of street representatives
remain highly problematic. The street representatives apparently
function within the realm of WDC tenants and residents (association).
The current proposal has been informed by a steering group of
street representatives who have worked with Include personnel,
Gleessons Developers, Triangle Architects and local Councillor
Alan Dean. However, research shows that a significant number of
residents do not know who their street representative is, suggesting
that the views of many people are not being articulated through
this consultation process.i There is also no mechanism in place
to check whether the personal viewpoints of street representatives
accord with or differ from members of the wider resident population.
Further lack of representation or access to communications arises
because several streets are without street representatives. Others
have had a street representative only very late on in the consultation,
too late apparently for their views to be incorporated. On at
least one occasion, a street representative has been instructed
to leave the steering group because the view of her street differed
from those of the steering committee. On another it is felt that
a street representative was treated so rudely for expressing the
views of his street that he withdrew from the process.
24. Public consultation meetings have not
been inclusive. The three Include Public Vision meetings held
prior to 25 March 2004 in effect excluded a significant number
of residents, particularly working people and those with young
children.
25. Delivery of information lacked vigour
and imagination. Radio and broadcast media, local press and local
resource centres such as doctors surgeries, libraries were not
exploited in the delivery of information to the public. Residents
who's routes did not take them towards high park street were unlikely
to see notices posted in shop windows or WDC offices.
26. Inappropriate means of communication
have been employed. The printed newsletters delivered by volunteers
though letter boxes may have been widely criticised as having
failed to communicate the serious intent of the partner organisations.
27. Research shows that the WDC (The tenants
and residents association for Windermere, Dovetail and Camelot
estates) newsletters were not read by all residents. Their design
quality and the fact they were not in envelopes did not allow
them to be differentiated to other unsolicited leaflets. In some
cases, interviews show that the leaflets were perceived as junk
mail. Some residents are adamant they never received these, or
received them sporadically. Their relevance to people living in
the nearby Welsh Streets was not clear particularly to residents
who had never been tenant of CDS. Residents often received some
but not all of the newsletters, which it transpires, contained
key information regarding the regeneration plans. It also appears
that Chrome, who conducted the Welsh Streets Neighbourhood Survey
in 2002, did not write to or survey all households.
28. The proposals failed to take on board
fundamentally important findings from the consultation process,
thus bringing into question the validity of the consultation process
and proposals as a whole. The proposal presented on 25 March 2004
bears little relationship in its technical content to the ideas,
which were set out and agreed upon by residents who attended the
three preceding Include public vision events. In particular and
crucially, at these consultation events the favoured option was
extensive refurbishment and demolition only of un-sound property.
Subsequent WDC forum meetings have not accommodated residents'
desire for and commitment to refurbishment, despite commitments
to conservation-lead development set out in various policy and
strategic planning documents produced by Liverpool City Council
and Central Government. ii
29. The proposal presents an unhelpfully
unbalanced appraisal of potential options, failing to present
the full range of viable options and relevant supporting evidence
in an accurate and fair way. For instance, the view that South
Street is a "rat run" and the garage workshops "a
liability" is not supported by evidence nor is it a view
widely held by local residents or visitors to the area. Information
regarding the value and condition of trees and energy efficiency
is misleading and, in cases, inaccurate. Discussion of potential
problems associated with new build property, such as resource
energy for construction, are entirely absent. Private owners are
described as a problem although there is no evidence to support
this.
30. There appears to be no formal method
of recording feedback or filtering resident comments upwards through
Include to inform decision making in a constructive and democratic
way. As one important example, following 25 March 2004 Include
informed residents that "this is just a proposal" and
that responses to it would inform the development of a final plan.
Residents have attempted to make feedback to Include via drop
in sessions at the WDC office but, as noted above, there is no
evidence of such feedback being registered or incorporated into
revised proposals. This lack of access to the decision making
process renders the validity of the public consultation exercises
highly questionable.
31. Communication from different agencies
to local residents has been confusing and conflicting. As late
as 28 July 2004 it was stated by a panel of WDC, LCC and Gleessons
that the existing proposal would not be subject to amendment following
public response, but instead was best viewed as a plan of action.
Prior to this date Include personnel had ensured residents that
their feedback would be used to inform the final plan. At the
WDC forum, LCC personnel stated that only if a judicial review
took place would there be any negotiation regards the proposal
despite residents desire to negotiate an acceptable plan immediately
in order to avoid the delays and expense incurred in a judicial
review.
32. There is evidence that residents and
who were critical of the communication process or the proposal
itself were verbally intimidated in public. Informed and reasoned
contributions to the regeneration proposal have been rejected.
Assertions from Include LCC and CDS that if the only proposal
was not accepted and supported the penalty would be no regeneration
and more empty homes, blight and decline. In the view of this
it is difficult to really know whether current survey results
reflect genuine support of fear of abandonment or ridicule.
As a result of this a sector of the community
has been demonised for failing to support the only proposal on
offer.
33. There is evidence to suggest that the
consultation process represents an ill-timed and token exercise.
Most significantly, many residents were "consulted"
after the proposal had been produced, as shown by the dates on
which people and buildings were surveyed.
34. The proposal fails to include consultation
findings of fundamental significance, bringing into question the
validity and viability of the scheme as a whole. Most notably,
the findings of the Chrome survey commissioned by Include in 2002
show that the majority of respondents were satisfied or very satisfied
with their existing homes. This finding is not reflected in the
proposal.
35. A subsequent survey published in the
Autumn 2004 lacked independence and it is alleged was not delivered
in accordance with market research protocols.
The local authority has in this instance delivered
a public consultation of limited effectiveness which strongly
encouraged participants to support the view and actions of the
local authority itself. As such it could be defined more as a
lobbying exercise than a public consultation.
TOO LITTLE
TOO LATE
36. It seems likely that the age range,
identity, financial status and cultural diversity of the residents
who regularly used the WDC service was severely limited.
37. WDC were unable to represent the whole
community living in the area initially described by Include as
Dingle South, but now apparently known as Princes Park nor would
it seem reasonable to expect an organisation of that size, scope
and remit to do so.
38. It would seem that the support, or training
provided by Include by either Include's components (ie LCC or
CDS Housing) to WDC essentially a small hard working, well motivated
self help community group of limited human resources was wilfully
or neglectfully inadequate.
39. The existence of the process was hidden
from particular types of residents such as those who work, tenants
of private landlords, or owner occupiers later lead to aggression
and conflict in the community. This conflict has been exacerbated
by the failure of the proposal and by implication of the consultative
process to identify and acknowledge key differences between different
types of housing stock and market potential in the area.
40. By the time the public at large were
beginning to understand the situation they were in, they were
told it was too late to contribute observations or ideas. Amendment
and compromise of the only proposal tabled remain untapped, but
it is hoped within the realm of possibilities.
41. It is clear that the great legal, and
financial power available to local authorities give them special
responsibilities with regard to the fair treatment of individual
citizens and communities.
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