Local authorities are increasingly consulting residents on implementing policy that significantly affects their lives. Oxfordshire County Council alone has 31 open traffic consultations at the time of writing. Even a single consultation takes effort to read, understand and reply to, so each needs to be easy to understand for residents. With 31 consultations in progress and 37 traffic regulation orders completed this year and many more on the way, clarity and simplicity in consultation documents are essential if residents are to have a chance of understanding, responding and getting involved in local democracy.
Without this clarity and simplicity, responding to consultations can end up as the preserve of transport specialists, activists and pressure groups. Numbers depend on how many supporters each ‘side’ can mobilise rather than the views of ‘normal’ people.
OCC says on its consultations homepage:
Consultation documents need to be readable by anyone
The average reading age in the UK is 9 years old. The Sun newspaper is written for a reading age of 8 and its articles have a readability score of around 70-80 (using the Flesch Kincaid Reading Ease scale where the higher the score, the more readable the writing). Consultation documents, as public documents designed to get people to participate and reply, should be at least this readable.
How readable is the COTP consultation document?
Overall, the document scores 38.8 – post-graduate degree level and half as readable as it needs to be; in fact, about as readable as Nietzsche’s ‘Beyond Good and Evil‘. Individual sections were far less readable, with the Foreword scoring just 44, and one section scoring just 4.2 on the Flesch Kincaid Reading Ease measure. The document was just over 13.5k words (not including wording in diagrams and charts) – slightly longer than ‘The Strange Case of Dr. Jekyll and Mr. Hyde’.
The Executive Summary scored between 31 and 38 with the Equalities Impact Assessment coming in with a similar score.
The COTP document itself is objectively hard to read, appears to conceal controversial concepts behind jargon and euphemism (almost certainly unintentionally), is perhaps closer to a consultant’s report than a public document and, rather like this blog post, is probably too long for most people to engage with.
The COTP consultation
In November this year, Oxfordshire County Council’s ‘Fair Deal Alliance’ cabinet voted to ratify its consultation on the Central Oxford Transport Plan or COTP. There’s been plenty of press coverage and even more social media noise from both sides of the debate. To be fair, ‘debate’ is probably a polite term for what has increasingly become an exchange of vitriol between pro- and anti-COTP groups and the council itself. OCC has, extraordinarily, had to issue a defence of its decision as so many people have, apparently, misunderstood its contents. This lack of understanding in itself is concerning.
Some examples
“Intercepting car journeys closer to source where attractive sustainable travel options are available is a desired principle. It might therefore be the case that on some transit corridors, multiple transport hubs of varying scales are an appropriate response.”
This scores 29.5 on the Flesch Kincaid Reading Ease scale – around the same as Darwin’s ‘On the Origin of Species’.
“The Central Oxfordshire Travel Plan (COTP) sets out the transport strategy for the central Oxfordshire area from 2023 to 2040, with a focus over the period to 2032. It is part of a suite documents (sic) that sit under the Local Transport and Connectivity Plan (LTCP), which was adopted by Oxfordshire County Council in July 2022. COTP builds upon and replaces the current Oxford Transport Strategy (OTS), adopted in 2015.”
This scores 46 on the Flesch Kincaid Reading Ease scale – around the same as Milton’s Paradise Lost.
“Climate and emissions: Exceedance of legal emission levels and the need to rapidly reduce carbon emissions from all transport related activities.”
This scores 4.2 on the Flesch Kincaid Reading Ease scale – five times harder to read than the EU’s regulations on importing asparagus.
“Reducing the attractiveness of driving, through implementing travel demand management measures, requires that we also invest in improving the sustainable transport offer to simultaneously provide choice and make this more attractive.”
This scores 6.2 on the Flesch Kincaid Reading Ease scale – nearly three times harder to read than this explanation of epitaxy in gallium arsenide manufacture
Concealed meanings
The consultation relies heavily on local authority transport euphemisms. Many people won’t understand these. For example, try asking a few people on the street what ‘freight consolidation’ ‘modal filter’ ‘active travel’ ‘raised tables’ and ‘demand management’ mean.
It would be uncharitable to suggest this was a deliberate attempt to hide the meaning of potentially unpopular policies, but it may have had that effect.
- Demand management – making using a car unattractive
- Traffic filter – physical or virtual roadblock
- On-street car parking space is repurposed – parking spaces are removed
- Workplace Parking Levy – tax for parking at work
Impressive sounding phrases with little substance
The document contained extensive passages of ‘consultantese’; difficult to understand and adding little meaning. Just two examples:
“The plan identifies a series of actions to address current and future transport challenges facing the central Oxfordshire area, whilst developing a world-leading, innovative, inclusive and carbon neutral transport system.”
“This strategy is shaped by a number of defined outcomes. These outcomes represent a set of guiding transport and movement principles, which inform and run throughout the Strategy.”
Not only are these phrases hard to read, (they score 8.9 and 56.7 respectively), their practical meaning is hard to extract. Worse, material like this takes significant amounts of attention to read and so detracts from the overall usability of the document.
Jargon
As well as transport euphemisms, the document contains a high level of local transport jargon. Many public consultees will struggle to understand this. For example:
“Deliver a wayfinding scheme across central Oxfordshire’s active travel network.”
“Develop and support implementation of a local toolkit of transport interventions that support the 20-minute neighbourhood approach and work to the principles of the healthy streets approach.”
“Intercepting car journeys closer to source where attractive sustainable travel options are available is a desired principle. It might therefore be the case that on some transit corridors, multiple transport hubs of varying scales are an appropriate response.”
“In addition, a focus on localised junctions and side roads is equally important for improving safety, reinforcing hierarchy of user priority, and reinforcing the continuity of active travelroutes. We will continue to deliver side road entry treatments, continuous footway design treatments (Copenhagen Crossings) and raised tables across central Oxfordshire.”
Anyone who is not a local authority transport specialist or member of a transport pressure group is unlikely to understand language like this.
The Gunning Principles
Does this lack of readability and high reading age mean the consultation breached the Local Government Association’s Gunning Principles on Consultation?
“The information provided must relate to the consultation and must be available, accessible, and easily interpretable for consultees to provide an informed response”
Although the consultation was available and accessible, from a readability point of view it was arguably not easily interpretable for members of the public or non-transport specialists to provide an informed response.
Why does this matter?
Because OCC encouraged people in the county to respond to its consultation, it needed to be readable for anyone who picked it up, whatever their reading age, education level or familiarity with local government transport language. It also matters because the COTP consultation is likely to form the template for OCC’s transport consultation plans for the rest of the county affecting the way that thousands of people travel, work and live.
Before the next consultation, OCC needs to look at how it can produce a document that anyone can read, understand and respond to. At least, this needs to match the average reading age of the public.
MMC Musings 