MEPG and the Consultation questionnaire

We should be being consulted on the draft Bill, not a subsidiary document which only contains a small portion of what is in the Bill. The 2019 Consultation results cannot be considered as the responses were for something completely different, were not validated and MHT analysed their own data.

MHT have an annual income of just over £1m per annum of which 61% is through taxation of the levy payers within Malvern. The levy is their only permanent and guaranteed source of income annually. MHT is therefore bound by Public Law obligations so that confidence in public bodies is not eroded.

‘A Public Body is a formally established organisation that is (at least in part) publicly funded to deliver a public service’ (Cabinet Office definition)

As a Public Body, MHT is duty bound to follow the Public Consultation Guidelines for a public body.

This requires a Consultation to run for at least 12 weeks, and at a formative stage of its proposals. Given that the majority of the provisions for the Private Bill were submitted to the Parliamentary Agent for drafting some months ago, this Consultation is hardly being held at a formative stage of its proposals. It is therefore difficult to see how any responses to a Consultation could genuinely have any impact on the contents of the Bill.

Any Consultation questionnaire according to Public Consultation guidelines should ensure that information to stakeholders is clear, concise, in an easily understandable format and uses plain language. The questionnaire we are being asked to complete is none of those things. It is therefore not fit for purpose.

A democratic process is laid down in the Consultation guidelines for Public Bodies which is NOT being followed. The public of Malvern deserve to see the full draft of the Bill.

There is a total lack of transparency and accountability about the contents of the Private Bill.

With a General Election having been called, Public Bodies are requested to suspend all activities which compete with the attention of the Public. (ie. Purdah).