Smart council officers outsmart attempts to game consultations

Smart and tech savvy council officers are weeding out attempts by anti-active travel campaigners to game consultations.  Over the last couple of years, officers working for several councils have spotted attempts to corrupt consultation results such as false names, false addresses and multiple internet submissions from the same IP address. And officers are now taking steps to ensure consultation responses satisfy the Department for Transport’s statutory guidance that they should reflect the local population.   

This post pulls together reports where a few councils have reported the results of their officers’ work … and a few councils which don’t bother.

“Consultations are not referendums”

In July 2021, the Department for Transport issued updated statutory advice on implementing active travel measures to support transport during the pandemic.  In his cover letter, Transport Secretary Grant Shapps was clear that engagement must be managed honestly:

“Engagement, especially on schemes where there is public controversy, should use objective methods, such as professional polling to British Polling Council standards, to establish a truly representative picture of local views and to ensure that minority views do not dominate the discourse. Consultations are not referendums, however.”

The statutory advice was underwritten by a letter to all local authorities in England from Transport Minister Chris Heaton-Harris, which stated that councils which failed to let schemes bed in and which didn’t manage consultations properly would lose future department funding.

#Onesies, cabbies and Kippers

During the covid pandemic, and as councils have followed government instructions to advance active travel schemes, a loose coalition has sprung up of allegedly local “One” groups (#OneRoystonVasey), taxi drivers, and minor characters on the fringes of left and right-wing politics.   Some have got as far as raising significant sums to challenge councils in the courts – and subsequently losing as the courts confirm that councils’ plans and actions are lawful (e.g. Lambeth, Hackney and Chiswick where £45k didn’t get to a court hearing).  

Whether for or against a proposed scheme, all campaign groups will encourage their supporters to raise the visibility of consultations and petitions and ask people to respond.  But characteristic of the anti-active travel groups’ behaviours is the noise they make on social media and the targeting of councillors and transport authority officials with frequent abuse.

Battle-hardened council officers have wised up to the tactics and are now taking proactive steps to ensure consultations are kept straight.

London Borough of Hackney

In August 2020, LB Hackney published the results of a consultation about road safety and reduced traffic in Stoke Newington. (Consultation webpage with PDF decision documents). The council received c4800 responses to the consultation, with 70.6% (3380) of respondents against the proposals, and 28.2% (1350) in support.

When the council’s tech-savvy officers dug into the submissions, they identified 1059 opposition submissions as anomalies:

  • three IP addresses accounted for 404 submissions;
  • further 50 IP addresses accounted for 655 responses; and  
  • 535 also had illegitimate mailing addresses.

The officers did not identify any anomalous submissions supporting the changes. 

Hackney Council reviewed the consultation responses, balanced them against its rationale for the scheme, and in a lengthy decision paper decided to proceed with the scheme largely as proposed.

City of London re All-Change-At-Bank, taxis and PHVs

The City of London has been working on the “All Change at Bank” junction project for several years, incrementally working towards a situation where motorised traffic outside the Bank of England, Mansion House and Royal Exchange is minimised, and more space is given to people to enjoy the hub of the City.  With the exception of buses and cycles, motorised traffic is excluded from the junction Mon-Fri 7am-7pm.   This has been a bugbear of London’s taxi drivers.

In summer 2021, the City consulted on a new round of urban realm proposals such as widened pavements and filtered access to Threadneedle Street.  The results were published at the City’s Streets Sub-Ctte in Sept’21.

Half of the c3500 submissions came from people claiming to be taxi or PHV drivers and customers.   The City is very good at traffic monitoring and analysis, and reported that just 2% of all journeys before the pandemic to/ from/ within the Square Mile were by taxi or PHV (report, section 4).

The City’s officers reweighted the submissions.  The City decided to proceed with the proposals as planned.

Newcastle City Council

In early 2021, Newcastle City Council ran a consultation after filtering traffic across five bridges in August 2020 in response to the covid pandemic.  The council used several consultation platforms with the most of the activity on a commonplace website.  The commonplace platform allows users to give a thumbs-up agreement to other users’ comments which they agree with.

Carlton Reid wrote an article for Forbes describing the shenanigans uncovered during in the consultation, so I’ll give the highlights:

Newcastle City Council published an interim report with initial findings in March 2021, with further analysis and decisions planned later in the year.

London Borough of Lambeth

Lambeth Council uses the SurveyMonkey platform for its low traffic neighbourhood consultations.  Unlike Ealing Council (below), it requires users to register with names plus physical and email addresses.

Lambeth’s implementation of low traffic neighbourhoods during the pandemic has attracted a lot of noise.  The controlling Labour councillors have been targeted with abuse, the borough’s only Conservative councillor has tagged Onesie activists nationwide, and well-funded legal challenges against the LTNs have failed.

In December 2021, the council published the results of the Oval to Stockwell low traffic neighbourhood consultation.  The analysis was done by the council’s officers and with consultants from Systra.  It’s worth reading Appendix C of the consultation analysis (4mb pdf) which sets out in detail how officers and consultants weeded out fake and duplicate responses to the consultations, including:

  • 286 responses in the Oval LTN responses had been “entered in perfect alphabetical and chronological order, with identical formatting to the open-ended question asking for the first line of the respondents home address”;
  • Duplicate responses from the same IP address were scrutinised for cut-and-paste duplicate responses;
  • Questionable demographic responses were scrutinised e.g. “Aged 18-24, but ‘wholly retired’; Aged 65+ but apprentices”.
  • Multiple responses from the same individual (based on name & address), with officers aggregating comments into one response.
  • Update: 5th Jan’22: Cllr Danny Adilypour, whose council portfolio includes transport, shared more of the investigation into fake submissions e.g. “ 600 responses submitted one after another from 3am until 1pm on one day – around one a minute for ten hours straight, all with identical formatting” and “they had recorded these fake responses as being almost entirely from people whose ethnicity was not white and who identified as LGBTQ+.

Overall, 302 of the 3697 Oval LTN responses were removed, and 1,626 of the 4,554 Railton LTN responses were removed. 

Lambeth Council decided to take both low traffic neighbourhoods forward for permanent implementation with minor changes.

London Borough of Enfield

If you recall the statutory guidance cited earlier from the Department for Transport about “consultations are not referendums”, you’ll remember the bit about ensuring collated views are representative of the local population, and not unnaturally weighted.

On 31 Dec’21, Enfield Council published the results of the Bowes low traffic neighbourhood consultation (files PL2106 in this folder).  The long decision document sets out the comments received, data collected about various modes’ travel times, air quality etc.  The consultation analysis (appendix 8) is instructive in how council officers and consultants ITP (Integrated Transport Planning Ltd) compared the profile of respondees with census and data to ensure that the consultation reflected the make-up of the local community and that the equality impact assessment was fair (age, disability, gender, income, car ownership, religion …).  

Some insights:

  • 1756 responses from 1301 unique respondents to the online survey; 863 emails from 563 unique email addresses;
  • 18% of responses were from households indicating they earned over £100,000pa, disproportionate with the local population;
  • Car-owning households were over represented (86% of responses vs 68% of census data), non-car owning households under-represented (14% vs 32%);
  • Mismatch between age profile of respondees versus the local demographics, e.g. only 4% of respondees were under 29 versus making up 25% of the population.  Similar shortfalls among ethnic groups.

Enfield Council has decided to make the temporary scheme permanent with some tweaks.

Some councils didn’t manage consultations effectively, and some removed active travel schemes before consultations were complete, and lost DfT funding.

London Borough of Ealing

Like Lambeth Council, Ealing too used the SurveyMonkey platform to managed its consultations on low traffic neighbourhoods introduced during the pandemic.  Unlike Lambeth, Ealing didn’t require users to register, with the resulting consultation turned into a free-for-all.   Ealing Council removed the LTNs, and lost DfT funding.

London Borough of Wandsworth

Wandsworth Council removed its low traffic neighbourhoods while consultations were still running and, in one case, before the paint was even dry on its installation.   The council received a petition with 12,000 signatures started by an anonymous nom-de-guerre but made no attempt to verify any as local, and dipping into the petition large numbers of respondees weren’t local.  Wandsworth Council subsequently lost DfT funding.

Cambridgeshire County Council

Click through to this very detailed report by the Conservative Friends of Cycling on how CCC’s Mill Road bus gate consultation was gamed, and the results skewed.   The high level figures initially suggested at 52%/46%/2% oppose/support/don’t know split in the consultation results.  However, digging into the responses, the council did identify 623 duplicate responses, with 173 responses from just six IP/browser addresses.   Councillors ignored the shenanigans and voted to remove the bus gate.   The DfT stopped funding to the Peterborough and Cambridgeshire combined authority in the summer of 2021. The authority’s mayor gave assurances in Sept’21 consultations would be better managed and funds better spent, opening up opportunity for future DfT funding.

What smart officers are looking for

Gathering together the insights from Hackney, City of London, Lambeth and Newcastle, looks like savvy officers are looking for:

  • Multiple submissions from the same IP address – if there’s more than e.g. 10 submissions from one IP address is it a coffee shop, the local free-love commune … or a block of dodgy responses?
  • Submissions from IP addresses overseas or outside the local area;
  • Submissions from IP addresses on cloud computing platforms e.g. Amazon, Oracle etc. – why would you get submissions from virtual machines?
  • Contradictory answers e.g. 65yo, disabled, taxi-driving apprentices etc.
  • Unbalanced sectoral submissions e.g. disproportions of drivers, cycles, (dis)abled, young, old etc. when compared to local travel patterns and demographics;
  • Multiple submissions from same physical addresses;
  • False names and/or addresses, ranging from addresses which don’t exist, to cross-referencing a subset of names versus the local electoral roll.

Some councils have officers proactively checking petition and consultation submissions to ensure they are not being gamed.  Many councils are not, because they’re not tech savvy, lazy, directed by political masters not to bother, or just happy to turn a blind eye. 

Given the scale of attempting gaming going on, it may be time to start submitting FOI requests after major consultations asking what steps officers did take to verify submissions, and how what they learned influenced their recommendations.

(Post updated on 1 Jan’22 to include examples from Enfield Council and Cambridgeshire & Peterborough Combined Authority. Updated on 5 Jan’22 to include statement from Lambeth’s Cllr Danny Adilypour).

2 thoughts on “Smart council officers outsmart attempts to game consultations”

  1. What about changing your pale grey type on white background theme to something with greater contrast to make it as easy to read as other web pages. Your black font is #606060. The Guardian’s black font, chosen at random, is #121212, significantly darker. Thanks.


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