- No Community Consultation has taken place.
(a) The only community engagement exercise carried out by the council was billed as a survey to find out what people wanted. It comprised one public event, held almost two years ago and a web survey.
(b) The web survey was hosted on the “Survey Monkey” website not the Fife Council Consultation website.
(c) The Fife Council Consultation website hosts all Fife Council consultations at: https://online.fifedirect.org.uk/consult/index.cfm?fuseaction=consult.diary
(d) The general information on the Council website regarding consultations states that “If we’re thinking of changing something that directly affects you, we’ll contact you”
(e) There are many historic and current consultations listed on the Fife Council consultation website, but no evidence that a Lade Braes consultation was ever listed there and no contact made to directly affected people.
(f) A specific letter drop to residents of the Hepburn Gardens as near neighbours of the proposals, inviting comment on the proposed changes to Lade Braes Walk was agreed at a meeting of the Fife Council Lade Braes Project Group on 19th September 2019, but never carried out.
(g) The results of the survey have never been reported on to members of the community.
(h) The detailed proposals resulting from the survey have never been consulted on with the public.
- The Quality, Fairness and Transparency of the Council’s Community Engagement process have multiple problems.
(i) The Community Engagement standards set by Sustrans’s in its Partner Responsibilities Document (Project Pack v1.0, 28/08/2019) and Community Engagement Guidance provided as an annexe to this document failed to be to met by Fife Council on multiple grounds. The flawed consultation process also breaches Scottish Government and Scottish Land Commission standards.
(j) At the public event held in the St Andrews Library on15th August 2018,Fife Council officials stated in response to questions that the improvements to the path were not designed to facilitate cycling. It has since become obvious that encouraging more cycling use on the Lade Braes footpath and linking it with the National Cycling network, to encourage more cycle traffic is an integral part of the scheme being proposed. (See Paragraph (z).
k) The survey / ”consultation” did not give alternatives, only a pre-conceived scheme, and did not for instance offer an option to retain the status quo with an improved surface, and/or an alternative cycle route following and extending the route of the existing core path on the south side of the Kinness Burn as recommended by the Fife Council Local Access Forum, and noted as a option worth investigating in a committee report on an abandoned multi-user path proposal in 2007.
(l) There is clear evidence from Council internal email correspondence obtained through an FOI request that Council officials were concerned that safety issues on Lade Braes Walk between Bridge Street and Cockshaugh Park, evidenced in a Safety Review by CSARA, could compromise their funding bid to Sustrans. The Safety Review, showed that this part of the path was not suitable for cycle traffic on multiple counts as it did not meet the required Scottish Government standards for a shared use path. A meeting between CSARA and the Council was agreed to discuss these safety issues but reneged on by the Council shortly after the email exchange noted above.
(m) The findings of the CSARA Safety Review were subsequently confirmed without reservation by an independent Safety Audit carried out to professional standards, by Wyllie Lodge, road specialist road safety consultants, in December 2019, at the request of Fife Council Planning Service.
(n) There is a specific requirement in the Lade Braes Path funding application process (Sustrans project pack v1.0, Category 2) to assess spur links into the parkland section of Lade Braes Walk for suitability and safety The populated part of Lade Braes Walk is the busiest feeder route to the parkland section of Lade Braes Walk but was not assessed. Its omission from the list of links included in this assessment, and Fife Council’s unwillingness to engage with residents of this part of Lade Braes to discuss safety issues there, reinforces a view that its omission was intended to avoid compromising the Council’s funding application to Sustrans. These issues which were well known to the Council and which remained unresolved were not reported to the Council Committee that approved the Council expenditure for the proposed path project.
(p) The North East Area Fife Area Committee, which approved the expenditure of, Common Good Funds for the Lade Braes Project (misleadingly described as “upgrade to the footpath” in the committee report) was not consulted on the outcome of the survey, which by this time had morphed into a “consultation”. This is most unusual.
(q) The process described as a consultation was in fact essentially a referendum, as in the report to committee, great emphasis was placed on numbers supporting or not supporting the scheme, and detailed submissions by several organisations and individuals were largely ignored.
(r) The provenance of responders to the Survey/”Consultation”, and which outcomes various interest favoured, or even whether some persons made multiple submissions, cannot be ascertained as this data has not been produced by Fife Council despite multiple requests for it from the Council. Consequently, the community engagement process does not meet the required standard for transparency. The Council states that this information does not exist.
(s) Following the survey /” consultation”, Sustrans proposed to Fife Council an exercise to identify people who might be disadvantaged or unhappy about the scheme so that they could be offered an opportunity to discuss concerns. This proposal was thwarted as Fife Council did not or could not provide details of individual responses to the proposals, but instead provided only aggregate information, which was useless for this purpose.
(t) The Sustrans/Fife Council Lade Braes Communication Plan, dated April 2019, part of the grant letter from Sustrans to Fife Council includes a requirement, under the title “Project Objectives and Scope of Work”, “to Increase accessibility and use of the National Cycle network”. Nowhere has it been publicised or consulted on that the Lade Braes footpath would become part of a long distance cycle route. This is an intention that should have been upfront from the beginning of the process so that people responding to the scheme could make an informed decision. It is not acceptable to introduce this issue to the public at a later stage if that is the intention. Access to the National Cycle Network will be a two way process, with St Andrews a desirable destination from many parts of the country. If implemented, this would transform Lade Braes Walk from a quiet woodland walk into a busy and fast cycle route with many cyclists travelling in groups.
(u) The Monitoring and Evaluation Plan in the same document notes that a criterion for success of the project is increased use of the National Cycle Network and connecting paths. The Fife Council committee deciding the Council funding for this scheme was provided with a list of desired outcomes for the project, which differed from that in the Sustrans’ grant document by omitting this cardinal fact – a condition of Sustrans funding, – that it would link with the National Cycle Network and introduce long distance cyclists who generally travel at speed, to Lade Braes Walk.
(v) FOI documents note that a consultation on the finalised scheme when – the draft plans were available – was intended, but this intention was rescinded. Sustrans’s community engagement standards state that the community has to be consulted at every stage of the process. This did not happen.
(w) It is clear that the widening of the footpath and removing bends on the parkland section of Lade Braes is to accommodate cyclists but it would nevertheless fail to meet minimum standards laid down in “Cycling by Design” for shared use paths It is even more sub-standard when Sustrans own standards are applied.
(x) Because of the failure to consult the public on the final scheme, members of the community are not aware of the detail of these proposals, and will not for instance, be aware that bends are proposed be straightened, trees removed to facilitate this and lighting installed – issues which will seriously affect the natural environment of Lade Braes and reduce its attraction for walkers, as will increased cycle traffic.
(y)The fact that the Lade Braes walk has been designated as part of the pilgrim Route to St Andrews, resulting in large groups of people moving along it, has not been taken into consideration in the proposals for the Lade Braes which are nearly two years old. The path as proposed fails to meet the minimum Government standards for shared use paths, especially those accommodating faster long distance cyclists. Sustrans’s own standards for shared use paths for groups of walkers, such as those on the Pilgrim Path are more stringent and fail to meet the required standards even more significantly.
(z) A choice given to responders of the Survey /”Consultation” was whether or not they thought the route could be suitable for cycling if improved. The people choosing this option could not be aware of the long-distance cycling being proposed, or the environmental cost of these “improvements”. The Community have not subsequently been consulted on the finalised scheme, its safety, and its impact on the natural environment. Choices made at the initial survey stage cannot not be regarded as realistic or informed given the inaccurate and incomplete information provided to the public at that time.
It is not possible to progress genuine consultations if full and frank information on the proposals is not available at the outset, or to add to or change critical aspects of the proposal and regard earlier opinions expressed as still being relevant.
That is why a consultation on the finalised scheme is necessary now, and even more so because of the very significant failings in the community engagement process which has been evidenced above.
CSARA
01/07/2020