Friday 2 November 2012

Better Late Than Never? Not much...

NCC's consultation exercise on its replacement for Council Tax Benefit is now over. As such, they now deem it safe to respond to the questions I asked at the consultation event I went to in Bulwell, as I can no longer use the info to come up with clever-arsed objections to their ideas.

Not that the info they've provided would have been much help. I'll reproduce it in full here;

"Dear Mr Platt,

Thank you for attending our recent information event on the changes to Council Tax Benefit. There were a few questions on the day that we couldn’t answer so please see below for our response as promised.

- You asked for the savings generated by each proposal. We are unable to provide the estimated savings generated by each individual proposal because the proposals are inter-dependant and will not show a true reflection of savings if treated separately. However, if we assume that all proposals in our draft scheme are applied then the savings generated would be:

Estimated savings generated



*An assumed collection rate of 70% has been being used in the calculation of the net savings figure.

- You asked what collection rate these figures were based on. Please see answer above.

- You asked to see the Equality Impact Assessment. A full EIA is not required at this stage as the scheme is still only a proposal and isn’t to change or introduce a new policy/service/function. Due regard to equality has been applied throughout the development of the proposed scheme and the consultation process itself forms part of the EIA. A full EIA will be completed to accompany the decision on the final design of the Council Tax Support Scheme following the period of consultation with all interested parties.

Nottingham City Council

Consultation Team"

There isn't really very much there is there? So why did that take a month to provide?

It's also fairly dodgy to claim that they couldn't provide the individual costings. I think it's disingenuous to claim that they are all interdependent. Yes, there may be diminishing returns as the cumulative effects of each change eventually knock individuals out of eligibility, preventing further provisions having any further effect in that individual case but this doesn't apply to all. In particular, the minimum 20% proposal can at least be partially calculated; I previously estimated that it would raise £3.5m from those currently receiving full CTB alone.

The confirmation of the expected 70% collection rate is also a red flag warning of the laws of diminishing returns. As this huge drop in collection rates is entirely attributable to the proposals, surely this demonstrates that some of the proposals are doing more harm than good?

This claim suggests that NCC simply grabbed together a random selection of cuts to apply and calculated the expected overall cost. This doesn't sound very strategic. Surely there must have been substitute calculations demonstrating effects of only including one of the provisions, or all except one etc? That would have given me some idea of the effects of each one.

As for the claim that no EIA has been carried out. All I can say is that's not what they said on the day. So why has the story changed? Is it that it's just in 'draft' form and showing us would give the impression that the proposals were a done deal and the consultation was a sham? Perish the thought...

This is deeply unsatisfactory. I still have an open FoI request, currently subject to review as they didn't answer my original request (not like them eh?) so hopefully this will produce more info. Failing that it's time for legal advice on possible judicial review and demanding the info via court production procedures.

It goes on...

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