Sheffield Bus Partnership

July 30, 2015

No, I’d never heard of it either, and I actually live in Sheffield.  But I noticed a pale sign on the bus that read


We’re improving Sheffield’s bus services.

Tell us what you think about our proposed new network in our public consultation from

6 July to

31 July 2015


Now, let’s take a moment to spot the weasels in that notice.  First of all, it was a pale blue notice with no graphics of any kind on it; nothing designed to catch the eye.  The text was white on blue, but the dates of the consultation were black and I had to look twice to see them.  The whole thing might as well have said “nothing interesting to look at here: move along please”

And we’re “improving” Sheffield’s bus services: so no need to worry your pretty little heads about it?

Tell us what you think about a “proposed new network”: sounds like something boring and bureaucratic that doesn’t have anything to do with you, probably.

Travelsouthyorkshire.com/sbp – not even a “for more details go to…”, just the web address.  Which, I might point out, is hardly helpful to people without net access.  Who tend to be older, poorer, less well educated than the average of the population.  (And, if we are to believe the ageist and classist quote, might align with the bus user demographic, if it’s really true that “A man who, beyond the age of 26, finds himself on a bus can count himself as a failure” attributed to Thatcher  Speaking as a regular bus user myself, I don’t think so…)  But my point is that the consultation itself is unlikely to reach the very people on whom it might have an impact.

Note also that the consultation is open for less than a month, and that Sheffield University’s 2014-15 session ended on 13th June – so all the students, another big bus user demographic, had already gone home.

Right then: let’s have a look at the actual consultation.

First thing to notice? Well, there are face to face drop in sessions – definitely following best practice there – but how is anyone supposed to know about them?

Secondly… well, where IS the consultation?  There isn’t a consultation document that I can find – nothing with a summary explaining what the rationale for change is, what changes are being proposed and what will be the likely impact.  Instead there are two leaflets; one for the north of the city and one for the south – what if your bus journey crosses this imaginary boundary?

Let’s have a look at the north first.

Your views are important and will be used to help us make sure the network offers the best travel options for the people in the city before it is introduced at the end of October 2015

OK, what’s wrong with that sentence?  If our views are important, why are they being sought only to confirm the changes before they are introduced? Isn’t best practice in consultation to consult only on things which you have the capacity to change?  If everyone emails in today saying these plans are awful, is there the capacity to pause the implementation date and re-think the plans?

Then there’s a map.  I can’t read it online (it’s either too small to pick out any of the detail, or else too detailed to pick out the overall picture.)

Then there is a table of individual route numbers and a brief note about the changes made to each.

The document for the south is identical: same rubric, different map, different table; full of helpful details like

20 Hemsworth – Norton Lees – Heeley – Lowfields – Sheffield – Burngreave – Northern General – Southey Green – Parson Cross – Ecclesfield: Revised route replacing 97/98 between City centre and Ecclesfield

20A 9A,18,20 See route details for 9A, 18, 20 — — — Service replaced by 9A/18/20

There is no overall document, no explanation of the rationale for the changes and their impacts.

How do you respond to the consultation?  The ONLY method offered is to complete a form, either online or on paper.  I had a look at the form.  Here it is.  Go on, have a look.  Now, I’m a better regulation specialist, and in my professional opinion that is NOT a consultation response document: it’s a consumer survey.

3.4 How much would you be willing to pay for a multi-operator ticket allowing you to use all buses?

5% more
10% more

(Yes, London friends, I know you manage to have an Oyster Card system you can use on buses and local trains and trams, and there are a billion journeys.  We in the sticks have two rival bus and tram companies who can’t manage to share ticketing revenue from, er, quite a lot less)

On a purely selfish basis I won’t be responding, as the only bus which I regularly use is “service unchanged”, and I don’t respond to marketing surveys.

But as an example of How Not To Do A Consultation?  I think I’ll be referring back to this quite a lot.



July 27, 2015

Don’t mind me; I seem to have reached the Grumpy Old Git stage of my convalescence.  This morning, for example, I thought I would read the Tax Assurance Commissioner’s new Annual Report – I know, I know, but there’s only so many episodes of Bargain Hunt and Time Team you can watch before your brain melts and dribbles out of your ears altogether.

Here it is: on gov.uk of course, on a page of “collections”, where the 2012-13, 2013-14 reports are collected along with the new one, for 2014-15.

Click on any of them, however, and you get the message that “This file may not be suitable for users of assistive technology”.  Now, wait a minute, wasn’t the government’s own website supposed to meet the government’s own standard for accessibility?  Why is the report a PDF document (which is a bugger to get to a reasonable size for comfortable reading) rather than HTML, which – as the government’s own Service Design Manual points out – is a more accessible option:

For written reports, the native format of the web (HTML) should be your default option. PDF can be an excellent display format, but without additional effort it can be inappropriate for users of screenreading software.

A pdf document should only be used where there is “no other option“:

HTML is quicker, easier and more widely usable/accessible than PDF, but where no other option is possible this PDF guidance should be followed.

I’m lucky enough not to require use of specialist software to read this document: I’m just pissed off that the text shows up on my laptop in a font too small for me to read comfortably without a lot of fiddling about, and that it took me a good ten minutes to find the control to increase the magnification.

But I wonder why there are so many HMRC and HMT documents which pop up as PDFs instead of HTLM.  Is there really “no other option”, or is there a default to seeking an easier life and not worrying about it till someone makes a fuss?

Answers on a postcard…


Have your say…?

July 22, 2015

“Have your say on the Finance Bill” is the headline on the Parliament website.  The Finance Bill went through its first and second readings in the Commons and is now to be scrutinised by the House of Commons Public Bill Committee.  Question for scholars: does anyone have an example of a Finance Bill being amended as a result of a submission to the scrutiny committee by a member of the public?


Here we go again: equality impact assessment

July 17, 2015

The Summer Budget OOTLAR (Overview Of Tax Legislation And Rates) contains 124 pages, including 110 of TIINs (Tax Information and Impact Notes). They are signed off (on page 12) by David Gauke as containing “a reasonable view of the costs, benefits and impacts of the measures”

No, bear with me, it’s important.

Remember 2010, when the Fawcett Society took a judicial review against the coalition’s “Emergency” Budget? Although they were denied permission (mainly, as I understand it, on the grounds that the Budget had been debated by Parliament by the time the judicial review proceedings were launched and, as any law student knows, Parliament trumps judges).  However the Treasury were pretty much caught with their trousers down as regards conducting equality impact assessment of budget measures and promised to do better in future.

One of the “doing better” changes was to include reporting on equality explicitly in the TIINs that accompany any changes.  The equalities impact field in the TIIN is the only guarantee we have that the Minister responsible for making the decision has had the question of the public sector equality duty put before him or her at the moment of decision.

In that light… David Gauke’s view of what is a “reasonable” view of the equality impact doesn’t have a great deal in common with my own, shall we say?

Take for example page 24 of OOTLAR where there is the table of impacts for the changes to personal allowances. In the equalities impact field there are figures showing clearly that there are more lower paid women than men and more higher paid men than women. The public sector duty in the equalities act requires the government to have due regard to the need to eliminate unlawful discrimination, advance equality of opportunity and foster good relations between those who share a protected characteristic and those who don’t. The equalities impact field of the TIIN is the government’s evidence it has done so: on this evidence it has noted the facts of inequality but given no consideration to advancement of opportunity.

Or look at page 27, which has the table of impacts for the reduction in corporation tax.  It is noted that by 2020-21 the change will give away an anticipated £2,475 million.  The equalities impact shows “changes to the CT rates affect corporate entities and therefore do not have equalities impacts” in spite of the fact that this single measure gives away an enormous chunk of the tax base, for an unquantified economic benefit of making the UK “more attractive as a destination to locate business activity.” They can probably get away with this, because the judicial review proceedings held that equality could be considered on a measure by measure basis rather than looking at the Budget as a whole.  But a bit of common sense and political nous might lead us to wonder whether that was a good decision, when consideration of whether a corporate tax cut is a priority over, say, tax credits for those in working poverty is left unaddressed.

Then there are the changes to inheritance tax: “the government has no evidence to suggest that the measure will have any significant adverse equalities impacts”. (p34) This is not the public sector equality duty and does not provide evidence that the government has paid “due regard” to the right issues. Does “due regard” require consideration of what evidence the government doesn’t have, but could reasonably acquire?

The “exploding head” moment for me came when I reached page 118: yes, the idea of HMRC having power of direct recovery from bank accounts is back!  And apparently “will not impact disproportionately on people with any of the legally protected characteristics” – so the government is confident it won’t be trying to take money directly from the bank accounts of people in mental distress or illness, are they?  We have been here before when HMRC thought they would only be using the power around 17,000 times a year and I suggested, well, in that case, why not limit the power so that it can ONLY be used 17,000 times a year?   So that they would have to prioritise the serious cases and not introduce mission creep.  And it would be used to recover debts from individuals, businesses and partnerships, so I suggested a three year trial of the power applying it only to non-natural persons, ie to companies and LLPs and the like, before they let it loose on the rest of us.  I observe that the current proposals are suggested to affect

 11,000 individuals (including self- employed taxpayers) and businesses a year.

And yet (look at the last field of the table of impacts) the power won’t affect small businesses?  I believe someone’s trousers are on fire.





July 16, 2015

I shouldn’t laugh, but I used to be the person in charge of project managing and proof-reading OOTLAR (the Overview of Tax Legislation and Rates) document.  I took voluntary redundancy, which of course implies that the post was abolished.  I’m not suggesting this means that no-one proof read OOTLAR for the Summer Budget but I had to laugh when I got to page 102 and found the fonts starting to wander.  The second paragraph of the impact on business for the reform of Vehicle Excise Duty is clearly in a different font than the rest of the document.  While I can’t of course say what happens inside 100 Parliament Street now, in my day that kind of error would have meant a last minute change to the document by the Treasury (because of course you couldn’t have HMRC and HMT – in the same building – being on the same computer system) .

What other last minute changes can we infer?  Well there’s a heinous page break at Insurance Premium Tax (pages 104-105) where the table of impacts loses its first two rows and becomes hard to read, and, oh look, there are the small and micro business impact and the monitoring and evaluation sections in the different font again.

My favourite one, though, is the table of impacts for the Simplification of HMRC debtor and creditor interest rates at pages 121-122 where the impacts are not quite blank but certainly empty of meaningful content.  Robust estimates of the exchequer impact are not available.  The measure is not expected to have any economic impacts.  There is no impact on individuals, households or families.  There are no equality impacts and a negligible impact on businesses and civil society organisations, no operational impact on HMRC and no other impacts.  Well why the bloody hell are you doing it in the first place then???  The point of a TIIN is supposed to be to explain what you are doing, why you are doing it at all, and why you are doing it in this particular way.  The policy rationale for this particular change is given in this lovely paragraph:

The measure ensures that rates of interest payable on tax-related debts to which HMRC is a party are all contained within tax legislation.  It also reduces the rates of interest on tax-related judgement debts owed by or to HMRC to an appropriate level given prevailing interest rates.

To which I respond: WFT?

(No, seriously, if you know why they introduced this one at all, please enlighten me in the comments!)



What it says on the TIIN (which never gets old, seriously)

July 8, 2015

I won’t say that calling them TIINs was motivated by the line, but I do remember we were talking for a while about what to call the new document that combined the newly-invented Tax Impact Assessment with the now obsolete Budget Notes, and someone’s joke about doing what it says on the TIIN came around the time we lighted on TIIN.

But if you found your way here after seeing my piece about TIINs in this week’s Taxation, can I also draw your attention to this entry, where I published the internal Treasury and HMRC instructions on preparation of TIINs after obtaining them via an FoI request?

At this point I usually say something scathing about the way the 64 pages of instructions on how to prepare and produce an Impact Assessment are in the public domain and isn’t it interesting/annoying/suspicious that the instructions on how to prepare a TIIN which performs the same function for tax changes are hidden from view.  Except suddenly I can’t find the instructions on how to prepare impact assessments any more either.  Have they just been quietly downgraded on the gov.uk site or is it my google-fu that’s letting me down?  But whatever the case, why can’t I find the old instructions on the National Archive site either?  <puts on tinfoil hat, retreats to bunker>


Austerity porn

June 23, 2015

I have been in hospital.  Five days, as it happened, instead of the scheduled one or two.  (Yes, thanks; it seems, fingers crossed, that I’m clear of the cancer now and just have to get over the op itself and go back for monitoring every few months)

So there was this moment early on when I was being held up by, I think, four nurses (I was on the really good drugs at that point, so I’m a bit hazy about the detail) and someone was doing unmentionably personal things for me, and I recall feeling it was very very important that the nurses should know where I was coming from.  I explained in a drug-induced haze that I wanted it to be very clearly understood that I thought it was an obscenity for MPs to award themselves a ten per cent pay rise when nurses such as themselves had been on the frozen-or-one-per-cent rule for so long.

I thought about that this morning, when the news story was all about foreign nurses perhaps having to return to their country of origin after six years if they weren’t earning more than £35k.

There’s a simple way round that.  Surely anyone who has been in nursing for six years ought to have progressed up the scale to £35k?  Reinstate increments.  Pay experienced nurses £35k minimum.  There.  Problem solved.

And another thing.  The idea that there need to be cuts in Working Tax Credits of £12bn or so out of a £30bn whole.  You know, that one I support.  It’s absurd that anyone in work should need to be supported by the taxpayer.  Work should pay.  Which means that employers should pay.  Which, surely, means the best way of cutting the welfare bill is to increase the minimum wage substantially, and then keep it topped up by inflation.  Which would transfer the burden of those WTC payments from the taxpayer to the employer, which is where they belong.  Isn’t anything else just, well, corporate welfare?


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