​Early in September, Hastings District Council passed a resolution declaring the district a “GM-free” food producing area by banning the growing of products that may contain genetically modified material. This decision was greeted with cheers by those who believe there are commercial benefits from such a declaration.

Like decisions made by other councils around New Zealand, such as those involving the removal of fluoride from drinking water, this is another example of decision-makers being captured by emotions, prejudices or religious beliefs that are not backed by sound science.

The council has probably assumed that this decision will not cost ratepayers anything and unlock unrealised wealth for the district’s food producers. If such a scheme is to be credible and robust, then it should involve a rigorous testing regime imposed on all food products entering and leaving the Hastings District. After all, imported cotton, soy and canola products used and consumed in the Hastings District by people and farm animals probably already contain GM material. Some food growers may also decide to import and grow GM produce regardless of any local ban.

Banning the production of GM food products in this manner makes several assumptions. 

Firstly it assumes that GM food products are bad or harmful. There is no scientific evidence that suggests this. Indeed there is much credible evidence that shows that the human health impacts of GM foods are no different to the original products on which they are based. GM products also allow more, better quality foods to be grown on less land with fewer applied herbicides and pesticides, and lower carbon emissions. Some also have better drought tolerance – a feature that may be of interest to many Hastings district growers and farmers facing the rigours of climate change.

Secondly, it assumes that GM products and foods are somehow new and untested. While some plants modified using biotechnology may be new, there are conventional methods of genetically modifying plants, animals and micro-organisms which have existed for hundreds of years and not caused any harm to human health or to the environment. It is unclear as to whether this latter group of products is included in the Hastings District Council’s ban. International companies that are in the business of modifying plants using biotechnology invest hundreds of millions of dollars in technology and the testing of modified plants before these are commercially released. Despite what “big pharma” conspiracy theorists believe, such companies are unlikely to risk the significant legal challenges and costs involved by taking risky short-cuts.

Thirdly, this decision assumes that GM “residues” can get loose in the environment and contaminate other living organisms. That’s a bit like believing that throwing a banana out of a car window will lead to the establishment of wildling bananas or banana genetic material being absorbed by roadside grasses and weeds.

Fourthly, it assumes that products will be tested to see whether or not they contain genetic material not found in their unmodified forms. It is unlikely that Hastings District Council has any intention of doing this as part of its new by-law. It is also unlikely that anybody who buys food produced in Hastings District will do any testing either. Why? It’s expensive, unlikely to find anything significant and the costs of paying for that would have to be met by the district’s ratepayers who have not been presented with this option.

Fifthly, it assumes that Hasting District councillors know more about the risks associated with genetically modified foods than do government agencies like the Environmental Protection Authority, Ministry of Health, Ministry for Primary Industries and the Ministry for the Environment.

The only “standard” here is a political decree that Hastings District is GM-free. Whether that claim is true cannot be proven. No basis of local enforcement is being proposed. It remains to be seen whether anybody will ever challenge this by-law’s credibility.

The recent U-turn on the future of Wellington’s Town Belt by city councillors makes a mockery of the Local Government Act. On 1 December last year a number of changes were made to this Act. One of those changes was a requirement for councils to adopt a Significance and Engagement Policy.

The purpose of a Significance and Engagement Policy is to enable councils and their communities to identify the degree of significance attached to particular issues, proposals, assets, decisions and activities; provide clarity about how and when communities can expect to be engaged in decisions about different issues, assets, or other matters; and inform those local authorities from the beginning of a decision-making process about the extent of any public engagement that is expected and the form or type of engagement involved.

Most councils met the legislative requirement to have their new policy in place by the 1 December 2014 deadline set out in the revised Act. Very few took on board the intention of this new consultation requirement when introducing this change and did little more than minimum engagement with their communities. Some councils chose to bury consultation over their proposed significance and engagement policies in their Long Term Plan consultation, a process that generates little interest from communities other than regular council contributors.

So the brave new world of council community engagement began with more of a whimper than a bang.

Since 1 December there have been several instances of councils making decisions that are clearly in breach of their published Significance and Engagement Policies. Wellington City Council’s recent about-face on protecting its Town Belt is a good example where councillors, with no community engagement whatsoever, have made a decision that affects the future of a significant community asset. Whether a central government agency put the hard word on councillors to make this change, as some critics allege, is immaterial. In making this decision, council has breached its Significance and Engagement Policy with little explanation as to why.

Yes, councillors are elected to be “representative” of their communities and to make decisions on their behalf. Councils also have requirements to consult, as outlined in the Local Government Act, Resource Management Act and other legislation. These are the minimum levels of engagement that councils should do. Communities often expect more and councils themselves should engage because they want to, not because they have to.

The intention of the requirement to have a Significance and Engagement Policy was that councils should engage willingly and openly with their communities about significant matters – including deciding what issues were “significant”. Yes, there will be occasions, such as civil emergencies, where decisions need to be made quickly and there is no time for engagement. Communities will generally accept the need for urgency in such situations. At other times there should be no excuse for “significant” decisions being made to the exclusion of community interests.

Disturbingly there is no formal mechanism in place for councils to be held accountable for decisions not made in accordance with their Significance and Engagement Policy. Financial management decisions and decisions around other matters such as health and safety practices are scrutinised in some detail. This scrutiny, often by reputable independent authorities, means Councils go to considerable lengths to ensure that they comply with those policies.

So why isn’t Significance and Engagement subject to the same rigor? Probably because councils know that the Office of the Auditor General’s annual inspection will go no further than checking that they have a policy in place. The Audit Office does not have the capability to look deeper than that.

This means that it falls on communities to stand up for their own rights to be engaged with on significant decisions, rights that are enshrined in legislation. And that’s really sad, because isn’t that what they have elected councillors to do for them?

You can’t manage what you can’t measure. Community engagement and communication are no exception to this generally accepted management belief. But just because it’s possible to measure something, is the information gathered going to be of any real use? Will it be able to contribute to organisational success? Are we becoming too focused on capturing information just because it’s readily available, rather than because it allows us to learn if we’re getting closer to our goals?

Why is community engagement important? The answer to that question will be different for any organisation. For example a monopoly service provider, such as a council or a government agency, will see engagement quite differently to a business that depends on selling goods or services. Councils are not required to have a measurement for customer loyalty and their consequential reputation, whereas customer loyalty and reputation is mission critical for most businesses reliant on selling goods or services.

Public sector organisations can learn much from their counterparts in the private sector when it comes to understanding and managing their reputation and influence. In the private sector, reputation has everything to do with profitability and business success. In today’s online world an organisation’s reputation can be destroyed in the blink of an eye, which makes monitoring it and managing it carefully absolutely critical.

In the public sector, where organisations have a mandate to operate that is enshrined in law, the attitude towards reputation is somewhat different. They can still operate, irrespective of the views of their customers. This often leads to a very blinkered approach to any consideration of how customers feel about decisions made by public sector organisations and their ongoing impacts on people affected.

Reputation and influence are things that elected members rarely focus on at a governance level. Some sort of crisis requiring a reactive response is often they only time such governance groups focus on reputation. Once that matter has been “sorted” it drops off their radar, sometimes with little thought given as to why it occurred in the first place and what can be done to stop it happening again.

Sadly a lot of organisational focus for public sector engagement and communication is on what it costs. This is generally a good signal that reputation enhancement is not a priority and the value or benefits to that organisation from having a good reputation that’s worth investing in have not been thought of in those terms. In other words the organisational mind-set is in a wrong place.

Things like trust, respect and credibility should be part of a reputation KPI for any organisation, whether public or private. There are other high level outcomes that could be added to that list. Other measures, like sales made or return on investment will be shaped by those high level outcomes being achieved and should not be thought of as KPIs in themselves. While they may be easier to measure than things like trust, respect and credibility, just because something is hard to measure doesn’t mean that it can’t be. If that were true, then those things wouldn’t be able to be managed. And if that were true, then organisations that have great reputations and who are highly trusted and respected must have achieved that position by good luck?

Organisational performance is never straightforward and measuring success requires more than one source of reliable data. For example: Working out the fuel efficiency of a motorcar requires data from two sources – the car’s odometer and a fuel retailer’s pumping device. Working out the running cost of that vehicle requires the per litre cost of fuel to be known. This combination of reliable information can then shape decisions about whether driver training is a worthwhile investment to help reduce vehicle running costs.

Enhancing reputation and influence and the benefits that great engagement and communication practices can add can only be appreciated if there are clear outcomes set which can be supported by reliable information. That sounds easy but it’s really hard to do, even when an organisation’s mind-set is in the right place for that to happen. It’s impossible to do if it isn’t.

A recent front-page article in the Kapiti News (Wednesday, August 12, 2015) highlights the problems created when a local council limits its engagement with its community to the minimal requirements of local government law and its associated plans and policies.

In this case the Kapiti Coast District Council has riled the Waikanae community over a proposed medical centre in Te Moana Road, a major arterial street in Waikanae. The council decided that only a limited notification resource consent would be required, rather than a fully notified resource consent. This limited the need for public input to a few immediate neighbours of the subject property and eliminated the need for wider public consultation. The reason given for this approach was that this was in compliance with the Resource Management Act.

This has angered the Olde Waikanae Beach Preservation Society which has concerns about the wider future implications of the proposal.

Relevant to this decision, in addition to the Resource Management Act requirements, is the Council’s Significance and Engagement Policy, adopted under recent changes to the Local Government Act.

Under its Significance and Engagement Policy the Council commits to engaging with communities on issues of concern to them, and especially when they are directly affected by an issue, matter or proposal. But the policy also expressly excludes any engagement process that may be required under the Resource Management Act. This creates a potential conflict.

One the one hand the council can argue that as the medical centre proposal is subject to the Resource Management Act, then the commitment made in the Significance and Engagement Policy does not apply. End of story.

But hang on a minute, the community, beyond the limits set in the Resource Management Act, has expressed a concern. So how is that going to be taken into consideration?

In most cases, consultation requirements in statutes are minimum compliance standards which an organisation can exceed. In other words the Council could both comply with its Resource Management Act obligations and engage with the wider Waikanae community at the same time.

Many significant decisions will, by their very nature, involve the Resource Management Act. Having this exclusion clause in its Significance and Engagement Policy seems to run completely contrary to any reasoned desire to involve the community in public decisions. Tragically, both the council and the community lose out because all of the statements and commitments made by the council about community participation in decision-making are seen to be false by the community which misses out on an opportunity to contribute to a decision that affects them.

The Kapiti Coast District Council is not alone on using minimal legal obligations as the maximum amount of consultation it is willing to undertake. Other councils have also adopted this practice. The irony in this is that councils loudly proclaim the importance of engaging with communities but seldom follow through and walk the talk. The wider issue is that relationship building between councils and communities is undermined and mistrust of councils by communities continues to prevail. A radical change of mind-set by councils is needed to really make a difference.

The Basin Reserve Flyover is back in the news. A flyover was put forward by the New Zealand Transport Agency (NZTA) as a solution to a traffic congestion problem on State Highway 1 near the centre of Wellington. After lengthy and fractious legal issues, the court ruled in favour of the objecting parties who then assumed that by winning their day in court this proposal would be abandoned. Little did they know…

This prolonged and expensive tale of divisive woe is a good case study for how not to go about engaging with a community that will be significantly impacted by a major capital works project.

The first step in any good practice community engagement process should be to identify and prioritise problems that need to be fixed. By drawing on the knowledge, experience and skill of the public to identify and quantify the problem to be solved, and then overlaying technical elements, the NZTA could have produced a sustainable and workable solution acceptable to the majority of the affected communities. This solution could be significantly different from the flyover proposal currently on the table but would have required a completely different approach to that being followed by the NZTA.

The NZTA appears to have identified some technical solutions to a traffic congestion issue around the Basin Reserve and then dumped these on the affected communities with little context provided. Clearly the NZTA is seeing a problem that community groups cannot. This makes it quite difficult for them to sell their “solution”.

The single-mindedness of the NZTA in pursuing its preferred solution through legal channels shows just how little it values the input of communities in good decision-making. These communities not only have very real concerns about the impact of this purely technical solution on the long-term future of the iconic Basin Reserve and the surrounding area but will also be meeting a large part of the project’s costs through their taxes.

Rather than relying on a judicial decision to get its own way, the NZTA would be better served by restarting an engagement process, beginning with listening and responding to community views about the problem to be solved as well as the social and cultural, and economic values those communities attach to the Basin Reserve and its surrounding areas. Restarting this process could save some costs and time and also do much to rebuild the NZTA’s now badly tarnished reputation.

Organisations should be applauded for their willingness to embrace new ways of reaching out to and engaging with their communities. Invercargill City Council has recently decided that there is value in going to where its communities are, rather than making those communities come to them, with two initiatives.

One of these involves physically connecting with people, the other is an online channel.

To improve its people-to-people connections, the Council has bought a caravan. It can tow this around the city to venues and events where people gather and have a comfortable private space out of the weather where people can talk with council representatives.

It has been branded with Council colours and logos and should be a bit of a conversation starter in itself.

Council’s new online engagement initiative is what it plans to call “ICC TV”. This is a YouTube channel intended to provide a range of content about Council’s thinking, initiatives and projects. Hopefully the community will get behind this, particularly if the content is relevant and engaging, and provide useful feedback through this channel.

There are also some exciting ways that both the caravan and ICC TV could be linked to work together, which Council will no doubt seek to explore.

Hopefully Invercargill’s citizens will see value in these initiatives, rather than focusing on the costs. Mind you that will depend on how well the Council puts these new tools to work.

Initiatives like these are generally a good reflection of where an organisation’s mind-set is – embraced by the top levels of the organisation, filtering through planning and operational staff. If it is to be judged by these two exciting engagement initiatives, Invercargill City Council’s organisational community engagement mind-set is in a very positive space.

Good practice community engagement is about building positive and constructive relationships with communities to enable their valuable knowledge to be incorporated into effective decision-making, not just about meeting minimal legal requirements.

The Queenstown Lakes District Council clearly does not subscribe to this premise. On one hand its significance and engagement policy says that “we want to have the right conversations with the right people about the right issues before making significant decisions”, while on the other its senior managers are clearly unwilling to consult unless there is a legal requirement to do so.

An example of this is are reported concerns within the Wakatipu community about a lack of consultation over proposed Special Housing Areas. The Queenstown Lakes District Council says there is “no obligation to consult with anyone” and this is emphasised by a reported comment made by the council’s planning and development general manager who stated “There is no obligation under the Housing Accords and Special Housing Areas Act for the council to consult with anyone.”

Since 1 December 2014, changes to the Local Government Act require councils to have a significance and engagement policy. The purpose of such a policy is to enable the council and its communities to determine the degree of significance attached to particular issues, assets or other matters; to provide clarity about how and when communities can expect to be engaged in decisions; and to inform the council from the beginning of a decision-making process about the extent, form and type of engagement required.

The Queenstown Lakes District Council has a significance and engagement policy which sets out thresholds and criteria for determining significance. These are:

• Importance to the Queenstown Lakes District – the extent to which the matters impact on the environment, culture and people of the District (e.g. significant capital projects).
  
• Community Interest – the extent to which individuals, organisations, groups and sectors in the community are affected by the Council’s decisions.
  
• Inconsistency with existing policy and strategy – the extent of inconsistency and the likely impact.
  
• The impact on the Council’s capability and capacity – the impact on the objectives set out in the Financial Strategy, Ten Year Plan and Annual Plan.
  

Based on media reports, the special housing areas proposal is considered by the community to impact on people in the district and is clearly of significant community interest. On this basis one would conclude, as many in the affected area believe, that a requirement to consult has been triggered.

By ignoring the wishes of the community and acting with apparent disregard to its own policy, the council seriously undermines its relationship with its own community and creates an unnecessary controversy that will consume council resources dealing with community fallout. All of this could be avoided by council complying with its own significance and engagement policy and implementing a good practice community engagement process.

New Zealanders have a strong and emotional connection with our natural heritage. This is about our spirit of place and respecting and treasuring things that are uniquely ours. Kauri trees are no exception, being massively majestic and long-lived, visually appealing and providing tangible connections to past eras that they were part of and we were not: days that preceded human settlement in and development of this remote island nation. The greatest enemy of the kauri is people who seek to mill it and compromise the environments in which it thrives. Like many links to our natural past and legacies for our natural future, it is under threat.

Fast forward to 2015. A west Auckland property developer acquired a section of land in a good location with great views. It has a bit of native forest cover that’s in the way of any development opportunity, including a kauri tree estimated as being 500 years old, and a 300-year-old rimu tree.

Although the developer had the good sense to check with Auckland Council to gain consent for removal of this forest remnant before starting work, they did not include as part of their due diligence process before acquiring the property, the public impact of removing heritage trees. Auckland Council subsequently issued a non-notifiable consent approving the development of the site including the removal of the trees.

The local west Auckland community and nature lovers from hither and yon got word that something was up and that this piece of forest and its heritage trees were under threat. Protest action ensued, including one game fellow shinning up the kauri beyond the reach of Police officers who issued him with a verbal prosecution notice. News and social media went berserk. Celebrities and politicians got involved. Questions were asked.

Auckland Council said it had complied with legal requirements when issuing its consent, which could not be revoked. Reports prepared by council officers were examined and their initial concerns about development on this site appeared to have been tempered, to support the non-notifiable consent decision.

It was the property owners who wisely decided to back down, rather than council emerging from its legal fortress and changing its decision. From this incident there have been significant costs to both parties – council and developer – both financial and reputational. Costs that could have been avoided if council officers and the developer had thought about issues beyond minimal legal compliance. Simply focusing on compliance with the Resource Management Act and the council’s various plans demonstrates the vast difference between legal compliance and good practice community engagement.

Lessons to be learned from this include that good practice community engagement will always incorporate legal compliance, where required. Legal requirements are a minimum standard to be applied, not the only standard. Identifying and analysing stakeholders is an essential element in any good practice community engagement process. Had this been undertaken correctly, and early, then the developers would have known, before purchasing the property, the intensity of public interest. The council, for its part, would have required the application to be notified.

The importance and influence of affected stakeholders and communities should always be examined, and should be part of any conversation that council officers have with applicants. A council that was in touch with its communities wouldn’t have allowed this situation to happen.

Social Licence to Operate. SLO. The latest buzz phrase and three-letter acronym doing the rounds and one that seems to be capturing the attention of senior managers in diverse enterprises. So what’s it all about? Do organisations really need to gain the approval of communities in order to operate?

“Social licence” is another way of describing the currency of reputation or goodwill. Some people may refer to this currency as Brownie Points™. While that description may be a bit glib, it’s a fair simplification of what’s an operationally complex issue. Complex because embracing it and doing it well cuts to the core of an organisation’s mind-set and culture and underpins that organisation’s brand.

An organisation accumulates goodwill by conducting its affairs in a manner that either meets with the approval of communities or doesn’t annoy them. This currency takes a long time – perhaps years – to accumulate but can be lost in a moment. Organisations that understand this value proposition and its complexities and are still prepared to invest are the ones who will do it well.

There are many examples of organisations that have damaged their social licence to operate. On this list are multinationals who manufacture their products in countries that allow child labour, manufacturers who include non-sustainable palm oil in their foodstuffs, those who trade in products sourced from endangered species, or airlines whose planes crash because of deficient maintenance and staff training.

These are extreme examples selected to make a point. Not all social licence-related issues involve breaking the law. A truth for any individual or organisation is that perception is reality. That perception doesn’t have to be underpinned by facts or sound science but if it’s widely held, then it needs to be understood and respected.

Another reality is that all organisations require a social licence to operate, whether or not they acknowledge that. In some cases the minimum standards necessary are set by regulations administered by government agencies or councils. In these cases the authority needed is provided by proxy from communities through government.

A social licence is based on trust, respect and mutual understanding. These are products of a commitment to partnership, a commitment which for many organisations is, regrettably, undertaken because they have to, thanks to regulations and statutory requirements, rather than because they want to. Such organisations may have no real interest in things like social licences to operate.

Organisations that do care about their social licence to operate generally seek ways to connect with their customers, clients and communities that add value to both sides of the relationship. They probably have an engagement policy, engagement strategies and plans for their major products, projects and processes. They’re probably no strangers to market research, focus groups, online panels, and community-led sponsorship, to name a few tools. There’s also a high probability that they’ve been actively engaging for a while. They will also understand what investing in their brand really means – that this investment involves more than a nifty logo and jazzy advertising.

Organisations new to this world of engagement and consequent reputation building – social licence to operate – may feel a bit confused about how to get started. They may also be organisations that have been around for a while but are feeling threatened or exposed by changes to what their clients, customers or communities are thinking and doing.

They may also be looking for an off-the-shelf solution that can be quickly put to work.

While there are off-the-shelf remedies, they’re unlikely to work in a believable and trust-building way unless the organisation concerned with delivering those is genuinely committed. Remember, communities have highly tuned Bullshit Receptors™ and can spot disingenuous operators in a heartbeat.

The choice of tools and techniques for community engagement and reputation building has to align appropriately with an organisation’s vision and values. If it doesn’t, then it is unlikely that employees of that organisation will make the right connections and any investment made could be money wasted.

But the first step has to be at an organisation’s top table. The board of directors, elected councillors, CEOs and their direct reports. The mind-set of these people is crucial for success. No well-intentioned, visionary and workaholic operational manager will succeed in this space unless they have the guidance, leadership and backing of those at the top of the organisation.

These leaders need to accept that their organisation will operate best with societal approval and all of the reputation and risk issues associated with gaining or retaining that.

So do organisations really need to gain the approval of communities in order to operate? If they want to operate successfully, then yes they do.

Can Engagementworks help organisations who want to better understand what’s possible in this world of social licences to operate? Yes we can. And we’re happy to discuss options and choices.

At this time of year New Zealand’s 78 local authorities are involved in crafting their annual plan documents or, once every three years, a long-term plan with a 10-year vision in accordance with section 93 of the Local Government Act (LGA).

These plans are supposed to be tailored by the needs and aspirations of the communities each council is elected to serve. Their contents and priorities should be shaped after extensive community engagement. Indeed the LGA requires, as a minimum, the Special Consultative Procedure to be used to develop a Long-Term Plan. The LGA also talks about these plans providing a basis for accountability between a council and its communities. A worthy ambition.

Given the importance that a long-term plan plays in shaping a council’s decision-making and priority setting, with flow-on impacts on the levels of rates set to fund those, it is surprising that so few community members take the time to become involved in any associated discussion or debate.

Formal submissions will be sought, usually through advertisements published in newspapers or on a council’s website. Public meetings will be scheduled and held in venues and at times that work best for elected councillors. Many councils will know with a high degree of certainty in advance of a draft plan being released who they will receive submissions from and what those will say. But how representative are those submissions of wider community ideas and opinions?

It may be argued that if there is no interest in or discussion about the content of a long-term plan, then it must be a fair representation of community views. It may also be argued that additional efforts to connect with communities will impose additional demands on a council’s time and money for no apparent additional benefit in terms of information received. That may be true, but what about the connectedness a council should be aiming to have with its communities, particularly the basis of accountability the LGA says should be provided?

Long-Term Plans are large, hard to read documents built to satisfy the needs of auditors. It is not surprising that very few people, other than auditors, actually read them. Councils invest time summarising these into smaller documents that may be put into letterboxes with the outpourings of Big Box Retailers and real estate agents. Adaptations of these summary documents may also get placed on council websites where analytics will reveal they attract scant interest from cyberspace inhabitants.

This could be because community members believe that councils really aren’t interested in listening to them. If they were, then they may be more active in creating opportunities or using engagement tools that communities understand and are comfortable with. There is an abundance of tools that can be used, either for face-to-face interactions as well as online. Citizens shouldn’t have to make a formal written or verbal submission. Such measures are a barrier to engagement, as the numbers of people using those, as a percentage of all community members, shows.

This isn’t a challenge that is particularly difficult to improve on. All that is required is a little imagination and a willingness to listen to communities – earlier rather than later – and show them how what they said was considered and shaped the final outcomes. Councils need to focus on delivering simple messages that are clearly expressed and easily understood, particularly by hard-to-reach community members, such as people with language disabilities. Pictures and infographics work really well as communication enhancers.

From 1 December 2014 all 78 councils will be required to have a significance and engagement policy in place. It will be interesting to observe what changes will be seen in council community engagement, particularly annual plan engagement, from 2015 and onwards.

The public should have a big stake in what sort of community they want for themselves, their children and their grandchildren. Their willingness to contribute to their “ideal” is greatly influenced by the contribution that they are able to make to the long term planning for their community.

Fair enough. But isn’t this what already happens? Regrettably no.

However recent changes to the LGA relating to significance and engagement creates an opportunity for councils to rethink their approach about how they interact with communities. This may act as a catalyst to change how councils make decisions by acknowledging that communities are important and can make a valuable contribution, particularly if successful community outcomes are desired.

This would mean looking beyond just legal compliance to good practice processes. In an LTP development this would involve the community in deciding what should go into the LTP in the first place and being engaged through the various steps ultimately leading to the more formal special consultative procedure consultation at a later stage of development prior to adoption.

This effectively relegates the special consultative procedure to a tick-the-box exercise, as with good prior community engagement, all of the important decisions will have already been made with the full involvement of the affected community.