External quality assurance of the stakeholder consultation processes used during the 2016 review of the national goose policy framework in Scotland

The Scottish Government is committed to reviewing goose management policy on a five- yearly basis. Throughout 2016/17 Scottish Natural Heritage (SNH) reviewed the current goose policy framework, its effectiveness in delivering the policy objectives and the development of a longer term outlook for goose management in Scotland. This work was undertaken on behalf of the Scottish Government, with advice from the National Goose Management Review Group (NGMRG).

To quality assure the review process an independent panel was established by SNH and Scottish Government. The task of the external quality assurance panel was therefore not to evaluate the effectiveness of current goose management policy in delivering the existing National Policy Objectives. The primary request made of the independent panel was that they “… identify whether the goose policy review has been conducted in an open, fair and transparent manner, treating all stakeholders with impartiality and respect”.

Main findings
(1) Those individuals who were contacted directly by the policy review authors (primarily members of the NGMRG, some environmental NGOs and members of SNH staff involved in geese management at a regional largely) largely appeared satisfied with stakeholder engagement processes taken by the light review. The panel found no evidence that stakeholders felt that they were not treated with impartiality and respect. However, some did express concern that the turnaround times set for comments on drafts did not allow them either to fully formulate their own views or consult wider themselves.
(2) However, outside of the above core group of stakeholders who were contacted directly, most of those stakeholders contacted felt that they did not get an opportunity to fully air their views or have them adequately incorporated into the draft review process. A minority felt that they were not adequately informed about the nature of the review process itself to even enable them to formulate and express their views.
(3) This could have arisen from a combination of factors, summarised as follows:
- the light touch review may have been inadequately resourced in terms of the capacity of the process to engage;
- lack of ability of those engaged directly by the report author to consult more widely within defined narrow time limits
- a misunderstanding of the nature and scope of the review process and the degree to which stakeholders could and were asked to contribute;
- the extended, and ultimately protracted, timescale over which the light touch review process was undertaken may have raised expectations and led some stakeholders to believe, incorrectly, that a larger, more detailed review was being conducted. This potentially led to disappointment when they finally had sight of the review document.
(4) Overall, the independent panel consider that the policy review was conducted in as professional manner as was possible given the severe time and capacity constraints put upon the policy review author. Many stakeholders recognised that the scope of this review was restricted to defining a future direction of travel and a focus for further discussion and management options development, rather than representing a major review recommending structural changes for the immediate future.
(5) It is, however, clear that many in the wider stakeholder community felt disenfranchised by the processes that were followed and some commentary and observations are provided by the panel at the end of the document with regard to potential improvements for any future such reviews. In summary these are:
- The range of issues, and limits, to be reviewed should be clearly stated; the reach of the consultation process should be mapped in a target list of stakeholders; issues that emerge during the review process, which fall out-with the terms of reference or scope of the light touch review, should be clearly flagged for further investigation and/or action.
- Priority stakeholders should be identified in the consultation terms of reference, with recognition that that all relevant stakeholders (i.e. not just those on NGMRG and GSAG) have a role to play in the consultation process; a communication pathway should be identified which recognises the need to involve stakeholders associated with the local goose schemes at a much earlier stage; the consultation should be in a questionnaire format, even if the preliminary review drafts are shared, in order to obtain comments from stakeholders across the full content of the review.
- A realistic timescale needs to be set for the scope and degree of any future consultations with stakeholders, irrespective of whether the review is light-touch or not. This particularly requires that the process: gives adequate time to incorporate the findings from the existing pilot Greylag and adaptive management schemes; respects the needs of stakeholders to reflect, internally consult and thoughtfully formulate their input to the policy review process; allows for independent and impartial review of the whole policy review process (i.e. not just stakeholder engagement).
- Ensuring that future reviews draw from as wide a range of experiences as possible, provide all relevant stakeholders with the opportunity to engage in the review and incorporates independent and impartial review of the revised policy framework will help to guarantee buy-in, ownership and support across stakeholders for the implementation of the recommendations and actions arising from the review process.