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For the attention of the Secondary Legislation Scrutiny Committee

I am writing to indicate my opposition to the government's new approach to consultation, in which new guidance states consultations may run for just two weeks instead of the usual 12.

This drastic shortening of consultations makes it prohibitively difficult for organisations and interested parties to gather evidence and submit a clear and considered response to proposals. As such, the new approach to consultation effectively leaves some sections of the public without a voice.

This has been recently evidenced in the cases of two consultation periods that were reduced to three weeks. Responses to the Department for Business, Innovation and Skills' consultation on "Implementing Employee Owner Status" required a large amount of research due to the far-reaching implications of creating a new status of worker. Three weeks was insufficient for organisations to gather strong evidence of the repercussions to workers, employers, tribunal procedures and any complications with EU law.

Elsewhere, the Department for Environment, Food and Rural Affairs' "The future of the Agricultural Wages Board for England and Wales, and Agricultural Wages Committees and Agricultural Dwelling House Advisory Committees in England" consultation did not provide enough time for Unite the Union to complete its legal analysis of the proposals, which it was suggested may have been illegal. Where major organisations like Unite are struggling to meet such tight deadlines, smaller bodies with fewer resources are effectively locked out of the consultation altogether.

I believe every consultation period should be 12 weeks long in order to ensure all interested parties, regardless of their wealth or size, are able to provide evidence.

I also do not agree that any previously held public consultations have been unnecessary and thus oppose any change in guidance to ministers that suggests some policies can be legislated on without public consultation. Even where a change to legislation may be described by some as a "technical amendment", there can be far-reaching implications to UK law.

This has recently been evidenced by the case of the amendment to (s)47 of the Health and Safety at Work Act 1974 that was added to the Enterprise and Regulatory Reform Bill without consultation. This amendment is not simply a technicality but in fact overturns employers' 114-year-old strict liability for the health and safety of their employees, causing major changes to people's real-life experience of employment law. The government should have consulted the public before making this amendment.

Finally, I oppose any attempt to restrict responses to digital only. I believe such a move would disempower those without access to technology. I also believe on-line responses allow less flexibility in the way respondents answer the questions.

I urge the Secondary Legislation Scrutiny Committee to rescind the government's new approach to consultation to ensure the voice of the public continues to be heard in Whitehall.

Signed