None of these concerns have been addressed by the government, they are ploughing on regardless with a ridiculously tight timescale – August 17 for boundary changes.

Yesterday in a post entitled: “Thumbs Down” for greater Plymouth, Exeter and Torbay, Owl pointed out that no group of consultation respondents supports the expansion of Plymouth, Exeter and Torbay and dumping the remaining half million Devonians in relative rural poverty. In fact it is the least favoured option with three quarters of respondents having negative views on it.

This companion post looks at the more subjective comments to emerge from the 69 page summary and analysis of the Devon, Plymouth and Torbay consultation.

The consultation questionnaire was a highly structured tick box exercise. However, many of the questions allowed free text comment. The straight forward analysis of these is uninformative due to the repetitive nature of replies between questions suggesting that respondents felt constrained in what they could say.

What is informative is the use of AI to identify themes hidden in the margins of these comments. These five emerge.

Loss of Local identity and representation.

Financial risk and doubts about efficiency.

Urban–rural inequality and imbalance.

Service delivery disruption and fragmentation.

Governance structure, size, and complexity.

Now to look at these in more detail.

The themes identified by the AI tool amongst comments on options

Loss of Local identity and representation. Concerns were raised that local identity and representation could be weakened, making decision-making feel more distant from communities. Additional concerns were raised that proposed groupings do not reflect real communities or local ties, grouping areas together in ways that feel artificial which could break existing links, especially in rural areas, leading to poorer representation and services that are less suited to local needs.

Financial risk and doubts about efficiency. Concerns were raised about financial risks and whether the new unitaries will improve efficiency or value for money. The responses suggested that any changes may increase costs, create more bureaucracy, and bring high transition expenses. Additional concerns suggested that proposals are financially unsustainable, especially for rural areas, with risks of higher council tax, duplication of services, and unfair distribution of funding. Overall, there are strong concerns that the reorganisation could lead to higher costs, greater financial instability, and fail to deliver the efficiencies it promises. 

Urban–rural inequality and imbalance. Concerns were raised in relation to combining urban and rural areas, that this could create imbalance, with cities having more influence and rural communities being left behind. Additional concerns suggested that some options could lead to large, centralised authorities that weaken local identity, reduce representation, and make decision-making feel remote, especially in rural and coastal areas. Responses suggested that some options offer a better balance but there is a strong concern that most would widen the gap between urban and rural areas, leading to rural communities being underrepresented, underfunded, and losing their identity and voice. 

Service delivery disruption and fragmentation. Concerns were raised that changes could disrupt services and reduce their quality, especially for vulnerable and rural communities, that reorganisation may cause short-term disruption to important services and may not fix existing problems. Additional concerns raised were that some options could lead to services being split or duplicated, making them harder to manage and less consistent, although there may be some opportunities to improve local focus. Responses suggest that there is a strong concern that reorganisation could fragment services, create differences in service quality between areas, and make it harder to deliver reliable support—particularly in areas like social care.

Governance structure, size, and complexity. Concerns were raised across all the proposals that very large or split authorities could be difficult to manage and may not work well for local communities, that proposed councils are too big and complex, making it harder to respond to different local needs. Additional concerns included proposals could lead to fragmented systems with duplicated roles and unclear responsibilities. Responses also expressed doubts about whether leadership and governance structures would be strong enough to deliver effective services. Further concerns were raised that changes could bring disruption, more bureaucracy, and long adjustment periods, with plans and accountability not always clearly set out. Responses suggested a strong concern that reorganisation could create complexity and confusion rather than improving how services are run, especially in rural areas. 

Summary of paper and emailed non-named consultee responses 

Emailed and paper responses noted the importance of local identity and democratic accountability; concerns about more remote decision-making and increased councillor workloads; and the need for councils to be financially sustainable and appropriately sized. Respondents also considered whether proposed geographies reflect functional economic areas and service footprints, in particular those options that expanded Plymouth’s boundaries and the subsequent parish arrangements. Service delivery and integration, transition risks, and the extent of engagement were also raised, alongside potential benefits such as clearer accountability, better service alignment and stronger strategic coordination.

Boundary changes (a consultation topic in its own right)

From the responses Boundary changes emerge as the single most contentious topic.

Three proposals involved boundary changes in addition to organisational ones: the 3 Unitary District Council one with modifications around Plymouth and both the 4 Unitary Plymouth and Exeter and 4 Unitary Torbay proposals.

Summary of Local Government Boundary Commission (The Commission) Response 

The Local Government Boundary Commission for England provided observations on the evidence provided to support the boundary change request within the 4 Unitary (District Councils Modified), 4 Unitary (Plymouth and Exeter) and 4 Unitary (Torbay) proposals, drawing on its Principal Area Boundary Review expertise. It considered the evidence in the proposals as it related to the identity and interests of local communities, and the promotion of effective and convenient local government. The Commission observed that, across all proposals, while efforts have been made there was relatively little detail to support the specific boundary changes that were put forward.

[Looks like a no-no to Owl and yet August 17 is set for authorities in Devon to submit new boundaries – expect fireworks]

The themes identified by the AI tool across all the boundary change options were as follows:

Negative impact on rural areas and representation. Concerns were raised across all three proposals with boundary change that they may disadvantage rural areas by reducing representation and prioritising urban interests, that they eroded local and cultural identity. There were also concerns that boundary changes would group together dissimilar communities, leading to poorer, less tailored services for rural areas and weakening the ability of local people to influence decisions.

Scepticism about financial sustainability and efficiency claims. Concerns were raised across all three proposals with boundary change that boundary changes had high implementation costs, increased bureaucracy and inefficiency, with doubts over their ability to achieve long-term financial sustainability. There were also doubts that expected savings will be realised, alongside fears of rising costs, growing debt and constrained resources. Concerns were also raised that boundary changes would fragment existing partnerships and disrupt services, particularly across social care, health and education, potentially reducing service quality while increasing both complexity and costs. 

Lack of strong justification for boundary change. Concerns were raised across all three proposals with boundary change that the boundary changes lacked clear, robust, and evidence-based justification, especially regarding improvements to public services or financial sustainability.

Political and financial motivations of Councils (political motivations in relation to the 4 unitary options but favouring urban areas across all options). Concerns were raised in two out of the three proposals with boundary changes that the boundary changes were being driven by political motives, including urban council self interest and efforts to expand tax bases, rather than delivering genuine public benefit. Respondents raised concerns about boundary changes favouring urban areas and disadvantaging rural communities, that decision-making is not impartial and does not reflect the needs of the whole area.

Boundary changes increase complexity, disruption, and inefficiency. Concerns were raised across all three proposals that boundary changes would create administrative complexity, disrupt established services, duplicate efforts, and lead to inefficiency and unnecessary costs. 

Summary of paper and emailed non-named consultee responses

Many respondents did not express a clear view specifically on boundary change, instead focusing on wider issues. Where views were given, they were mixed. Some respondents supported boundary changes where these were seen to better reflect economic geographies or create more balanced and sustainable unitary areas, but many raised concerns or opposed specific changes, particularly where proposals involved splitting districts, expanding urban areas into rural communities, or creating large and uneven geographies. Key issues included the potential loss of community identity and local representation, the risk that rural areas would be overshadowed within urban focused structures, and challenges around travel distances, accessibility, and service delivery across large or dispersed areas. Respondents also highlighted concerns about the complexity and deliverability of some proposals, particularly those involving multiple boundary changes or new governance layers, although a small number identified potential benefits such as improved alignment with functional economic areas and stronger strategic coordination. 

Despite all these comments ex Minister Steve Reed ploughed on without addressing any of the issues.