It was clearly an error of judgment by the Secretary of State for Communities and Local Government to appoint a former Leader of a Conservative council independently to inquire into the effectiveness, efficiency, fairness and transparency of the so-called local council tax support (LCTS) schemes introduced by the Coalition on 2013, to work on his own without any independent support from other male or female inquiry members.

I am glad he reports, in Three Years On, me calling the LCTS schemes "a tax on benefits" (page 67) because that is what it is.

The great inefficiency he fails to mention is in central government providing benefit income for the survival and shelter of the poorest people while the local authorities take it away with council tax.

He fails to condemn his own party for requiring, since April 2013, the poorest benefit claimants to pay the council tax on £73.10 a week JSA, which in many cases is also paying the bedroom tax, and then allowing the enforcement of that tax to continue while benefit incomes have been stopped by a sanction. He fails to make the link between ever rising council tax arrears, enforcement, sanctions, physical and mental health problems.

The words "sanction", "mental and physical ill health" do not appear in his report.

The expectation of life in Tottenham where they tax benefits is 17 years shorter at 71 than in Kensignton and Chealsea at 88 years where they don't.

His recommendation that councils should be allowed to deduct the tax from benefit without applying for a liability order from the Magistrates merely makes it easier and cheaper for the councils to tax benefits.

He has ignored the reports he received about the immediate oppression in the enforcement of debts against the poorest residents with sanctions and their damage to the health of the poorest residents. He kicked them into the long grass with a vague and leisurely  recommendation;

"More broadly, my research revealed a very limited body of evidence on the impact of LCTS on recipients and, crucially, the collective impact when considered alongside other welfare reforms. The point has been made by many. There is clearly a need for some in depth and academic research in this area.".

Secondly the report lof this single man allows the free rein to the whingeing of local councils about their legal duty to consult.

He reports their whingeing as follows;

"While many councils pointed out the benefits that public consultation has brought, such as greater local accountability and engagement, some issues are evident.

The legislative requirement to review schemes each year is seen as onerous, rigid, and costly.

Councils find the legislative framework for consultations too vague, and the perceived lack of clarity has introduced unnecessary legal risks into the consultation process.

The resultant consultation documents can therefore be dense, technical, and long, making them less comprehensible and engaging to residents"

At a time when the gap between democratic government and the people gets ever  it it is up to the councils to write their consultations clearly and engage their residents.

An Independent inquiry comprising independent members could have have backed the Supreme Court. A inquiry by a single politician committed to irrational deregulation, and invisible hands, was guaranteed never to spell out an entirely necessary law on consultation.

It was spelled out by five members of the Supreme Court on the 29th October 2014 as follows in "R (on the application of Moseley (in substitution of Stirling Deceased)) (AP) (Appellant) v London Borough of Haringey (Respondent)" The challenge of two brave single mothers should not be so carelessly ignored.

The court endorsed the following principles od consultation;

“ First, that consultation must be at a time when proposals are still at a formative stage.

Second, that the proposer must give sufficient reasons for any proposal to permit of intelligent consideration and response.

Third,… that adequate time must be given for consideration and response and, finally,

Fourth, that the product of consultation must be conscientiously taken into account in finalising any statutory proposals.”

The Supreme Court then gave their reasons for supporting theses principles.

"First, the requirement “is liable to result in better decisions, by ensuring that the decision-maker receives all relevant information and that it is properly tested”

Second, it avoids “the sense of injustice which the person who is the subject of the decision will otherwise feel”  Such are two valuable practical consequences of fair consultation.

But underlying it is also a third purpose, reflective of the democratic principle at the heart of our society. This third purpose is particularly relevant in a case like the present, in which the question was not “Yes or no, should we close this particular care home, this particular school etc?” It was “Required, as we are, to make a taxation-related scheme for application to all the inhabitants of our Borough, should we make one in the terms which we here propose?”

The report could have the effect of enabling local authorities more efficiently to tax to death the poorest benefit claimants.

It has omitted crucial evidence needed to permit its intelligent consideration by the government and the public .