DfT consultation

I see that the Department for Transport have opened consultation on the Transparency section of their business plan. The information is here. We are not being invited to comment on the content - I assume that consultation has already happened. So leaving aside any issues we might have with the rest of the document, we are invited to comment on whether they:

• have selected the right indicators and measures and clearly explained their meaning in order to give a helpful high-level picture on the spending and performance of the transport sector
• have robust data systems in place to ensure that the information provided is accurate, timely and robust and the quality is fit for purpose
• have clearly defined their commitment to publishing data to help judge performance and whether the data that will be published meets our needs
• should be mandating or encouraging the publication of extra data, or data broken down in a different way, that we would find helpful in holding the transport sector to account or making choices about transport services

I'll take it as a given that the people in DfT really are interested in encouraging sustainable travel, making cycling more attractive and so on. On that basis my first thoughts are:

• Decision taking is going to be at a local level, but the DfT plan is to publish the main indicators at a regional level - shouldn't we expect data at local authority level on the proportion of cycling trips to presented in a consistent format so that we can compare how different local authorities are performing?
• Numbers are pretty useless in isolation - there are too many other factors to explain any differences and confuse the issues. Shouldn't we expect at least some baseline data for each local authority, so that we can see future trends
• Measuring the number of urban trips under 5 miles strikes me as a fairly useful proxy for measuring progress. It's particularly relevant for large towns and cities. But any single target is potentially going to distort behaviour. What about additional measures for local authorities that choose to prioritise other forms of cycling (sport, or tourism); or particular groups (school-children, commuters, rail users) 
• What this is seeking is behavioural change across large numbers of road users. That takes time. I imagine that even the most effective local initiatives will show little impact on outcomes in the first couple of years. The suggested indicators are "lagging" in the way they measure any impact. It's no good looking back in four years time and saying "well that didn't work then". Effective scrutiny will have to rely on  leading indicators, to see what our local representatives are up to, and whether things are heading in the right direction. If individual local authorities are bombarded with FOIA requests it will waste a lot of their time.  Local authorities themselves will need more detail to monitor and steer their local initiatives. So it would be good to see some consistent standard measures for each local authority of things like the level of investment in cycling infrastructure, what local goals and targets have been set, the types of initiative that are taking place, and the number of participants in schemes such as training for cyclists
• Is DfT providing any guidelines to local authorities on how to track progress and how to ensure measurements are consistent between authorities - and if so, what are they. 
• Finally (and I'm not sure if this fits the consultation criteria or not), I've not seen anything on how proposals for the sustainable transport fund are going to be evaluated - how can we participate  without knowing this?

I don't have any experience of this kind of thing. Maybe others do, and maybe they are already involved. What is the best way to be heard? Have I missed anything? Am I wasting my time even thinking about it?