Open Letter to North Warwickshire Borough Council

As part of our campaign against the development adjacent to Red Marl Way, we have today asked the council to reject the community engagement part of their application and for it to be done again in conjunction with the residents Association.

Please remember that this is a campaign, not a single battle and we will keep challenging using various methods and complaints.

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Warton Residents’ Association
Formal Representation Regarding the Community Engagement Process
Planning Application PAP/2025/0155  Land North of Orton Road, Warton. Document  EP155/SCE, statement of community engagement.
Date: 16th May 2025
To: North Warwickshire Borough Council Planning Department

Dear Sir/Madam,
On behalf of the Warton Residents’ Association, we write to raise serious concerns regarding the Statement of Community Engagement submitted by Evolve Planning in support of the above application for development of land north of Orton Road, Warton. We believe the engagement process documented fails to meet the standards of fair, inclusive, and meaningful consultation as set out in national policy and case law.

We respectfully request that the current Statement of Community Engagement be set aside and a new consultation process undertaken. This renewed process to be developed in partnership with the Warton Residents’ Association, and be subject to independent oversight and analysis, in order to ensure both transparency and public confidence in its findings.

Grounds for Objection

1. Flawed Methodology and Biased Survey Design
The online questionnaire issued via the consultation website contained compulsory questions, with no facility to skip or withhold answers. This technique, often referred to as a “dark pattern”, risks distorting the evidence base by eliciting coerced or forced responses. Moreover, Question 2, which asked participants to rank “important” features of the proposed development, included only positive attributes (e.g., affordable housing, open space), with no option to reflect negatively on the scheme as a whole. Such skewed framing is inconsistent with the principles of neutral consultation.

This undermines Gunning Principle 2 (1985), which requires consultees be given sufficient information and genuine opportunity to give an informed and intelligent response.

2. Insufficient Consultation Period and Delayed Delivery
The consultation ran from 18 February to 8 March 2025, a period of 18 calendar days. However, leaflets informing residents of the consultation were not delivered until Saturday 22 February, meaning a significant portion of that window was lost. In practice, residents had less than two full working weeks to respond.

This violates Gunning Principle 3, which requires adequate time to respond, particularly in a rural setting where digital literacy may vary and time is needed to mobilise community groups.

3. Conflict with Neighbourhood Planning Process
The consultation period overlapped with the formal adoption process of the Warton Neighbourhood Plan, a community-led statutory document. This created confusion among residents about which process would prevail, and whether their views were being sought independently or in conflict with decisions already being formalised.

This raises questions under Gunning Principle 1, which requires that consultation be carried out prior to decision-making and at a time when proposals are genuinely at a formative stage. Running a consultation concurrent with the formalisation of a Neighbourhood Plan undermines that principle.

4. Failure to Ensure Inclusive and Representative Engagement
The engagement relied almost entirely on digital platforms, with no face-to-face meetings, exhibitions, workshops or interactive forums. No public events were held, and crucially, no efforts were made to follow up after Polesworth Parish Council failed to respond to initial contact. This shows an abdication of responsibility in securing representative feedback from elected local stakeholders.

Furthermore, the report acknowledges that only 115 responses were received from 566 households, a return rate of approximately 20%. No submissions were received by post or email. This figure—given the scale and potential impact of the proposed development—does not represent robust engagement and ignores many residents who lack digital skills or access.

In light of the above, we request the following actions:

• That the Council formally reject the current Statement of Community Engagement on the basis that it is procedurally and methodologically flawed;
  • That a new consultation be required before this application is considered further, to include:
  • A co-designed engagement strategy developed in partnership with the Warton Residents’ Association;
  • A blend of in-person and online methods, including community meetings, drop-in events, and paper-based feedback opportunities;
  • Independent moderation and analysis of consultation responses, to ensure impartial interpretation and reporting of public views.
• That the CEO of North Warwickshire Borough Council investigate why the elected Parish Councillors failed to respond to the contact from Evolve.

We trust the Council will recognise our concerns and act in the interest of democratic accountability and community confidence.