At its October 2023 full council meeting, Saltford Parish Council (SPC) resolved to submit a formal complaint to WECA about the process and conduction of the A4 Bath to Bristol consultation (open 21 August – 1 October).
SPC views that the WECA consultation was not conducted appropriately, primarily due to new or more detailed information being released (both formally on the website and informally from officers) during the consultation period following SPC’s submitted response, some of which could be interpreted as being shared with an aim to influence responses in favour of supporting proposals.
Some new or more detailed information released could also be interpreted as having been shared to counteract any future objections being made to WECA including some objections raised by SPC.
The full complaint by SPC is as follows:
- The consultation website was difficult to navigate.
The consultation website layout meant information was difficult to find and refer to, especially if looking to respond by email or in writing.
Maps were difficult to decipher (until new ones added on 19 September) and hard to find (e.g., High Street map mislabelled).
Supporting information on the website was not linked appropriately e.g. Bristol to Bath Railway Path Proposal map for Saltford was not linked to the ‘Proposals’ ‘Walking and Cycling’ consultation page for reference to accompany the (vague) text.
Overall this meant that the consultation was challenging to respond to, and that it was easy for those looking to respond to overlook both original or additionally added information when looking to respond to proposals.
- The Online Survey wording may have ‘pushed’ responses
SPC is concerned that the online survey ‘pushed’ responses in a specific and deliberate direction, with questions worded in such a way to generate a desired result.
- SPC and residents who responded between 21 August and 18 September did not have the opportunity to base their responses on all the information shared as part of the consultation. New or more detailed information was published on 19 September (c.1 month after consultation opened) on the website under ‘downloads’ and ‘FAQs’ pages. (Officers also gave new, more detailed or different information to residents at the consultation drop-in event at Saltford Hall – see next point).
WECA was aware ahead of the consultation opening that SPC would resolve its consultation on 5 September (as officers were invited to present in July). SPC formed its response on the basis on information available on the HaveYourSay website published on 21 August. At the time the website included poor quality images of Saltford maps, which meant much of the detail was hard to determine, as provided as feedback in SPC’s response to WECA (e.g. double yellow lines marked on light brown ‘textured paving’ in low resolution images).
On 19th September, almost a month after the launch, WECA added substantially more information to its ‘downloads’ page on the consultation website. This included high resolution maps of Saltford giving more detail than SPC had been able to respond to. It also included a factsheet for the Saltford area (‘Broadmead to Globe roundabouts’). Though it could be viewed that WECA was reacting to points raised by SPC in its consultation response about e.g. poor quality maps, as SPC did not have the opportunity to resolve a response about the new or additional information revealed, it could be interpreted that the consultation was not fairly conducted. It could also be viewed as a strategic way for WECA to prevent SPC (and others who had submitted responses before 19 September) from being able to comment on some matters.
SPC had to clarify to residents in the weeks following its response being submitted (when the consultation was open) that some aspects had been unintentionally omitted from its response as the information had not been clearly available at the time it resolved its view on proposals.
- WECA could be interpreted as influencing those responding to not include comments on certain matters via information added to their FAQ section (Saltford station and bus fare prices)
On 19th September, a FAQ page was published (previously it was just a tab with no information on the page) which included a ‘Saltford’ section. Specifically with regards to the ‘FAQ’ section, WECA is viewed to have influenced those looking to respond to the consultation to not include comments on specific matters raised by Saltford Parish Council in its published response. This relates to WECA’s ‘FAQ – Saltford’ section where WECA addressed re-opening Saltford railway station and Saltford being in the ‘West of England’ fare zone by stating future planned actions.
By doing this, it could be viewed that WECA was aiming to influence future responses during the open consultation period by dissuading residents to raise these points, which would then result in re-opening Saltford Station and Fairer Fares not being reflected in WECA’s evaluation outcomes, or WECA claiming that residents did not show demand for a station or fairer fares in their consultation responses.
The information under ‘FAQ’ for Saltford was likely added following points raised to WECA’s attention in SPC’s response, and though may have been added with a view to be helpful, may also be perceived to have influenced consultation responses following SPC’s published response being widely shared. For a consistent and fair consultation, additional information should not be added part-way through a consultation, being poor practice and in essence resulting in residents and organisations responding to differing information.
- WECA officers informed residents that items on the consultation website were included ‘by mistake’ or were not correct, steering residents to not respond (or object to) certain proposals.
SPC raises the complaint that residents and others were informed by officers during the open consultation period of information not on – or differing from – the consultation website.
Three examples are as follows: 1) that The Crown pedestrian crossing point would remain (consultation image showed no pedestrian crossing point); 2) That the High St Double Yellow Lines on the (mislabelled Norman Rd and Beech Rd) map were not positioned correctly, and; 3) That the 2hr parking bay by the PO/Library / Coffee Shop was not included in the ‘no parking on right hand of Manor Rd from A4’ (as was clearly stated on the consultation website text). This meant that residents may have chosen not to object to proposals displayed or stated on consultation website.
Similarly to the point above, if residents were steered away from objecting to these, WECA would potentially have evidence that they consulted on these matters and responses showed support / no objection for e.g. no parking on entire right-hand side of Manor Rd which may subsequently provide ‘evidence’ for the removal of the 2hr parking bay.
- ‘Drip feed’ of consultation information impacted and hindered a number of resident responses
Both formal and informal additional information shared during the period that the consultation was open meant that residents were in essence responding to different information as the consultation period went on, with no indication if more information would be released prior to the end date of 1 Oct. This meant that some residents may have delayed responding, ultimately resulting in residents running out of time to respond to the consultation.
- Email responses to the consultation were discouraged
Signposting to information on the option to respond by email or in writing was not made clear on the online survey page (as on the ‘Get Involved’ and ‘Contact Us’ pages, where those looking to respond to proposals may not have seen having been steered to the online survey).
When Saltford Parish Council contacted WECA on 30 August to confirm that residents and SPC could respond by email, the Parish Council only received a response from an unnamed WECA officer on 21 September confirming this as an option. This email was received three weeks after SPC and many residents had looked to submit a view on proposals. (Due to no response to its 30 August email, SPC had asked the presenters at SPC’s 5 September meeting and they confirmed SPC and residents could respond by email, which was shared by SPC after its meeting).
The significant delay to SPC’s email enquiry near the start of the consultation period coupled with limited information on the online survey page was indicative that WECA discouraged email responses, possibly to direct residents to respond via the online survey (see above for concerns about wording of the online survey steering answers).
- Drop in event – not enough officers to adequately listen to resident views/concerns/questions:
The drop-in event did not have enough WECA officers present to adequately listen to the views, concerns and questions of residents. Only five WECA officers were present (with two at the front desk collecting visitor names and post codes) plus a B&NES Officer.
WECA had been advised by the venue in advance of anticipated high levels of attendance (including a change of room to Main Hall to accommodate anticipated numbers), which had also been indicated to officers by the strong presence at WECA’s presentation during SPC’s September meeting. As such the Saltford drop-in event should have been adequately staffed.
SPC received complaints from frustrated residents during and after attendance at the drop-in event that they had been unable to express concerns directly to WECA officers about proposals.
- Drop-in event – numbers & GDPR concerns
SPC raises GDPR concerns with regards to WECA officers asking Saltford residents to add their full names and post codes to a ‘sign in’ sheet on a clipboard left visible to all attendees on the front desk at the WECA drop-in event.
No information was on the sheet or available from WECA officers about what the information was for, how Saltford resident information would be used by WECA (bar for counting attendees, as verbally confirmed by a WECA officer – for which a tally sheet would have been appropriate) or how this personal information would be securely held by WECA.
This approach was not only a clear breach of GDPR, but also meant some residents chose not to add their details. As no other resident count was occurring, and as some residents were unaware of a sign in sheet, as well as a GDPR breach this approach meant that WECA could claim a significantly lower number of attendees at the Saltford drop-in event than were present.
In light of the above, SPC urges WECA to conduct the 2024 consultation in a fair and appropriate manner, which sets out clearly from its opening the information that residents and organisations are being consulted on to prevent the concerns outlined above from re-occurring. SPC also urges WECA to take onboard additional information in its above complaint.
A copy of SPC’s complaint has been published on its website and sent to:
Bath to Bristol consultation email
West of England Combined Authority Officer
Dan Norris, Metro Mayer, WECA
Jacob Rees-Mogg, MP
B&NES Cabinet Member for Highways
B&NES Cabinet Member for Sustainable Communities
B&NES Ward Councillors for Saltford
B&NES Officers including Director of Sustainable Communities, Head of Transport Strategy and Strategic Transport Projects Manager
Saltford Parish Council has requested that an update following the 2023 consultation is provided at the February 2024 Keynsham Area Forum. It has also requested a ‘timeline’ for actions to be made available for residents. SPC understands that the next consultation will take place in September 2024.
To sign up for updates from WECA about the project, visit the HaveYourSay ‘Get Involved’ page of the consultation website at https://b2b.haveyoursaywest.co.uk/index.php?contentid=30 (click on ‘Sign up for updates’ box to the bottom right of the page)
Image shows buses on the A4 Bath Road through Saltford, taken September 2023