More poor quality consultations from Bolton Council

In Bolton Active Travel Forum, we’ve held several workshops on engagement, yet the Council still insists on running engagements that are flawed in many ways, and are likely to be either misunderstood or misused by decision-makers. This article looks at one that is running right now about a scheme to change several junctions on De Havilland Way in Horwich. In my view, there is a lot wrong with the proposed scheme, but I do not intend particularly to look at those here – that is for the consultation response itself – though I may need to use some examples to illustrate the problems with the consultation.

Lack of context

Bolton has absolutely no overall plan for addressing the need to enable alternative forms of transport, which ultimately will have to involve reallocation of road space to enable walking, cycling and improved public transport. I’m talking about plans like Glasgow’s superb Active Travel Strategy or West Midlands’s Local Transport Plan Core Strategy. Without such a thing, and a serious attempt to publicise and promote it, people responding to a consultation will have no understanding of the context in which a proposal is being made, nor any real feel for the reasons behind it. Real engagement requires a lot more that just sticking a web site up and telling the local newspaper how wonderful a seriously flawed scheme is.

Overall Structure of the Consultation

The top level of the “Have Your Say” section of the consultation provides links to questionnaires that you can answer about specific parts of the scheme.

However, there is nowhere to comment about the scheme as a whole. Either inadvertently or, heaven forbid, deliberately, this constrains the responder to fit within the predefined parameters determined by the team. There is no room here for those of us who like to think more widely about the context and look for alternative solutions.

Even the final free text question only asks: “Do you have any further comments on this junction?” (my emphasis). One of my concerns is that there is a whole, horrendous junction, at Mansell Way, which is not even discussed at all under these proposals, yet there is nowhere to say that!

A consultation is not a referendum.

I’m getting sick of repeating this until I’m blue in the face. The issue here is what I can only describe as an utterly stupid question that appears in every one of these sections:

The one shown here is for one part of the scheme, but each one has a similar question. I can only wonder what the questionnaire designer is hoping to get out of this question, but I do know how it will almost certainly be used. If someone answers that they are “Dissatisfied”, there is no way of knowing what they mean. There is a section later in the form that asks for a free text answer to the question: “Please say why you feel this way”, but it is separated from the “How do you feel” question by a bunch of other questions. The answer to this question could mean anything from “there should be no change here at all” to “these changes do not go nearly far enough and should be made far more ambitious”.

To understand how it will be used, we only have to look at a previous “consultation” on the Chorley New Road cycleways. That contained a similar question, which resulted in the following statement in the committee report prior to the decision to remove the scheme:

“Generally, the scheme has been poorly received with 68% dissatisfied with the scheme as implemented. This is a consequence of both a focused targeting of residents within the consultation area and a dissatisfaction with how the scheme has been left incomplete and compromised through its implementation.”

Despite the qualification provided in the second sentence, the Exec Member responsible for making the decision to remove the scheme, when asked for a justification, stated:

“there was a consultation held regarding Chorley New Road and 68% of the people were against it in the scheme that it was, so the decision was taken in the Executive Member meeting to cancel the wand-orca element of the scheme. He stated that people who read the consultation results had said that 68% of the people were unhappy with the wand-orcas as they were.” (Bolton Active Travel Forum minutes, January 2022)

Effectively, the response to this question had been treated as if it were a referendum, despite only 0.28% of the Borough’s population responding, and even then the figure was misused, taking no account of the ambiguity of the question.

I have very little confidence that the results of the De Havilland Way consultation won’t be misused in the same way. In fact I am very confident that they will be!


In each section, the questionnaire goes on to ask questions like:

“Do you think the proposed changes to ‘Beehive’ junction will somewhat reduce congestion in the area?”

“Do you think the proposed changes to ‘Beehive’ junction will improve opportunities for walking and cycling in the area?”

This is a public consultation. How does the questionnaire designer think the responses to these questions will be of any value whatsoever? I have been studying the subject for about a decade and I still don’t feel confident to answer these questions – especially the congestion one! Most people answering this will have no clue whatsoever about these.

The best that could be asked of members of the general public would be something like:

“Would these changes make you feel comfortable cycling through this route.”

At least that question is one that a typical respondent might be qualified to answer. Beyond that, most people would not be competent to express a view with any real meaning.

The questionnaires do go on to ask the following:

This is better, provided that (a) the team (and the councillors making decisions) actually take notice, and (b) it is again recognised that most of the respondents do not have any expertise in this area. In other words, it is a source of ideas and concerns, which would then need to be checked out by experts in the field and/or actual measurements and modelling, not blindly taken as gospel.

Finally in this part, the following question is asked:

Again, it is to be hoped that lack of expertise of the respondent will be considered in interpreting the result from this question. For example, there are many research studies showing that people who own businesses generally overestimate significantly the proportion of customers who arrive to their business by car (For example, see the references under Myth 4 in this Sustrans report). If there are concerns expressed in this area, the correct action would be to gather together the research and engage with those concerned to allay their fears.

Asking questions like these of people who are in no way qualified to answer them is again likely to result in misinterpretation or even deliberate misuse of the result. Referring again to the Chorley New Road cycleways consultation, after the protected cycle lanes were removed, Councillor Andy Morgan, a member of the council’s cabinet and the de-facto leader of the populist campaign to have the lanes removed said:

“The practicality is that they reduced the carriageway size and so rather than easing congestion and helping the environment we just ended up with stationary traffic caught in congestion.” (Bolton News, 22nd September 2021)

This would appear to be on the basis of completely unverified claims from consultation respondents that congestion was caused. This despite the committee report stating, regarding these responses:

“Congestion was a concern in the consultation although observed queuing appeared to be no worse than pre covid conditions set against evidence that the number of vehicle journeys on our network is now 2% higher. Right turning vehicles were referenced the most for creating congestion and delay. Engineers have confirmed that the narrowest width of the road where there is a right turn pocket is 9 metres. This enables 2 3metre running lanes and a 3metre right turn lane. These are adequate widths in accordance with national guidance Design Manual for Roads and Bridges, and Manual for Streets. Poor lane discipline is likely to be more responsible for congestion created by right turning vehicles.”


It seems that yet another “consultation” is being run that will really not help the decision-making at all, and I have no confidence that it won’t be misused to justify decisions that have already been made. Some would (do) say that we should work with the council to try to improve matters, but I’ve put hundreds of hours of work into trying to do just that. How long must that go on before we just decide that we are wasting our time.

It is worth noting that recent statutory guidance issued by the Department for Transport under the Transport Management Act (2004) states:

“As set out in Local transport note 1/20: cycle infrastructure design, effective engagement with the local community, particularly at an early stage, is essential to ensuring the political and public acceptance of any scheme.”

In failing to carry out consultation properly, a highway authority may find itself in breach of what is a statutory duty under this guidance.

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1 Response to More poor quality consultations from Bolton Council

  1. Darcy says:

    Thank you for everything you’re doing!

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