27/02/2026
1. One Page Guidance Note
Why Focus on Procedure, Not Emotion
Peak Cluster EN0710001 – How to Make Your Representation Count
At this stage of the process, the Planning Inspectorate is not deciding whether the project is “good” or “bad”. It is deciding whether the consultation has been legally adequate and whether the application can properly be accepted.
That distinction matters.
Why procedural arguments carry more weight
The Development Consent Order process under the Planning Act 2008 is highly structured. The Inspectorate must assess:
Whether Section 47 consultation duties were complied with
Whether the Statement of Community Consultation was followed
Whether consultation was adequate in substance, not just in form
Emotional objections about risk, anger, distrust, or general opposition are understandable, but they carry less procedural weight at this stage.
Procedural deficiencies, by contrast:
Can delay acceptance
Can require further consultation
Can weaken the applicant’s position
Must be formally considered
The Inspectorate is legally bound to consider procedural fairness.
What strengthens your representation
Focus on:
Timing of disclosure of key information
Whether you were properly notified
Whether dimensional parameters were available during consultation
Whether you were able to make an informed response
Avoid:
Personal attacks
Allegations of corruption
Generalised political arguments
Emotional language
Measured, reasoned, procedural submissions are more powerful.
The key point
If fundamental design information such as AGI height or vent stack parameters was not available during the main consultation period, it is legitimate to question whether consultation was adequate.
That is not emotive. It is procedural.
And procedural arguments are harder to dismiss.
2. Personalisation Checklist
(So submissions are not identical)
Encourage members to adjust at least 2 or 3 of the following:
Add one personal fact
How you became aware of the project
Whether you received a letter addressed to “The Occupier”
Whether you initially thought it was junk mail
Whether you were unaware of AGI height until recently
Add one location reference
State your road or area
Mention proximity to Meols AGI or Coastal AGI
Reference local landscape character
Add one procedural concern in your own words
For example:
“I could not assess visual impact because height information was not available.”
“I was asked to comment before key parameters were defined.”
“The timing of disclosure prevented informed engagement.”
Keep tone calm and factual
Avoid:
Capital letters
Exclamation marks
Accusations
The goal is 50 similar but not identical procedural objections.
Consistency in theme, variation in wording.
