Whether or not as part of pre-application community consultation promoters can require people to submit their comments in writing.

As you?re no doubt aware S. 50 (3) of the 2008 Planning Act (the Act) requires applicants to have regard to guidance issued by the Secretary of State and the IPC about how to comply with the requirements of chapter 2 of the Act (pre-application procedure). Particularly relevant to your query is the CLG Guidance ?Planning Act: Guidance on Pre-application Consultation? (2009) and the IPC Guidance Note 1. None of the guidance documents explicitly state how applicants should be prepared to receive consultation comments. Instead the CLG Guidance sets out the principles and objectives that consultation should fulfil ? of which I have drawn out and summarised those which seem most relevant to your query:
Para 16 ?(?) a community involvement process should ensure that people: (i) have access to information; (ii) can put forward their own ideas and feel confident that there is a process for considering ideas; (iii) have an active role in developing proposals and options to ensure local knowledge and perspectives are taken into account; (iv) can comment on and influence formal proposals; (v) get feedback and be informed about progress and outcomes;
Consultation should be fair and reasonable for promoters as well as communities. To ensure that it is fair to all parties, promoters should be able to demonstrate that the consultation plan is proportionate to the impacts of the project in the area that it affects (para 54);
For effective consultation promoters need to take an inclusive approach which ensures that different groups have the opportunity to participate and are not disadvantaged in the process (para 60);
Promoters should actively engage (para 63) with communities and consult using a range of methods in addition to written consultation in order for the consultation to be more effective at reaching different communities (para 62);
It is important that consultees respond in good time to promoters (para 79);
?Promoters should therefore be able to demonstrate that they have acted reasonably in fulfilling the requirements of s.49 of the Act, to take account of responses to consultation and publicity? (para 88);
In summary, the guidance doesn?t specifically prevent you from limiting consultation responses to written comments ? as long as you can still demonstrate that your consultation nevertheless complies with the requirements of the Act and the principles and objectives set out in the guidance. You may also want to informally consult with Carmarthenshire County Council on this issue as they may have relevant experience to assist you in this decision. For example, they may be able to advise on providing different and appropriate written response opportunities in the area (like email, letters, ?comment cards at exhibitions?, drawing on plans etc). Furthermore, given the Local Authority?s role in formally commenting to the IPC on the adequacy of pre-application community consultation at acceptance, you may therefore wish to discuss with them how they would view such an approach.
As I explained on the phone, at acceptance the IPC must be satisfied that the pre-application consultation was compliant with the requirements of the Act and that guidance has been followed - or where it has not been followed there are good, clearly explained reasons for it. Para 86 of the CLG guidance on pre-application sets this out in detail.
You should also bear in mind that S. 47(7) of the Act places a statutory duty on the applicant to carry out pre-application consultation as proposed in the SOCC. You should therefore ensure ? and may want to seek legal advice on this matter - that what you do in the community consultation is in line with what you indicated in your SOCC, fulfils the requirements of chapter 2 of the Act and that you can demonstrate you have taken account of the relevant guidance.