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1.2 The First Reference: Commentary on Planning Issues
11. The first reference appears on 6th April 2018 in Mr Taylor’s “Commentary on Planning
Issues”(Folio 3). In paragraph 10.1 it lists five “specific requirements” that emerged from
the consultation but makes no reference to the number of units supposedly demanded by
MSDC. There is only one mention of the “50+ units” and that is in relation to the
Neighbourhood Plan which Mr Taylor explains;
“[which] does not specify the capacity of the site in terms of number of residential units,
instead quoting an "approximate capacity" of 50+; which is indicative of an acceptance that
capacity is substantial and [that a] greater number of units can be produced here, subject to
design”.
12. Mr Taylor had no justification – other than wishful thinking - for interpreting the term
“approximate capacity” as the basis for increasing the number of dwellings by 40%: from
50+ to 71 by adding 21 units of affordable housing. He is a town planning expert and
must have known that figures in Sustainability Reports and associated plans are usually
inclusive of affordable housing.
1.3 The Second Reference: Design & Access Statement
13. The second reference to the pre-application consultation, again dated April 2018, was by
Lytle Associates. Section 3 page 17 of its Design and Access Statement (Folio 23-25).
14. It lists 15 points that supposedly emerged from the consultation including:
• The scheme was for an eclectic mix of 90 town housing and apartments:
• “Feedback stated that the proposed layout was unsatisfactory and gave the following
advice”:
a) A minimum of 50 dwellings would be expected;
b) 30% affordable housing requirement;
c) High density supported (3+1 storeys);
d) Recommend a contemporary design approach;
e) Consideration of adjacent allocated site
The design could not have been unsatisfactory (point a above) because it had too few units
when it already had 90. The syntax suggests that the objection was that there were too
many units.
15. The Design and Access Statement continues: “whilst the layout and [current] proposals are
very different from those submitted in 2016, every effort has been made to incorporate
the advice provided—". In fact, most of the 15 points of “advice”, “specific requirement”,
“feedback” or whatever terms MSDC used were ignored: including underground and
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concealed parking and the need for open spaces.
E:\Cobasco\Personal, House and computer instructions\EDF and WH Development\MJC
Plans theories and Objectives\CONSOLIDATED SUBMISSIONS\4a Mr Ashcroft 7th Dec
2018.docx