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16. The architect’s admission that the proposed scheme was “very different” from the pre-
application design destroys the claim that there was no requirement to consult AWVC.
1.4 The Third Reference: Application Forms
17. The third reference appears on the Application Forms. The first form, dated 13 April
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2018 (Folio 1), states that no pre-application consultation had taken place and the
replacement form, dated six days later on 19 April 2018 (Folio 32) states that it had and:
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“Feedback stated that the proposed layout was unsatisfactory and gave the following advice.
A minimum of 50 dwellings would be expected. 30% affordable housing requirement. High
density supported (3+1 storeys)------ recommend contemporary design….. etc”.
The form stated that the meeting had taken place in October 2016 with Mr King. He
processed the application and did not deny being involved in the consultation. His tune
changed later on (see paragraph 2.21).
18. Both forms were certified as true and correct and submitted by Darren Page, of Lytle
Associates. The revised version states that there had been proposals for 70 and 68 units
whereas the Design and Access Statement says the pre-application had been for 90.
1.5 The Fourth
1.6 Reference: File Note of 20 August 2018 Meeting
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19. The fourth reference to the consultation was in the file note prepared by Lytle Associates
of a meeting on 20 August 2018 (see the summary at Attachment 5 and folios 100-103)
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to explain why a detailed schematic of the WH:LIC development had mysteriously
appeared at page 34 of the Design and Access Statement (Attachment 12).
It says:
The “sketch plan” was “only to illustrate that the application scheme does not inhibit the
neighbouring site coming forward in the future. The approach was suggested in the previous
pre-application response”. This is not strictly true.
Mr King appears to have accepted this explanation, without question, but it is not credible,
and it is much more likely that the integrated plan was included by accident:
• It is the only mention in over 2,000 pages of application data of any intention to
develop the WH:LIC site;
• It is not a “sketch plan” but a detailed drawing. The numbering of plans in the Design
and Access Statement suggests that large blocks of drawings had been redacted:
probably because they related to the WH:LIC site;
• The plan of WH:LIC site enclosed with the original application (Attachment 7) –
which was the only clue of the integrated development - was removed from the
revision;
• There was no requirement in the pre-application meeting to produce drawings: the Page 19
advice was to ensure that “consideration should be given to the “adjacent allocated
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