Page 6 - John Belsey

Paragraph 1
Misleading Applications

Replacement Application
8. On 6 June 2018 (Folios 37-38), Henry Jezeph of Lytle Associates submitted a report of
th
13
the consultation and, as a result, Steven King validated the application (Folio 39). It was
supported by an Application Form (Folio 32), dated 19 April 2018.– again prepared and
th
certified as true by Darren Page of Lytle Associates .
14
9. The form is materially different from the original version;
• The applicant is shown as Ashgrove Homes Limited & GCP Developments Limited.

This conflicts with Mr Owen’s statement at the consultation meeting that GCP was not a
participant in the project:

• Point 5, states that the pre-consultation had taken place with Steven King under
reference DM/16/2845 on 13 October 2016. Incredibly, Mr King did not challenge
th
this misrepresentation;

• Point 17 proposes 50 market housing units, 11 social rented housing and 10
intermediate housing= Total 71.
10. The MSDC website records that the revised application (Folio 32) was loaded on 23 rd
April 2018, but this is unlikely to be correct. It was more likely to have been after the
consultation report and not loaded until around 11 June 2018. I do not understand the
th
significance of this apparent backdating.
Suspected Misstatements
11. The statement on both the original and replacement application forms (Point 5) that the
“site was not currently vacant” is wrong and self-serving. Its probable objective was to
establish the foundation for hyperbole in the Traffic Statement (Folio 30) that the
proposed development reduced “existing” traffic flows by 38%. In fact, “existing” traffic
flows from the vacant EDF building were approximately zero and, when it had been
occupied, flows were in the opposite direction (for example, incoming in the morning
rush hour, whereas for residential developments the flow is outwards). The TRICS data
used was not a valid base and the transport reports are farcical (see paragraph 5).

12. The original application included a plan of the rear of Wealden House (Attachment 6)
which is relevant only to the integrated development and was probably included in error.
The plan misrepresented the WH:LIC boundary in a way that would permit the
development to spill over to land belonging to Ashbourne Park.

15
The plan has been removed from the substituted application without comment .
A MISLEADING “MINIMUM EXPECTATION” FOR WH:EDF
Supporting Pillars
1. The current application to build 71 units on the WH:EDF site is based on four pillars that
are manifestly wrong. The application and supporting documentation state or imply that:

a) The site was supposedly designated in the AW Neighbourhood Plan with a “minimum
expectation” of “50”+ units which was “indicative” of 71;
b) Affordable housing was additional to the 50+ units;

c) The area is “starkly urban” thereby justifying a “utilitarian” design and excessive
density.

Page | 6