Page 9 - John Belsey

Paragraph 2
Minimum Expectations or Requirements

• It is significant that of all of the sites evaluated by the Steering Group and MSDC,
WH:EDF was the only one where a deduction should have been made for ancient
woodland and where DdHa was so grossly excessive (See Attachment 8).

The two figures of “50+” and a derived total of between 20 and 33 units are so discrepant
that it is astonishing that everyone failed to notice it.
How the Error Occurred
7. The question is how could such a serious error have occurred and remain undetected by
planning professionals? The answer appears to be confusion rather than skulduggery and
resulted from the calculation being based on the gross area of 1.6(47) hectares in the
AWNP of “sites submitted” without any deduction for ancient woodland. Development
of such an area on the scale of 28 DdHa would result in 47.76 units. Addition of the 10%
“buffer” suggested in the proposed NPPF update (see Taylor report paragraph 5.6) would
result in 51.52 units (ie “50+”).
8. I have tried to resolve the discrepancy with members of the Steering Group but my
telephone messages have not been returned.

Pre-application Consultation
9. The 2016 pre-application consultation has been elevated - with a significance far beyond
its worth - to support over-development of the WH:EDF site.
10. The consultation is supposed to have taken place between MSDC and architects Robert
Davies John West Limited, representing an unidentified developer (DM/16/2845). No
official record has been produced of the meeting, but AHLs’ application includes four
different hearsay accounts that refer interchangeably to MSDC’s “advice”, “feedback”,
“minimum expectation”, “specific requirements” and “approximate capacity”.

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
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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.
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).

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