We write further to our earlier objection letters dated 28th August 2020 and would like you to consider this supplemental objection in your determination of this planning application. It remains unclear if the Council is minded refusing this application. We have taken legal advice in respect of the application and this includes a review of the up to date responses from statutory consultees and the new information submitted by the applicant in May. For the reasons set out below, it is considered that any grant of planning permission would be unlawful and susceptible to judicial review.