In Schultheis v. Board of Supervisors of Upper Bern Township, Berks County, 727 A.2d 145 (Pa. Cmwlth. 1999), a developer submitted a sketch plan for a proposed residential subdivision. The township engineer reviewed the sketch plan and issued a review letter indicating the plan was deficient under the subdivision ordinance because of the lack of soil percolation and probe tests and wetlands delineation. About five months later, the developer submitted his preliminary plan. A week after submission of the preliminary plan, the township adopted a new zoning ordinance that reduced the number of permissible lots for the proposed development. The township engineer then issued a review letter indicating the plan was deficient under the subdivision ordinance with regard to soil percolation and probe tests, wetlands delineations and erosion and sedimentation controls. Shortly thereafter, the township's governing body denied the plan based on the deficiencies cited in the review letter. After the denial, the developer submitted additional information in an attempt to cure the deficiencies. On the developer's appeal, the trial court held the grounds for denial were relatively minor; accordingly, it remanded the matter in order to provide the developer an opportunity to correct the deficiencies. On further appeal, however, this Court reversed, holding the deficiencies were substantive and, therefore, justified outright denial of the plan. The Court stated the degree of deviation from the relevant ordinance requirements was not critical where it was clear the plan did, in fact, deviate from the requirements. The Court further stated neither case law nor the ordinance required the governing body to grant conditional approval or permit the developer to revise his plan; rather, the governing body was only obligated to review the plan as submitted.