EAT on 29th November 2004, reported at [2005] IRLR 242, EAT
an employer "proposes to dismiss" 20 or more employees if he is proposing to make some of them redundant and offer others alternative employment on new terms even if fewer than 20 will actually be dismissed - and he is therefore obliged to consult with them within the time limits and in the manner prescribed by TULR(C)A 1988 s.188.
For relevant general notes see Redundancy/consultation/general and/or Changes to terms of employment