Allocations: Schedule of modifications

Mr. Smith. I attended Day 1 of this PE and gave you an explanation of why in each Location/Site Allocated the Council had adopted a max 5% Cap. I note from your Interim Letter/Report that you require the Council to delete this in every instance by Modification to render the CS Sound. Please consider this representation an objection to apply to every instance of deletion without limitation.

You mention the "early" Revision of The Core Strategy which was determined to be required by Ms. Graham in 2011; Your Quotation is "the Council is committed to an early review of the Core Strategy which is due to begin in 2014" (EXA175a).

You state that the Council will commence the Revision of The Core Strategy in January 2014 and I would say that by referring to this that obviously see some reliance and relevance to this in the findings of your Interim Report.

Officers have opined that the Revision of The Core Strategy can only be taken forward with the publication of the SHMA 2013. This has not taken place and I think you need to be cautious with assuming that there will be an "early" Revision of The Core Strategy. Perhaps you need to discuss this further with the Council or make a further requirement with dates.

As to the 5% Cap if the "early" Revision of The Core Strategy were to be proceeding with greater commitment from the Council then I believe that you could reverse your decision and retain the cap because of the greater assurance that could be given to providing the 5 year supply because concerns over certain Sites could be put aside with replacements that will come forward.

Furthermore I believe that to have deleted the Cap in all Locations and Allocated Sites means that any site may now deliver 30 houses per Hectare, which I believe to be the maximum density determined by the Government but the Sustainability Appraisals do not support such density. Mr. Smith, you drew attention to this issue in EXA 167 "The Council should also bear in mind the possible need for further Sustainability Appraisal" and whilst this quotation was not made in that exact context the issue is of equally direct and determinative in relationship to deletion of the Cap.

As new Sustainability Appraisals would now be required and this could cause the CS to stall and I would recommend that the 5% Cap is retained.

In addition as the CS including the Cap and subject to defined housing numbers was previously consulted upon surely a further public consultation must be undertaken that makes it quite clear what the impact of deleting the Cap will have. This is not made clear in this Consultation and deletion of the Cap under these circumstances would be legally flawed and render the decision Unsound.