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Joint Core Strategy - Issues and Options

Joint Core Strategy - Issues and Options

Responses

List of answers to the specified question
ResponseOptionTextDate
#714423

4.1.5 Gladman consider that a comprehensive and robust review is the correct approach for the JCS

review.

4.1.6 As the Council’s will be aware on the 24th July 2018, the government published a revised National Planning Policy Framework. The revised Framework states at paragraph 213 that ‘the policies of the previous Framework will apply for the purposes of examining plans, where those plans are submitted on or before 24 January 2019.’ As such the Council’s will need to ensure that all policies are reviewed and are consistent with the NPPF18. Further it is essential that the shortfall arising from the removal of the MoD Ashcurch land allocation from the JCS is addressed in full.

 

01 Apr 2019 15:57
#714414

Yes, Bruton Knowles support the review of the JCS. The review is required in accordance with the updated National Planning Policy Framework (NPPF) (paragraph 33), where reviews should be completed no later than five years from the adoption date of a plan (by December 2022). Only with a comprehensive holistic review of the JCS area can the issues and options for the area be properlyaddressed.

 

01 Apr 2019 15:39
#713403

MHL agree that a comprehensive review of the emerging plan is the correct approach. This is particularly the case in respect to the scale of housing need and housing land supply, for two main reasons. Firstly, there is an increasing need for housing based on the Council’s own published evidence. An initial comparison of the adopted JCS (uplifted) ‘demographic need’ OAN and the latest Standard Local Housing Need calculation suggests an overall increase for the three LPAs as a whole (see the summary table below). The figures are set out here because they represent the ‘adjusted’ demographic needs using both calculations prior to any further adjustment being made to tackle affordable housing needs. The adjustment to the JCS figure is an economic uplift, whilst the standard method figure applies the affordability factor as per the new methodology.

JCS demographic need OAN with economic uplift (dpa) (taken from JCS 2017)

Gloucester 683
Cheltenham 520
Tewkesbury 471

Local housing need (‘Standard method’) (dpa) (taken from 'Implications of the Government’s new standard housing need formula for Gloucestershire', Neil McDonald September 2018)

Gloucester 652
Cheltenham 539
Tewkesbury 580

Difference

Gloucester -31
Cheltenham 19
Tewkesbury 109

The two sets of figures indicate that the bulk of the likely increase in the housing need (and consequently an increase in the housing requirement) the JCS area will largely fall within Tewkesbury. This is, however, before any additional allowances or uplifts are applied to the standard local housing need to address any reasonable ‘policy on’ factors, for example affordable housing need or economic growth, which may impact on the final requirement. Nonetheless, the outcome will most likely result in an increase in local housing need and housing requirements across all three authorities and not simply Tewkesbury.

Secondly, it is acknowledged in the IOD (at para 2.3) that the strategic allocations identified in the JCS have not progressed as quickly as anticipated. This has impacted on the delivery of housing in the early years of the current plan period, resulting in shortfalls in completions across Gloucester and Cheltenham. This has further compounded the under-supply of housing and the shortfall in allocations through the adopted JCS in both Gloucester and Tewkesbury.

Consequently, it is our view that there is a pressing need to address the shortfall in housing land supply across the JCS area as a whole, as well as tackling the under-delivery of those strategic sites that were allocated. This is likely to be brought into sharper focus given the potential for an increase in the overall housing requirement based on the new standard method, and the likely need for other appropriate adjustments to respond the issues including affordable housing need and economic
growth.

28 Mar 2019 12:49
#711643

RPS notes the commentary set out in paragraph 2.1 of the IOD, which recognises the review needs to address the housing shortfalls across the JCS area, in particular within Tewkesbury District. RPS also notes (in paras 2.4-2.5) the suggestion that it may be more practical to look at housing supply in a more comprehensive way, which we would also support. Clearly, a more comprehensive review would allow for the full consideration of the options available to assist in addressing the current and future housing needs of the area.

27 Mar 2019 16:27
#711497

Representations on behalf of Gloucester Quays LLP/Peel Land & Property (Peel Group)

The timescales for the comprehensive review do not accord with the JCS Councils’ commitment (Policy SD2 of the adopted JCS) to complete an immediate retail review by December 2019. The immediate retail review has to be progressed separately from the wider JCS review which is not programmed for adoption until March 2021 at the earliest (some 15 months later). Therefore, the comprehensive review needs to exclude a review of JCS Policy SD2 (Retail and City/Town Centre), which instead needs to be carried out independently and with immediate effect in advance of the wider review.

27 Mar 2019 15:36
#711448

Reading the Issues and Options paper, one might be forgiven for thinking that what was being proposed was not a review at all but an entirely new Joint Core Strategy. This is absolutely the wrong approach.

The original Joint Core Strategy ("JCS") was incredibly detailed. It took many years and cost many hundreds and thousands (if not millions of pounds) to bring to adoption. It only received approval during Examination in Public ("EiP") on the basis of the JCS Councils agreeing to immediate reviews for Gloucester and Tewkesbury housing needs and to an immediate retail review. We are not aware that much of this work has actually happened beyond Tewkesbury starting to look at future development around Ashchurch (see 13.) and the engagement of consultants in respect of retail (see 11.).

In addition there were monitoring and review provisions in the JCS which were intended to trigger a review should the delivery of developable sites fall behind the planned trajectory. It is presumed that this has happened for Cheltenham and Gloucester.

Given the massive investment that has already taken place in the JCS in terms both of time and money, it is clearly wrong, only just over a year after adoption to now effectively start afresh and write off all that investment.

We consider that the review should instead focus primarily on the undertakings made by the three Councils during EiP and on those which may have subsequently arisen under provisions contained in the JCS. It is understood that these are:

  • Housing delivery at Gloucester and Tewkesbury
  • Retail review
  • (Presumably) shortfall against trajectory of deliverable sites.

Naturally to these must be added other external requirements for review (Para 33 NPPF 2018/Regulation 10A of the Town and Country Planning (Local Planning) (England) Regulations 2012).

However this should not amount to a re-performance of the entire JCS process. If this is allowed to happen then inevitably it will lead to delays in the process and the time limit for the review of policies in Paragraph 33 (to be completed by December 2022) will not be met.

Instead the Councils should be focussing on what they have promised to do hitherto and what really has to be done.

27 Mar 2019 14:55
#711396

No.

For Cheltenham, simply update its distinctive/unique 'retained' Retail Policies "immediately", as promised by the JCS, and as is urgent for CBC’s development control.

These Cheltenham-specific Retail policies, handling this historic town's long-established Hierarchy of shopping districts, are arguably non-strategic (not in-common) and could be progressed immediately in the Cheltenham Local Plan. Once agreed, they would not need to conflict with the less elaborate Retail Policies for TBC and Gloucester City (focused mainly on their 'town centre' shopping district) if those authorities need to take longer to develop Retail policies from 'cold' (via JCS-2).

27 Mar 2019 14:26
#711289

VSM and the DIO supports the JCS Councils in undertaking a comprehensive review of the adopted JCS. It is considered essential to ensure that an up-to-date, co-ordinated and managed response to the economic, housing and infrastructure needs for the JCS authorities.

27 Mar 2019 13:06
#711264

A comprehensive review of the plan is considered to be the correct approach.

27 Mar 2019 12:28
#711255

A comprehensive review of the Plan housing and land supply policies is welcomed.

A comprehensive review, across all three Authority areas, is the best way to ensure that the next Plan is well equipped to identify the most sustainable portfolio of sites going forward to meet the area’s needs. This review must be comprehensive to allow the most sustainable sites to be delivered regardless of administrative policy boundaries.

Without a comprehensive review of the housing need and supply policies, it is unclear how significant strategic issues, could be addressed in a co-coordinated way.

Moreover, as discussed in relation to Question 2, there is considerable uncertainty around the emerging (minimum) Plan housing requirement at the moment. It is expected that further rounds of Consultation regarding the Standard Method and new household projections will take place before the JCS Plan is submitted to the SoS. Not commencing a comprehensive review of land supply at this stage could hinder the ability for the emerging JCS Plan to be flexible enough to manage the uncertainty as the Plan progresses to publication.

However, it is recognised that a comprehensive review of the whole JCS Plan is a timely and costly exercise for the Councils and not all policies need reviewing in light of changes in the NPPF. Therefore, in order to simplify the Plan review process and speed up its potential examination and adoption, there may be merit in a light touch review of some of the Development Management policies and other areas of the plan not related to housing land supply and need, where they remain in conformity with the new NPPF.

With specific reference to paragraph 2.2 of the Issues and Options document, in the event that the JCS does not undergo a holistic review, the very latest a review would need to be completed is December 2022 as instructed by the Inspector at the last EIP of the JCS, where it was concluded that the housing supply was just over 5 years taking the JCS to Dec 2022. This would however place significant pressure on the process and may result in the rolling 5-year land supply failing. It also places pressure on the JCS to be found sound quickly and there would be lots of uncertainty if this is not achieved. Our representation is unequivocal; a comprehensive review is necessary now.

 

27 Mar 2019 12:12
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