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Joint Core Strategy - Issues and Options

Joint Core Strategy - Issues and Options


List of answers to the specified question

4.1.7 Paragraph 22 of the NPPF 2018 states that "strategic policies should look ahead over a minimum 15-year period from adoption". Gladman therefore suggest that the JCSR should plan for an extended period in accordance with the NPPF18 ensuring that the review can anticipate and respond to long term requirements.


01 Apr 2019 15:57

The NPPF paragraph 22 states "Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure". If the JCS review is undertaken by December 2022 then the plan period should be extended until December 2037 in line with NPPF.


01 Apr 2019 15:39

The IOD rightly states (at para 3.2) that the new strategic policies within the emerging JCS should look ahead at least 15 years from adoption in line with the NPPF. Given the uncertainty as to the precise adoption date, this is likely to be 2021 at the earliest, and potentially beyond that. This would lead to an end date of 2036 at the earliest. However, we do not consider this to be sufficient to allow the three LPAs to plan effectively for the future growth aspirations across the area.

It is clear that the three LAs are looking to establish a long-term strategy framework for growth as part of the ‘Gloucestershire 2050’ project. These include potential a population of 520,000 people, and the delivery of c.2,500 new homes every year over the next 32 years (80,000 homes in total). It is acknowledged that this is in part aspirational and clearly does not suggest that the plan period should be extended to 2050 at this time. However, the 2050 project includes some ambitious plans and proposals that will require significant co-ordination and forward planning if they are to be progressed in a timely manner.

Furthermore, it would seem sensible to align itself, as much as practicable, with those neighbouring areas that are also updating their plans to ensure consistency between plans across boundaries i.e. South Worcestershire Joint Planning area who are reviewing their plans beyond 2036 (up to 2041).

Consequently, for the reasons set out here, it is our view that a reasonable timeframe to support and facilitate the delivery of these proposals, amongst others elsewhere across the joint area. Such a timeframe should cover a period beyond 2036, and potentially up to 2041, to support the phased release of land and infrastructure needed to facilitate the delivery of the quantum of development being considered.

28 Mar 2019 12:49

If there needs to be a 5 year review in 2021 then there are merits in extending this study to cover that review. However care should be taken to ensure that unrealistic expectations of future housing need are not built into a plan at too early a stage. The review needs to focus on an evidence-based approach for housing need and not get ahead of itself.

27 Mar 2019 16:54

RPS notes the commentary set out in paragraph 3.3 of the IOD, which recognises that extending the timescale beyond 2031 would provide opportunities for closer, more strategic planning with adjacent areas, helping to tackle cross-boundary growth issues. In this context, RPS notes the specific references also made to the emerging review being progressed by the South Worcestershire Authorities, along similar timelines to the emerging Plan. This is a sensible approach to both addressing cross-boundary development growth, as well as ensuring the appropriate contributions from new development can be maximised for the benefit of local communities.

A longer timescale beyond 2031 would clearly facilitate a more comprehensive approach to planning for future growth. Consequently, RPS would suggest that a timescale up to at least 2041 would be consistent with those adjoining areas who are also progressing their respective plan reviews and would allow for more effective and constructive cross-boundary working, including how to plan for the future housing needs of Tewkesbury in the context of its current acknowledged housing land supply shortfall.

It is noted, however, that housing delivery at Mitton to assist in meeting Tewkesbury’s needs is identified within the first five-year period of the current housing trajectory.

27 Mar 2019 16:27

Agree, the plan period should be extended to 2036.

27 Mar 2019 15:36

We do not consider that the plan period should be extended as part of the review. This will simply add complexity and delay.

We find the reasons for proposing such an extension to be unconvincing.

As regards paragraph 3.2, a review of strategic policies can look forward beyond the plan period and does not require it to be extended. For example land is "safeguarded" or taken out of Green Belt to cover possible requirements beyond the end of the plan period.

In response to 3.3, what other Councils are doing is down to them and based on their own individual fact pattern. This may not be the same as the JCS Councils and therefore other Council’s review periods should not be regarded as models to be followed.

Paragraph 3.4 diverts attention away from where it should be focussed - on the execution and delivery of the existing plan rather than on planning even further into the future.

This is particularly illustrated by consideration of infrastructure requirements discussed in 3.5. Delivery of the large strategic site at North West Cheltenham is at a standstill because the Councils are apparently unable to deliver on the transport and other infrastructure necessary for it to proceed. This is notwithstanding that it has been a proposed site for many years. They should focus on that, i.e. the here and now, first.

The Gloucestershire 2050 project is a red herring. It is far too vague and dreamlike to have any place in this review.

27 Mar 2019 14:55

To 2036 is long enough, and considering that the principal synchrony needs to be with Stroud DC (for burgeoning Gloucester's expansions, to South and East).

Looking beyond (as far as 2041) just facilitates the allocation of yet more site "options" for developers, whose laims will always be as over-aspirational as at the JCS (successfully) and equally out of touch with what is being delivered, and whether demand for so very much additional Employment land can materialise.

No further site supply (options) should be created to undermine the urgent delivery of Cheltenham NW and Cheltenham West. (Otherwise, the Cheltenham 'Safeguarded' land risks being phased ahead if more profitable for developers.)

27 Mar 2019 14:26

The JCS Issues and Options paper (IOP) recognises that the National Planning Policy Framework (July 2018) (NPPF2) states that strategic policies should look ahead at least 15 years from the point of adoption (paragraph 22).

Based on the Plan Making Programme set out at paragraph 1.19 of the IOP, adoption is anticipated in 2021. On that basis, paragraph 3.2 notes that this would require extending the plan period to at least 2036 which would accord with the NPPF2 guidance. However, given the potential for delays in plan production, the strategic nature of the JCSR and the need to ensure a plan period of a minimum of 15 years from the point of adoption, we advocate a plan period up until 2041.

27 Mar 2019 13:06

Paragraph 22 of the NPPF (July 2018) states that strategic policies should look ahead over a minimum 15 year period from adoption. The JCS Review should plan for an extended time period in accordance with the 2018 NPPF.

27 Mar 2019 12:28
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