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Joint Core Strategy - Issues and Options

Joint Core Strategy - Issues and Options


List of answers to the specified question

4.1.8 In line with requirements set out at Paragraph 17 of the NPPF18, the GCT JCSR should include strategic policies which address the Council’s identified strategic priorities for the development and use of land across the plan area. The Council’s should further refer to Paragraph 20 of the Framework which states that these strategic policies should identify an overall strategy for the pattern, scale and quantity of development.


4.1.9 The JCSR review must consider the implementations of the governments Standard Methodology for calculating housing need, this should include consideration as to what uplift may need to be applied to consider issues such as economic growth. Once this is done thought will need to be given as to whether the current proposed distribution of growth is the most appropriate strategy for delivering these needs. As part of this process the Councils will be required to consider the deliverability of any strategy proposed, and particularly the deliverability of any proposed major strategic sites, in light of the changes to the definition of deliverability in Annex 1 of the NPPF2018.


01 Apr 2019 15:57

The JCS should consider strategic policy that is consistent with paragraph 20 of the NPPF which sets out that sufficient provision should be made for housing, employment, retail, leisure and other commercial development whilst consideration is made towards the conservation and enhancement of the environment.


01 Apr 2019 15:39

See answer 4

28 Mar 2019 12:49

See question 4

27 Mar 2019 16:27

The JCS review should exclude Policy SD2 as it is required to be subject to a separate, immediate retail review for completion by the end of 2019, all in accordance with commitments already given.

27 Mar 2019 15:36

See 1. above.

27 Mar 2019 14:55

All further incursions into the much diminished Green Belt ought to be approved first via a full JCS Examination, not via a more time-limited Local Plan inquiry (as is currently scheduled for Cheltenham, with no multi-stage cross-questioning of "evidence").

All further Housing sites proposed for more than 50 units bordering Cheltenham or Gloucester City will inevitably be cross-boundary issues into TBC territory, and therefore need strategic JCS-2 approval and apportionment.

All DtC 'agreements' should be approved via full JCS-2 Examination, not as ad hoc (or single Local Plan) deals.

27 Mar 2019 14:26

In line with paragraph 17 of the NPPF2, the JCSR must include strategic policies to address each local planning authority’s priorities for the development and use of land in its area. These strategic policies should set out an overall strategy for the pattern, scale and quality of housing, economic, infrastructureand community development (paragraph 20).

In addition, strategic development locations should be ‘allocated’ through the JCSR as opposed to the allocations coming through future development plan documents.

27 Mar 2019 13:06

Paragraph 20 of the NPPF (July 2018) states that strategic policies should set out an overall strategy for the pattern, scale and quality of development. It continues by stating that policies should also make provision for housing, employment, retail and other commercial development; infrastructure; community facilities; and conservation and enhancement of the natural, built and historic environment.

Paragraph 21 of the NPPF makes it clear that strategic policies should be limited to those necessary to address the strategic priorities of the area (and any relevant cross-boundary issues).

Paragraph 23 of the NPPF states that strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period. This should include the allocation of sufficient sites to deliver the strategic priorities of the area.

27 Mar 2019 12:28

The benefits of a two-tier system are recognised and are supported within the NPPF. There does however need to be clarity in the top tier plan how local plans are to deal with issues that may arise when they come to allocating smaller sites for development, for example, how they may deal with non-strategic Green Belt release.

The main strategic topics the JCS should cover include housing, infrastructure, Green Belt, and employment. Importantly, the JCS should identify strategic development locations which meet need where that need arises, as was discussed in the previous JCS EIP and concluded in the Inspector’s Report. The JCS should identify any new strategic development locations as well as a housing distribution figure for each of the main settlements, the latter to guide smaller local plan site allocations which maintain the overall spatial strategy.

Due to delays in producing the Central Severn Vale Transport Model when the JCS was being produced, its impact upon the delivery of strategic sites was not properly considered. Many of the M5 motorway junctions are unable to accommodate traffic generated by substantial growth and, as such, are reliant upon a mixture of funding sources to improve their capacity. The ability to deliver strategic highway improvements is something that will take time. As infrastructure comes late in the process, there is a real concern that it will also prove to act as a brake upon strategic housing growth within the JCS area. This round of JCS review has the opportunity to consider infrastructure needs early in the plan production and ensure that the delivery of sites is not delayed. Locations such as Ashchurch which has received HIF support should be a housing priority area.

Our client’s position, consistent with paragraphs 138 and 139 of the NPFF 2018, is that development options that do not require another Green Belt review should be the focus of any additional development. This includes Ashchurch as a non-Green Belt location. The previous Green Belt review should endure well beyond the current JCS plan period.

27 Mar 2019 12:12
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