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Joint Core Strategy - Issues and Options

Joint Core Strategy - Issues and Options


List of answers to the specified question

4.1.11 Gladman refer the Council’s to Paragraph 35 of NPPF18 which states that local plans should be positively prepared and provide a strategy, which as a minimum, seeks to meet in full local housing needs and further, is informed by agreements with other authorities, so as to ensure that any unmet need arising from neighbouring areas is accommodated where appropriate. In order to meet in full, the legal requirements of the Duty to Co-operate, the Council’s should engage on a constructive, active and on-going basis with neighbouring authorities to maximise the effectiveness of plan making.

4.1.12 In line with the requirements of the Framework, it is essential that the GCT JCSR is prepared through joint working on cross boundary issues, such as where unmet need arises. This includes close working with Stroud District Council and other neighbouring authorities. A Statement of Common Ground (SoCG) signed by all respective authorities, in accordance with the Paragraphs 24, 25 and 27 of the NPPF18, should address the meeting of unmet needs.


01 Apr 2019 15:57

Paragraphs 24 to 27 of the NPPF set out guidance for the duty to cooperate. The JCS review must consider these paragraphs. Paragraph 27 particularly illustrates that in order to demonstrate effective and on-going joint working, strategic policymaking authorities should prepare and maintain one or more statements of common ground, documenting the cross-boundary matters being addressed and progress in cooperating to address these.

Given the location of our client’s site to Wychavon District Council’s administrative area there is the opportunity to assess and work with South Worcestershire’s review of its Development Plan which is ongoing. Only with a joined up approach to the housing need and supply across the wider area will proper planning be achieved.


01 Apr 2019 15:39

It is noted that the JCS Inspector’s Report (Oct 2017) indicated at paragraphs 35 and 36 that extensions to Gloucester and extensions to Cheltenham should relate to the needs from those administrative authorities. In this context the JCS review should continue with this general approach and MHL land interests at Fiddington have the clear potential to assist with delivering housing for the future needs of Gloucester City.

35. The JCS Councils intended to apportion supply between the three authorities so that housing on the edge of Cheltenham contributed towards Gloucester’s and Tewkesbury’s needs, and housing on the edge of Gloucester contributed towards Tewkesbury’s needs. However, the proposed [submission] methodologies for distributing supply from shared urban extensions as they were built out seemed over-complicated and uncertain, potentially leading to five-year housing land supply issues between authorities. None of the methodologies presented appear effective and are, therefore, unjustified.

36. The primary reason for allocating urban extensions around Gloucester and Cheltenham is to meet the unmet needs of Gloucester and Cheltenham where that need arises. The proposed apportionment would not fulfil this aim and, therefore, is unjustified. The most logical and effective way forward is to simply allocate Gloucester’s strategic allocations to Gloucester, Cheltenham’s to Cheltenham, and those in the wider Tewkesbury Town/Ashchurch area to Tewkesbury. The JCS authorities have accepted this approach, which is reflected in MM026.

28 Mar 2019 12:49

RPS notes the inclusion of a specific section on the duty to cooperate, in particular the specific reference made to the Land at Mitton. We therefore agree with the aims and objectives of the duty set out in paras 5.2-5.3 of the IOD.

The potential for the delivery of new development in a location contiguous with the boundary of the JCS area, but also adjacent to the existing built-up area of Tewkesbury, offers an opportunity to deliver sustainable development that can also contribute towards addressing the needs of Tewkesbury District. The current adopted plans for both the JCS and South Worcestershire already acknowledge this. Therefore, this is clearly a strategic matter under the duty to cooperate that should be resolved through the reviews of both the emerging Plan and South Worcestershire Development Plan reviews.

27 Mar 2019 16:27

Any duty to co-operate issues will only arise as a result of the JCS review and not before. It would therefore be premature to start thinking about them now.

As pointed out in 5.1, the JCS Councils meet this obligation as they have a single JCS for the three authorities. It is worth reminding ourselves of the rules that have to be followed when allocating strategic developments against each Council’s individual housing need. In particular the requirement that development around the Cheltenham area, even if it is within Tewkesbury Borough Council is for Cheltenham’s account alone. There is a corresponding rule for Gloucester.

If Gloucester has a shortfall that it cannot meet itself or by co-operation with Stroud then it should took to non-Green Belt land to the west of the city and over the river rather than sites in the already much-diminished Green Belt to the north.

The Gloucestershire LEP is a quango. Whether it is regarded as a good quango or a bad quango will depend on one’s point of view. It seeks to maximise economic growth in the county and to this end it will no doubt continue to lobby the JCS Councils. However the LEP’s vision of economic growth is not the be all and end all of planning and indeed is likely to involve a cost to the existing population.

Whilst the JCS councils might be expected to hear what the Gloucestershire LEP have to say, this is no different from their being expected to hear what any other concerned resident or business have to say. Planning is to a large extent a question of evaluating and balancing evidence from many different sources.

However we consider that the JCS Councils certainly have no duty-to-co-operate with the Gloucestershire LEP either within the provisions of the NPPF or in any other way and this should be recognised.

27 Mar 2019 14:55

For Housing sites, no DtC request can be issued from Gloucester City to CBC because those two Districts are not contiguous.
Land-deficient CBC could make a DtC request to Tewkesbury BC;
Gloucester City could make DtC requests to TBC and/or Stroud DC;
TBC could make DtC requests to Wychavon or Malvern Hills in Worcestershire.
Above all, remember the 'Apportionment' guidance established by the JCS Examination, that urban extensions for Cheltenham or Gloucester can be solely for their own individual Housing targets.

Schooling (at Secondary level) is a major Infrastructure issue, which the JCS failed to deal with because GCC kept quiet about its 'Strategic Review' (already written but deviously not published until after the JCS Examination sessions) which proposed an extra Secondary school for Cheltenham and its surrounding areas (additional to the planned Secondary school in the Cheltenham NW UE).
Secondary schools need considerable land and are inevitably cross-boundary service providers.

JCS-2 must address the whole issue of 'school planning districts' (Cheltenham, Tewkesbury and Gloucester areas), and GCC must be a full participant in JCS-2 (not wait until the JCS Examination sessions have closed and then immediately subvert the major JCS decision in favour of a substantial LGS (Local Green Space) for the 'valued Landscape' of Leckhampton; and indeed flout that verdict completely by intending soon to give giving full planning permission to itself).
GCC must publish comprehensive and convincing evidence and data covering all the interdependent 'school planning areas' within the JCS Districts, for timely scrutiny via the JCS-2 consultations.

GCC also needs to become a full JCS-2 participant for Transport planning, and publish scheme options early and be cross-examinable.

There is no proper DtC with a LEP.

Para. 5.4 states:
"The Gloucestershire Local Enterprise Partnership (LEP) is currently preparing the Industrial Strategy for economic growth in the county and the JCS will have an important role in delivering this."
This is an abdication by JCS officers, who ought instead to commission (and fund) their own independent Employment consultants, not over-influenced by the unelected non-transparent LEP lobby group. A sustainable growth level should be determined by the JCS itself, which should not be a mere "delivery" mechanism.
The G-First-LEP is a group of employers driven on by pushy planning consultants making over-aspirational claims of drawing "growth" (and population) into this environmentally most sensitive county.

The LEP should only be involved if as a full participant, publishing its material with (not after) each JCS-2 stage, and being open to cross-examination.

27 Mar 2019 14:26

The JCSR should be positively prepared and provide a strategy which, as a minimum, seeks to meet local housing needs and is informed by agreements with other authorities (NPPF2, para 35). To fully meet the legal requirements of the Duty to Co-operate the JCS Councils should engage on a constructive, active and on-going basis with neighbouring authorities to maximise the effectiveness of plan making.

One key outcome from co-operation between the authorities should be the meeting of housing needs in full. A key element of Examination is ensuring that there is certainty through formal agreements that an effective strategy will be in place to deal with strategic matters such as unmet housing needs when subsequent Plans are adopted.

27 Mar 2019 13:06

A key issue associated with the duty to cooperate will be ensuring that the identified housing need is met in full.

27 Mar 2019 12:28

It is acknowledged and accepted that there will be a need to co-operate with adjoining authorities. Paragraphs 24-27 of the NPPF makes clear that authorities have a Duty to Cooperate with other Authorities and other prescribed bodies on strategic matters that cross administrative boundaries; albeit, this is not an HMA-based matter any longer (given their demise).

The NPPF goes on to state that joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, joint working should help to determine where additional infrastructure is necessary, and whether development needs that cannot be met wholly within a particular plan area could be met elsewhere as explained further in the response to Question 2. The approach is hierarchical however, and the JCS authorities should look first within their area. There are significant development opportunities outside the Green Belt, but with the JCS that must be explored. The Duty to Co-operate is already engaged at places like Mitton and can continue to be successfully delivered.

When progressing this Plan, the Authorities need to ensure that there is enough contingency in the land supply to accommodate any late ‘Duty to Co-operate’ requests to accommodate cross boundary needs. As with the JCS Councils no other Council currently has clarity over what scale of housing need they may need to meet, and this will only become clear at very late stages of the JCS Plan preparation.

27 Mar 2019 12:12

Paragraph 11 of the revised NPPF states that: "strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas," It is therefore clear that meeting housing need is a key duty to cooperate issue that the JCS will need to consider. This is further underlined by paragraph 35 of the revised NPPF that sets out the examination tests for ‘soundness’. To demonstrate that the JCS review is ‘sound’ it will need to be "informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development."


25 Mar 2019 11:59
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