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Joint Core Strategy - Issues and Options

Joint Core Strategy - Issues and Options


List of answers to the specified question

4.1.19 Gladman do not consider that there are any exceptional circumstance which can be used as justification for the GCT JCSR to depart from the standard methodology. NPPF18 at paragraph 60 states that "to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using that standard method in national planning guidance". The use of the phrase ‘exceptional circumstances’ is deliberate by government, and designed to set a high bar for local authorities seeking to diverge from using the Standard


4.1.20 This methodology, however, should be seen as only a minimum starting point, and the Council’s should seriously consider providing for a greater scale of growth across the GCT JCSR area.

4.1.21 The standard method is only intended to identify the baseline requirement and it is important to ensure that actual housing need is not under-estimated as consideration should also be given toeconomic growth, affordable housing delivery and any unmet needs arising from neighbouring authorities to be determined through a SoCG.

4.1.22 Furthermore, it is important to note that the standard method may require further adjustments to ensure that the starting point in the plan making process is consistent with the Government’s commitment to building 300,0000 new homes per annum by the mid-2020s.


01 Apr 2019 15:57

The Government’s standard housing calculation and methodology is to determine the minimum number of dwellings required. Therefore the methodology could be used, if used positively. However there are a number of concerns that the methodology will slow growth and the Government has advised it will revisit the standard housing needs assessment methodology in light of Office for National Statistics projections, which showed a substantial drop in predicted household growth rates. Therefore a departure from the standard housing calculation would be justified to provide the required growth in the JCS area.


01 Apr 2019 15:39

We note the comparison drawn in the IOD between the JCS minimum requirement (1,760 dpa) and the new standard method figures (1,780 dpa). This would, on the face of it, suggest a minimal difference in terms of overall growth across the three authorities as a whole. However, it is also noted that the new standard method figure is a minimum and does not include any adjustments to cater for economic growth or affordable housing need. By applying the figures quoted in the IOD, if adjustments are made to the standard method figure consistent with the adjustments applied in the adopted JCS, then this would lead to a notional increase in the requirement c. 1,962 dwellings per annum (Using the 1,780 ‘Standard Method’ figure as a starting point, then add on 5% for economic growth and an additional 5% to address affordable housing need = 1,962 multiplied by 20 (years) gives 39,240). Over a 20-year period, this would produce a plan requirement of c. 39,240 dwellings, which would represent nearly 12% increase over the adopted JCS housing requirement of 35,175.

As highlighted in our response to question 1 above, given the nature of and relationship between the three authority boundaries, we suggest that the majority of this increase will most likely emanate from the Tewkesbury borough area. Furthermore, the Government is currently consulting nationally on the standard methodology and in the short-term (the next two years) LPAs will be required to apply the 2014-based projections until such time as the formula is revised, with a view to establishing a new method that meets the principle aspiration to deliver 300,000 new homes each year. The result of this process will most likely result in a new method that leads to an increase nationally in the projected number of new homes compared to the current methodology. It is likely that prior to examination and adoption of the emerging JCS the new method will be confirmed. If, as suspected, this leads to further increases in the OAN for the three authorities, the spatial strategy of the evolving JCS must be suitably flexible as the plan evolves to accommodate the potential increase in housing growth.

28 Mar 2019 12:49

RPS notes the commentary set out in paragraph 8.4 of the IOD, that the future minimum requirement for the JCS area, based on the standard method as at September 2018, is suggested to be 1,780 dwellings per year, only 20 dwellings per year higher than the current JCS figures (1,760 dpa). However, the figures for Tewkesbury suggest that the difference is likely to be greater (see table below) and in an upwards direction.

JCS demographic need OAN with economic uplift, dpa (taken from Joint Core Strategy 2017 )

Gloucester 683

Cheltenham 520

Tewkesbury 471


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

Gloucester 652

Cheltenham 539

Tewkesbury 580



Gloucester -31

Cheltenham 19

Tewkesbury 109


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. 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. 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) across 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 for Tewkesbury.

The implications of this, in particular with respects to the need for additional sites, is considered in our response to questions 12 and 13 below.

27 Mar 2019 16:27

We were under the impression that the standard methodology was a required minimum. Furthermore we note that the figures quoted (1,780 under the new methodology versus 1,760 under the old) do not appear to be comparing like with like. The old figure was after a ten per cent uplift for "economic growth" and a further five per cent for "flexibility". This was notwithstanding that Mr McDonald argued during EiP that they were unnecessary.

In addition it is widely reported that the Government is considering modifying the methodology to give even higher figures in order to maintain the countrywide policy objective of 300,000 new dwellings per annum.

We consider that Mr McDonald should be asked to prepare figures based on his own best professional judgement (that is the old basis). These might then be compared with the figures as imposed by central government. This would at least allow us to establish the extent to which a policy uplift is already baked into the standard methodology.

27 Mar 2019 14:55

Twenty additional houses per annum is minor, not worth altering (uplifting) JCS-1 for.

JCS housing (and Transport infrastructure) needs to commence being delivered first.

27 Mar 2019 14:26

It is reassuring that the JCS Councils recognise that the Government’s Standard Methodology (SM) for calculating housing need is a minimum figure and, therefore, only the starting point for identifying the number of houses required for the JCS area (para 8.3 of the IOP).

NPPF2 maintains the requirement for councils to significantly boost the supply of housing (para 59). The JCS Councils should proactively support this and the JCSR should reflect the objective. Therefore, using the most up to date evidence base, the JCSR should ensure that the full Objectively Assessed Housing Need (OAHN) and affordable housing need are met as far as is consistent with the NPPF, including identifying key sites critical to the delivery of the housing strategy over the plan period. As set out in the Housing White Paper ‘Fixing our Broken Housing Market’ (Feb 2017), the JCS Councils should be planning for the right homes in the right places by making enough land available to meet assessed housing requirements.

It is not clear what is meant by 'departing from the Government's standard housing calculation' in Q.8. It is VSM’s and DIO’s view that the JCS Councils should use the SM as the starting point for calculating housing need. The PPG sets out the circumstances which may lead to a departure and an increase above the starting point. The Councils should consider these carefully and explain whether these or any other reasons justify an increase above the SM figure.

We are aware of no 'exceptional circumstances' which would justify a figure below the SM.

It is noted that Paragraph 12.1 of the IOP states that 'at the point of adoption, the JCS had shortfalls of land to provide for new homes. For Gloucester City this is around 1,000 new homes form 2028 and for Tewkesbury 2,450 new homes from 2025.' This should be addressed as part of the calculation of housing need for the JCSR. It also demonstrates the benefits of planning for a greater number of dwellings than the housing requirement in order to provide flexibility in supply and support delivery.

27 Mar 2019 13:06

The NPPF makes it clear that the determination of the minimum number of homes required should be informed by a local housing need assessment, which should use the standard methodology. Council’s should only depart from the standard method in exceptional circumstances. No such circumstances apply in this case.

The JCS Review must also reflect that the standard method is only the minimum starting point. The Review should also consider factors such as supporting economic growth and delivering sufficient affordable housing.

27 Mar 2019 12:28

The Standard Method only sets the minimum housing need and in line with National Policy the JCS should, where able, aspire to delivering more. However, with regard to the minimum requirement, there is significant uncertainly around what form the Standard Method may take by the time this plan is submitted for Examination. As noted in the response to Question 2 further rounds of consultation are expected on the Standard Method in 2019 to align the method with the Governments 300,000 per annum housing target, various changes in data are also expected between now and the JCS Plan submission.

Therefore, while there is no justification to depart from the Standard Method (as the minimum), there is a need to plan for significant contingency of land supply, over and above today’s (2014 based) Standard Method. This is to ensure that, at the time of submission, the Plan has ample flexibility to accommodate likely possible increases in the minimum number of homes needed.

As noted in Question 2, one way to mitigate this risk is for the JCS to progress with an extended Plan period, ideally extending beyond 2041. This is so the emerging plan is flexible enough that the pace of development in later drafts of the plan can be increased if needed at the time of submission. This could be achieved by shortening the plan period, and increasing the per annum requirement, while still maintaining the minimum plan length required by the NPPF of 15 years.

An alternative approach could be to work to a higher need figure than currently shown in the 2014 based Standard Method. However, any estimate of what the Method may show in 2020/21 can only be speculation and no consensus is likely to emerge as to what future National Policy changes may show. Hence why, at the moment, it is considered that extending the plan period is the preferable alternative to speculating about an alternative minimum housing need number.

Regardless of the minimum requirement for the area, the JCS Authorities may choose to also promote a higher, aspirational target and allocate more sites to meet economic or other social needs. One such driver may be the GFirst LEP economic strategy which is aspirational in its approach and should guide the preparation of the JCS. Recent changes to guidance, most obviously the ‘two tier’ housing requirement now promoted in the guidance makes it much easier to aspire to higher targets and over allocate land where it is sustainable to do so. This new flexibility is a further reason the JCS Authorities should take a very positive approach to housing targets in the early stages of plan preparation, to avoid the same shortfall situation as faced at the moment from the last plan preparation process.

Growth of the Government Communication Head Quarters (GCHQ) in Cheltenham may be a market disrupter that is not taken in to account in the ONS projections. The growth of GCHQ has the opportunity to be a big employer requiring housing need which may not be taken into account in ‘need’ figures.

27 Mar 2019 12:12

MMG support the principle of a standard methodology that will enable coordinated action to meet the nationwide target of 300,000 new homes on average by the mid 2020’s, as announced in the 2017 budget. However, they consider that the figure of 1,780 new homes a year, quoted in the Consultation Document as the standard methodology output using the latest available information, will need to be increased if the nationwide target is to be met.

In October 2018 the Government published a Technical consultation on updates to national planning policy and guidance, that in part seeks to redress the imbalance between the current output of the standard methodology and the target of 300,000 new homes a year. It states the following:

 "The ONS published the latest household projections on 20 September 2018. These reduce the projected rate of household formation compared to the previous projections by 53,000 a year between 2018 and 2028. These lower projections of household growth result in the national minimum annual housing need calculated using the standard method falling significantly; from approximately 269,000 homes prior to the publication of the updated household projections, to approximately 213,000 based on the updated data. This is below the 217,350 homes delivered last year."

 The ONS household projections published in 2018 are based on a period of relative unaffordability, that has prevented many first-time buyers from purchasing their first home. As a result, they have had the undesired outcome of 'baking in' recent low household formation trends associated with the lack of housing supply and consequent affordability issues.

 In the Consultation Document it states that: "Based on the information available in early September 2018, the minimum requirement in the JCS area would be in the region of 1,780 new homes a year. In contrast, the current figure for the JCS area is approximately 1,760." This would suggest that the standard methodology will not result in a significantly different housing requirement from that of the Adopted JCS. However, in light of the various Government announcements and recent consultation, it is clear that the standard methodology will be revised to produce a markedly higher output.

In light of the above MMG considers that the JCS authorities need to be prepared to plan for a significantly increased housing requirement than that of the adopted JCS.


25 Mar 2019 11:59
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