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Joint Core Strategy - Issues and Options

Joint Core Strategy - Issues and Options


List of answers to the specified question

4.1.31 Gladman recognise that the known development opportunities at Ashchurch, North West & West Cheltenham can contribute towards meeting housing needs in part. We do however consider that it will be necessary for the JCSR to identify further strategic growth options so as to ensure that the full objectively assessed need for housing across the plan area can be met.

4.1.32 Gladman wish to raise a number of significant concerns regarding the proposed strategic development at Ashchurch. We question the ability of the site to deliver the scale of anticipated development and its ability to contribute to the provision of housing in a timely manner consistent with the likely plan period. Gladman welcome the opportunity to review the Ashchurch Concept Masterplan which has been published alongside the JCSR Issues and Options Paper.

4.1.33 Delays in the MoD providing vacant possession of the portion of the site they control (64.4ha), has already led to the allocation being removed from the adopted JCS, and it would appear, that there still remains considerable uncertainty regarding the MoD’s intentions and associated timescales going forward. The Concept Masterplan stated that "the MoD will now be retaining the site for another10 years, with a smaller portion (15.8ha) potentially to be disposed of earlier". Beyond the land owned by the MoD, the rest of the site is in multiple ownerships and is being promoted by a number of developers.

4.1.34 In respect of the proposed allocation, an indicative phasing approach has been defined, outlining a total of 4 Phases. The Concept Masterplan currently anticipates that only Phase 1 can be delivered by the end of the current JCS plan period in 2031.

4.1.35 Phase 1 envisages the development of the areas north of the MoD base, the HCA land and the Fiddington site, delivering up to 3,180 new homes, 46 HA of employment land, a local centre and a new Primary School.

4.1.36 The Concept Masterplan itself identifies a number of very significant highways and transport issues, for which it is recognised that there is as of yet, no solution for the quantum of proposed development in Phase 1. For Phase 1 alone to be accommodated it is recognised that a Northern link is needed with crossing over mainline rail, joining up existing roads and that further consideration needs to be given to bringing forward a southern development road. As things currently stand, both Junction 9 of the M5 and the A46 are operating at or very close to capacity and experiencing severe delays, and it is recognised within the Masterplan that the proposals for development at Ashchurch are likely to have a further significant impact on the already very stretched highways network.

4.1.37 Gloucestershire County Council have themselves commissioned work on a short-term access strategy, considering solutions that would enable development to commence in a timely manner. The report commissioned confirms that a compressive approach is required, and that short-term options are of limited benefit; "The prevailing issues of traffic demand, related vehicle delays and the limited road network connections available mean that more substantial and comprehensive road infrastructure improvement is required to support anticipated development. To minimise the related negative impacts of such infrastructure, severance, noise, visual impact etc, and to provide a more positive and active movement and living environment, then a related and comprehensive approach is required, predicated on sustainable transport." 4.1.38 At the time of writing there are 3 live planning applications/appeals relating to land located within the Masterplan. A further site has been granted planning permission for 150 dwellings and an application for 550 dwellings has been dismissed. The approach being taken fails to address in full the necessary infrastructure requirements, and as stated within the Concept Masterplan, the complex highways issues, can only be addressed through a comprehensive and collaborative approach.

4.1.39 The delivery of development on the scale and with the infrastructure complexities of the proposed allocation at Ashchurch, will clearly require a different way of thinking from the Council’s. Given that the level of infrastructure required is likely to be costed in the millions of pounds and will require cooperation from third parties, including, Network Rail, the Council’s will very clearly need to demonstrate where the levels of funding are coming from and how the delivery of the allocation will be viable.

4.1.40 At present the Masterplan indicates that the ‘local centre’ including retail and community facilities, will be delivered almost entirely on the land owned by the HCA. At this stage there are no firm details regarding the timing of the delivery of this necessary infrastructure or indeed any indication from the HCA that this is considered an acceptable and indeed viable use of the land they control. We suggest that, as is the case on all proposals of this scale, the provision of infrastructure and community facilities should proceed or at least mirror the provision of housing and employment  development. Through review of the Concept Masterplan, we have found no evidence to demonstrate that the required infrastructure will be delivered in a manner consistent with development of residential dwellings, and further, have seen very little evidence to suggest that the infrastructure and community facilities that are required by development of this scale are deliverable at all.

4.1.41 In line with our above comments, Gladman consider that there is considerable further work and explanation needed by the Council’s to demonstrate that the allocation at Ashchurch is deliverable. The current approach runs the risk of overpromising on what the allocation can deliver, if it can be delivered at all, with a more considered approach to viability, funding, highways and landownership an urgent requirement.

4.1.42 Gladman suggest that given the considerable uncertainties that remain around the Ashchurch allocation, it would be prudent to consider other options for strategic growth across the plan area, and specifically within the Tewkesbury administration boundary.


01 Apr 2019 15:57

Development opportunities in the JCS area and the spatial strategy, in particular land around Ashchurch, can play a significant role in helping to meet the required housing needs over the plan period. In relation to our client’s land, the JCS acknowledges the sustainable location of the land around junction 9 of the M5, by virtue of the proximity to Tewkesbury, the M5 and mainline railway.The strategy can play a significant role in addressing development needs, and our client’s land offers a readily available site that could release additional land beyond that which is already identified for growth.


01 Apr 2019 15:39

A call for additional sites seems premature in terms of housing need after 2031.

27 Mar 2019 16:54

RPS is concerned that there is no mention made to the Land at Mitton in the section headed ‘Known development opportunities’ as helping to address current shortfalls in supply. There is no doubt that Land at Mitton is a known opportunity given its inclusion in both the current JCS and the adopted SWDP and should continue to be recognised as such in the emerging JCS and can play a role in helping meet housing needs. Both the JCS and SWDP make provision for consideration of Land at Mitton to help address the unmet needs at Tewkesbury. Furthermore, the current JCS specifically identifies the Mitton site as part of Tewkesbury’s housing land supply which will play an important role in meeting Tewkesbury’s housing needs. The Mitton site is already included within Tewkesbury’s 5YHLS. A planning application has been submitted which demonstrates the deliverability of the site. Consequently, the lack of reference to the Mitton site contradicts the adopted development plan as well as the position inferred under section 5 (at para 5.3) of the I&O consultation, which refers to, "…joint working taking place with Wychavon District Council in Worcestershire on a cross-boundary site at Mitton to help meet the needs of Tewkesbury Borough…". The lack of reference to the Site is also inconsistent with references made to other known opportunities within neighbouring areas (at Stroud).

There is no doubt Mitton is a known opportunity – in the same way as the Stroud sites are. Our objection is that Mitton is not acknowledged as such in the consultation paper, given the existence of the JPS which confirms that the 500 units will go towards meeting Tewkesbury’s needs.

27 Mar 2019 16:27

Yes, the land at Peel Centre/Madleaze (SALA ref: ED013NEW (SALA 2018)) can play an important role in meeting the needs of identified shopping and other town centre uses, including offices, and housing requirements, once the evidence base has been updated, as part of a fully flexible allocation for mixed uses.

27 Mar 2019 15:36

Yes. The sites indicated represent the future direction of travel. We would only add that we must learn from delays at the major strategic sites in the JCS.

As regards smaller sites, it all depends where they are. In particular the Green Belt is already critically small and any development in some areas will have a quite disproportionate effect on the ability of the Green Belt to perform its intended purpose.

27 Mar 2019 14:55

Yes, the huge known JCS-1 schemes must be progressed urgently.

The only additional sites should be those recommended by the JCS-1 Examination (but needing further detailing before formal adoption), principally:

Brookthorpe-Whaddon and
'Greater Tewkesbury' (encompassing M5-J9 and Ashchurch).

Greater Tewkesbury or 'Great Ashbury' was the inevitable consequence of TBC (and CBC and Gloucester City) officers failing to consider any tempering-back (on environmental sustainability grounds) from the full growth calculation of 30,000+ houses, in this most delicately balanced county.

At NorthWest and West Cheltenham, the ‘safeguarded land’ areas should definitely not be for growth "particularly from an employment perspective", following the massive 65+ hectares allocated there by JCS-1. Cheltenham is far too short of land for its long-term Housing growth to squander its last possible UE sites merely to provide JCS-wide commercial "opportunities", never mind that those sites happen to lie close to an M5 junction.
Moreover, any such "employment" use (so called) would most likely become sprawling land-wasteful retail parks or logistics warehousing, with limited jobs provision. Cheltenham's 'safeguarded land', the town's final contiguous option, must be predominantly for Housing.

After the seismic UE expansions of JCS-1 (none of which is reliably progressing to implementation) there should not (as in para. 12.15) "be a requirement to allocate further strategic sites" for a mere 5 or 10 year period extension beyond 2031. What JCS-1 schemes will have materialised by 2031 is most uncertain.

27 Mar 2019 14:26

The strategic policies of the JCSR should provide a clear strategy for bringing sufficient land forward and at an appropriate rate to address housing needs over the plan period by planning for and allocating sufficient sites to deliver strategic priorities (NPPF2, paragraph 23). This includes acknowledging individual site circumstances and the flexibility and deliverability benefits of phasing development.

Paragraph 12.1 of the IOP recognises that at the time of adoption there was a housing land supply shortfall of 1,000 dwellings for Gloucester from 2028 and 2,450 dwellings for Tewkesbury from 2025.

Paragraph 12.3 explains that Tewkesbury’s shortfall was a result of the DIO indicating the delayed release of MOD Ashchurch which was a proposed strategic allocation in the Submission JCS. The DIO has since confirmed that the site will be released in phases. As above, this site provides a valuable opportunity to deliver significant housing growth on previously developed land. The principle of development is acceptable (further confirmed by its previous allocation in the JCS) and, therefore, the JCSR should ensure allocations policies are sufficiently flexible and facilitate phased delivery.

In this vein, support is given the Council’s preparation of a masterplan for Tewkesbury / Ashchurch which includes MOD Ashchurch. Detailed comments with regard to the Masterplan Report as provided in the final section of these representations.

27 Mar 2019 13:06

The JCS Review must identify a sufficient supply and mix of housing sites, which takes into account availability, suitability and economic viability. Whilst the known development opportunities are likely to make a contribution towards meeting the identified need, it is noted that since adoption of the JCS, strategic allocations have not forward as quickly as anticipated. The JCS Review should set out a strategy that allows a range of deliverable and developable sites to come forward to ensure that the housing requirement is met. This should include a contribution from smaller sites, which can often be brought forward earlier in the plan period.

27 Mar 2019 12:28

The JCS has identified Ashchurch, North West and West Cheltenham and South Gloucester for development growth. It is not questioned whether these areas have a role to play in the supply of land for housing, rather that the JCS should not over-rely on their delivery; South Gloucester forms part of a separate planning area/Local Plan and West Cheltenham has yet to deliver any planned growth, so putting more emphasis there will not improve supply.

As noted previously, our client supports the delivery of development in the north eastern part of the Masterplan area in the early phases.

There are other sites in the wider vicinity of, but still well-connected to, the Masterplan area, such that could help bolster housing supply over the short/medium term in the absence of the MoD site. This includes land at Brookhouse Farm. The MoD site could then fit in as it becomes available for development over the longer term. Development to the north and east would not be reliant on costly infrastructure, unlike development in the southern area, and could be delivered promptly.

Lessons should be taken from the previous JCS in the over reliance on Ashchurch to deliver significant housing numbers.

It is also questioned whether development at North West Cheltenham will help delivery given the area is constrained and has history of not being able to meet delivery needs.

27 Mar 2019 12:12
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