jcs issues and questions consultation -...

JCS Issues and Questions Consultation

Foreword

In 2008 the Councils of Gloucester City, Tewkesbury Borough and CheltenhamBorough decided to prepare a joint development plan. This will have many benefits toplanning a sustainable future for all three Council areas and the approach is supportedby Gloucestershire County Council.

This consultation document is the first stage in producing the joint development planand has regard to the latest Draft of the Regional Spatial Strategy (RSS) for the SouthWest. Despite Government promises, the RSS has still not been formally published.The Government advises that the Draft RSS should be used as a material planningconsideration in the planning process when considering applications for proposalscontained within it. The development industry therefore may not wait for the

Government to publish the RSS and the Planning Inspectorate is likely to come underpressure to make decisions on planning appeals in advance of its publication.

Cheltenham Borough, Gloucester City and Tewkesbury Borough together withGloucestershire County Council have various significant objections to key aspects ofthe RSS, particularly in relation to unjustified urban extensions and unnecessaryincursion into the Green Belt arising from its proposals for increased growth tounprecedented levels.. Although the Councils remain opposed to the RSS, we feel it isvital to put plans in place to help secure proper infrastructure should applications comeforward for proposals within the Draft RSS.

It is also necessary, for the good planning of the area, to ensure that an up-to-datedevelopment plan is in place to guide future sustainable development and safeguardenvironmental, social, economic and other key interests.

In publishing this document the three Councils are inviting local communities andstakeholders to present their views and engage fully in the process of preparing thejoint development plan.

JCS Issues and Questions Consultation Page 1

IntroductionThis document has been produced by Gloucester, Cheltenham and TewkesburyCouncils. Its purpose is to raise awareness of the Key Issues that the area faces and togenerate debate about how these could be addressed. The document is the first steptowards a Joint Core Strategy that will set out the strategic planning framework for thethree authorities and guide future development up until the year 2026. On adoption,the Joint Core Strategy will become part of the statutory development plan for eachauthority.

Preparing a Joint Core Strategy will mean making choices about how the area willdevelop over the period from now until 2026. As part of the preparation of the JCS it isimportant to consult stakeholders and communities on what they see as the issues fortoday and the solutions for the future. This document is the first stage in thepreparation of the Joint Core Strategy and the Councils are seeking your views on anumber of subjects and topics that will need to be addressed.

This consultation document invites your to provide your views on:

• The Key Issues that need to be addressed;• The Vision for the area;• The topics the Joint Core Strategy should cover;• What policies could be included within the JCS and what the priorities should

be.

This document fulfils the requirements of Regulation 25 of the Town and CountryPlanning (Local Development) (England) Regulations 2004, as amended.

Structure of the Document

The document is split into two parts. The first part is about Gloucester, Cheltenham andTewkesbury Borough in 2009. It explains why a Joint Core Strategy is being produced,how it fits into other relevant plans, policies and programmes and summarises theevidence that has been collected for the area. It ends by detailing what are consideredto be the Key Issues to be addressed in the JCS.

The second part is about the future. It outlines what could be included in a potentialVision for the area for 2026 and a set of Strategic Objectives which would need to bemet to achieve a Vision. The second part also outlines the possible policy areas thatthe Joint Core Strategy will need to cover in order to achieve the Vision and seeks yourviews on them. Each topic area includes a brief description of relevant national orregional policy as appropriate.


Why a Joint Core Strategy?

The decision to produce a Joint Core Strategy was made by all three Councils in July2008. Working jointly means a plan can be prepared at a strategic level for the future ofthe area to ensure that urban locations complement each other rather than compete.This is particularly important for Gloucester and Cheltenham because, by workingtogether, they can act as a sub-regional centre and attract investment and jobs. it willalso enable rural communities to benefit from economic opportunities across the area.

What area will the Joint Core Strategy Cover?

The Joint Core Strategy will be the key document in the development plan ofGloucester City, Cheltenham Borough and Tewkesbury Borough Councils. As such itwill cover the administrative areas of the three authorities as illustrated below.

How will the Joint Core Strategy relate to other plans?

The Joint Core Strategy will be a Development Plan Document and will be part of thethree Councils' Local Development Frameworks (LDFs). LDFs were introduced as partof the new statutory planning process under the 2004 Planning and CompulsoryPurchase Act and will replace the Local Plans for each of the authorities. For moreinformation on Local Development Frameworks and the new planning system pleasevisit http://www.planningportal.gov.uk/uploads/ldf/ldfguide.html

As set out above, the new planning system also introduced a new type of regionalplanning document known as a Regional Spatial Strategy (RSS). This will also formpart of the Councils' development plans for the area. The Regional Spatial Strategy forthe South West has been prepared and undergone independent examination. It is,however, yet to be published and there remains some uncertainty about what it willcontain in its final version. When it is published, the Joint Core Strategy will have to bein general conformity with its policies. At present the most up to date version of the


http://www.planningportal.gov.uk/uploads/ldf/ldfguide.html

RSS is the Secretary of State's Proposed Changes version that was publishedfollowing the report of the Panel appointed to examine the Draft RSS.

In addition to the RSS, the JCS must also have regard to, and seek to deliver, on awide range of other plans and programmes prepared by each of the Councils and otherstakeholders. For example it must have regard to the Housing Strategies prepared byeach authority and the Economic Development Strategies and initiatives in existence.In particular for Gloucester and Cheltenham, the Joint Core Strategy will need to reflectupon the initiatives and proposals coming forward as part of the Gloucester HeritageUrban Regeneration Company and Civic Pride respectively. As can be seen, the JCSwill therefore need to have regard to a whole range of strategies and programmes andseek to deliver the spatial elements of them all, where appropriate to the developmentof the JCS area.

Links to the Sustainable Community Strategies

It is also crucial that the Joint Core Strategy delivers on some of the intentions of thefour (including the county-wide) Sustainable Community Strategies produced by theLocal Strategic Partnerships (LSP) and the Gloucestershire Conference. A facilitatedLSP Workshop was held in November 2008 where the LSPs set out what they wishedto see included within the JCS. The outcomes of that workshop are listed below.

1. Develop strong and complementary relationships between communities whilstretaining the local distinctiveness of the City, Spa Town, rural communities andsuburbs.

2. Improved retail offer (shops)3. Meeting the variety of housing needs of the communities across the JCS area4. Innovative solutions for transport, planning and urban design to increase the

use of public transport.5. Develop the employment portfolio of Gloucester, Cheltenham and Tewkesbury6. Develop the skills agenda for people of all ages7. Enhance the cultural, leisure and tourism offer8. Mitigate contributions to climate change and ensure effective adaptations to

help improve the resilience of the JCS area9. Reduce the risk of flooding and its impact

10. Protect, manage and enhance biodiversity and the natural environment11. Deliver effective and ongoing social, economic and physical regeneration of

Gloucester12. Improve health and access to healthcare for residents of Gloucester,

Cheltenham and Tewkesbury areas.

A fuller and more detailed explanaiton of each of the above is available from the JointCore Strategy LSP Workshop Report, included within the evidence base for the CoreStrategy.

For each of the Council's Sustainable Community Strategy, please visithttp://www.gct-jcs.org/Publications/SustainableCommunityStrategy.aspx

What else will influence the Joint Core Strategy?


http://www.gct-jcs.org/Publications/SustainableCommunityStrategy.aspx

Decisions taken in the Joint Core Strategy will need to be based on a strongunderstanding of the area and robust evidence. How, when and where the necessarylevel of infrastructure can be provided will also be a key determinant. At present thethree Councils are preparing a range of evidence base studies. If you would like to viewthe evidence base, please visit www.gct-jcs.org/EvidenceBase

What happens next?

Once we have received all your comments, we will publish a summary of the issuesraised. This will then be used to help prepared a draft Joint Core Strategy. Thetimetable is set out below.

• Evidence Gathering Stage• Issues and Question Consultation in November 2009• Developing Prefered Options Draft in September 2010• Pre-submission Draft in January 2011• Submission Joint Core Strategy in June 2011• Examination in the Autumn of 2011• Adoption in December 2011.


http://www.gct-jcs.org/EvidenceBase

Sustainability Appraisal

Local authorities are required under the Planning and Compulsory Purchase Act 2004to subject all LDF documents to a process known as Sustainability Appraisal (SA),incorporating the requirements of the European Strategic EnvironmentalAssessment (SEA) Directive.

SA is a process that promotes sustainable development by assessing how social,environmental and economic considerations have been taken into account major newplans and programmes. It is a way of ensuring that sustainable development is at theheart of emerging plans and policies.

As part of the Joint Core Strategy, a SA Scoping Report was produced, consultedupon. The SA Scoping Report sets out how the plan will be assessed against a set ofSustainability Objectives. Each section of this document includes a list of SustainabilityObjectives that are appropriate to consider when making your response.

For more information of the SA Scoping Report and the SA process in general pleasevisit www.gct-jcs.org.

Making Comments

This document is all about getting your views. To make this easier, an onlineconsultation system has been provided that allows you to read the document andcomment online. You can access the system at http://consult.gct-jcs.org/inovem.You will need to register to make comments.

If you prefer to view a paper copy, please call 0800 073 1441 and a copy of thedocument and a response form will be sent to you. Response forms and any generalcomments you have can be sent to the following email address: [email protected]

Or by post to: Joint Core Strategy TeamMunicipal OfficesPromenadeCheltenhamGL50 9SA

The deadline for responses is 5pm on 14 December 2009

If you have any questions about the document, please feel free to contact us.

If you would like a braille, large print, audio or alternative language copy of thedocument please contact us.

Introduction

Introduction ........................................................................................................3Policy Context ...................................................................................................9Spatial Portrait and Issues ..............................................................................12


http://www.gct-jcs.orghttp://consult.gct-jcs.org/inovemmailto:[email protected]

Vision and Objectives ......................................................................................18Strategic Spatial Policy Areas .........................................................................21

Development in the JCS Area ............................................................21Gloucester City Urban Area ...............................................................23Cheltenham Urban Area .....................................................................26Tewkesbury Borough .........................................................................29Sustainable Urban Extensions ...........................................................32Priorities for Delivery Through Development ......................................36Urban Regeneration ...........................................................................38

Topic Based Policy Areas ...............................................................................42

Affordable Housing .............................................................................42Sustainable Buildings .........................................................................45Renewable Energy .............................................................................48Flooding ..............................................................................................50Employment .......................................................................................52City and Town Centres .......................................................................55Green Infrastructure ...........................................................................58Gypsy and Traveller Provision ...........................................................61

Other Policy Areas ..........................................................................................63Deliverability ....................................................................................................65Glossary of Terms ...........................................................................................68


Policy ContextAlthough the Joint Core Strategy will be the key document in the three Councils' LocalDevelopment Frameworks, it is also important to understand that it needs to conform tonational and regional policy. In addition and importantly, one of the changes brought inby the new planning system in 2004 is that local documents should not repeat nationaland regional policy. One of the things that is being consulted on with this document iswhat local issues are sufficiently covered by national policy and what are thosethat need a policy at local level?

What is National and Regional Policy?

The new planning system brought a change to the way the Government sets outnational policy. This change essentially replaced previous guidance in the form ofPlanning Policy Guidance Notes, with a set of Planning Policy Statements (PPS).These Planning Policy Statements are now policy and are backed up by a range ofPractical Guides that explain how policy should be implemented.

Planning Policy Statements 11 (Regional Spatial Strategies) and 12 (Local SpatialPlanning) set out the framework for the preparation of regional and local planningpolicy. For more information on national planning policy, pleasevisit www.communities.gov.uk

What are Regional Spatial Strategies?

Regional Spatial Strategies are planning policy documents prepared at a regional leveland set the strategic framework for development at local level. Once published, theRegional Spatial Strategy forms part of the statutory development plan for every localplanning authority in that region. As such, all local level planning policy documentshave to be in general conformity with the Regional Spatial Strategy. In practice, thismeans that Regional Spatial Strategies set out broad policies for the future of theirregion, such as the number of houses to be built in each area, the number of jobs to beprovided and what level of infrastructure is required. It is then for local authorities todecide how best to implement them. The Joint Core Strategy area is situated in theSouth West region and therefore must be in general conformity with the RegionalSpatial Strategy for the South West when it is published.

What is the timetable for the South West Regional Spatial Strategy?

The Draft Regional Spatial Strategy for the South West was first published in June2006 and was subject to Examination in Public (EiP) between April and June 2007.Since the EiP, a Panel Report was published in January 2008, followed by theSecretary of State's Proposed Changes to the draft in July 2008. The Regional SpatialStrategy for the South West was due to be finalised and published in June 2009 butthis has been delayed. As yet, no revised adoption date has been set.


http://www.communities.gov.uk/

What does the Draft RSS propose for the JCS area?

In the absence of a finalised Regional Spatial Strategy for the South West, Governmentadvice is that Core Strategies should be based upon the Proposed Changes version(July 2008).

The Draft Regional Spatial Strategy for the South West sets out draft policies ontransport, infrastructure, community facilities, affordable housing, renewable energy,flooding, sustainability and gypsy and traveller accommodation.

To accommodate this development the Secretary of State's Proposed Changes setsout five areas of search for extensions to the existing urban areas. These areas ofsearch are predominantly in Tewkesbury Borough but relate to the existing urban areasof Gloucester and Cheltenham; both of which are designated as StrategicallySignificant Cities and Towns in the Draft Regional Spatial Strategy. This relationship isone of the key reasons for working together on a Joint Core Strategy. Indicativelocations for the proposed urban extension are illustrated on the diagram below.

What is the three Council's position on the current RSS?

In 2008 the Councils of Gloucester City, Tewkesbury Borough and CheltenhamBorough decided to prepare a joint development plan. This will have many benefits toplanning a sustainable future for all three Council areas and the approach is supportedby Gloucestershire County Council.


This consultation document is the first stage in producing the joint development planand has regard to the latest Draft of the Regional Spatial Strategy (RSS) for the SouthWest. Despite Government promises, the RSS has still not been formally published.The Government advises that the Draft RSS should be used as a material planningconsideration in the planning process when considering applications for proposalscontained within it. The development industry therefore may not wait for theGovernment to publish the RSS and the Planning Inspectorate is likely to come underpressure to make decisions on planning appeals in advance of its publication.

Cheltenham Borough, Gloucester City and Tewkesbury Borough together withGloucestershire County Council have various significant objections to key aspects ofthe RSS, particularly in relation to unjustified urban extensions and unnecessaryincursion into the Green Belt arising from its proposals for increased growth tounprecedented levels.. Although the Councils remain opposed to the RSS, we feel it isvital to put plans in place to help secure proper infrastructure should applications comeforward for proposals within the Draft RSS.

It is also necessary, for the good planning of the area, to ensure that an up-to-datedevelopment plan is in place to guide future sustainable development and safeguardenvironmental, social, economic and other key interests.

In publishing this document the three Councils are inviting local communities andstakeholders to present their views and engage fully in the process of preparing thejoint development plan.


Spatial Portrait and IssuesWhat is a Spatial Portrait?

The Joint Core Strategy will need to set a Vision for the future of the Joint CoreStrategy area as it moves towards 2026. However, in order to produce a vision for thefuture it is necessary to understand the past and present and the strengths andweaknesses of the area as they stand. The purpose of a Spatial Portrait for the area isto do just that. It needs to paint a picture of what it is like to live in the Joint CoreStrategy area now. In doing so, it will help identify the Key Issues facing the area andunderstand what is necessary to address them.

It is vitally important that the Spatial Portrait provides an accurate snapshot of the JointCore Strategy area. As part of the process so far, a significant evidence base has beencollated to understand the area. This evidence base includes specialist studies into theeconomy of the area, its housing market, the leisure and retail industry, as well astechnical studies on flood risk and the availability of land for housing and other uses.Added to these studies, the evidence base includes a comprehensive set of statisticson social, economic and environmental issues collected as part of the Joint CoreStrategy Sustainability Appraisal process.

By analysing these studies and statistics, a draft snapshot of the Joint Core Strategyarea in 2009 has been drafted. From this the initial Key Issues have been identified. Itis anticipated that through this process of consultation, the Key Issues and Portraitoutlined in this document will be further refined in the next document that will talk morefully about specific locations within the JCS area.

The Spatial Portrait

Within the Joint Core Strategy area Gloucester City and Cheltenham together accountfor approximately 75% of the area's population and provide a focus for economicactivity across the whole county. Their similarity in terms of size and population meansthat individually they are equally important to the functioning of the area. However, dueto their proximity to one another, they are significant on a regional and national scale.

At a local level, however, the two settlements are considered very differently from oneanother. Gloucester dates back to Roman times and has a longer history of habitationthan Cheltenham. Its position on the River Severn at the point where the river becomesan estuary meant it was a strategically important place. Gloucester was a natural portand retains a location important maritime heritage. To this day, its docks and quayremain a focus for the city, and now ship building and repairs take place alongsidedockside flats and an exciting new retail destination. Away from the docks, Gloucesteris dominated by its 11th Century Cathedral and evidence of earlier occupants in itsRoman "gate" streets, historic central cross and medieval lanes, much of this ishowever, hidden amongst the recent and past growth of the City.

Cheltenham, has a much shorter history. The Town has a strong Regency heritage,attracting residents and visitors to its wide streets and Georgian architecture.


Cheltenham's central conservation area is the largest such designation in Europe,reflecting the importance of what is considered to be the most complete Regency townin Britain. Cheltenham is also characterised by a series of formal and semi-formalparks, gardens and green spaces, which give its centre an open feel and play host tonumerous festivals and events. Away from the City and Town centres, both settlementshave expanded greatly in the 19th and 20th centuries and both have become majorurban areas and centres for the employment, services, shops and education.

Both settlements demonstrate a very high rate of self-reliance for employment, withalmost 70% of the workforce living and working within the same local authority area.This is important as it results in fewer and shorter commutes in both the city and thetown and makes them both relatively sustainable in respect of journey times. Both haveaccess to the M5 motorway which passes directly between them along with mainlinerailway stations in both centres. Gloucestershire Airport also provides a hub forbusiness travellers and some limited public services.

The differences between the two settlements are most apparent in their economies.Although both are important to the economy of the county, their individual economiesare very different and there remains a large gap in terms of earnings and generalaffluence. On average, earnings in Gloucester are 18% lower than those inCheltenham. However, this disparity is somewhat offset by the difference in houseprices with prices in Gloucester on average 27% lower than those in Cheltenham.

This inequality is mirrored by the gap in skills and qualifications between the twocentres. In Cheltenham, almost 40% of the workforce is qualified to degree level orhigher and only 8% have no qualifications. In Gloucester, however, only 23% of theworkforce has a degree, although the percentage with no qualifications is similar.

While the two settlements of Gloucester and Cheltenham are relatively prosperous,there are still large disparities between different areas within them. Cheltenham hasareas within the top 10% most deprived in the country, while Gloucester has 5. TheTown and City each have a further 10 and 17 Super Output Areas in the top 25% mostdeprived respectively. These pockets of deprivation demonstrate the inequalities thatexist across both the city and town.

In both Gloucester and Cheltenham the majority of jobs are in the Public sector(including education and health), which accounts for over 30% of employment in bothareas. Beyond this dominant sector, however, the two economies are distinctivelydifferent. Cheltenham's economy is concentrated within finance and in services suchas hotels, retail and restaurants, with relatively low levels of manufacturing,construction, communications and distribution. Gloucester, by contrast, has a morebalanced economy, with more employment in the manufacturing, construction andcommunications sectors and significantly less in the service industries and finances.The Tewkesbury rural area which surrounds Cheltenham and Gloucester City alsocontains a significant number of influential industries important to the local economy.

The recession has affected both settlements and unemployment has risen steadilyfrom January 2008 and through 2009. The percentage claiming Job Seekers Allowancereached 4.1% in Cheltenham and 4.6% in Gloucester in July 2009 from lows of 1.7%and 1.9%. In both settlements, there are a significantly higher percentage of male


claimants. However Gloucester Quays has recently opened in Gloucester andproduced a significant number of new jobs in the City.

In both settlements the importance of the service sector is rising. Cheltenham hasdeveloped a reputation as a retail destination and is ranked as the 23rd most importantretail centre in the country, far higher than its population would suggest. Gloucester,despite having the slightly larger population, is ranked 89th but this does not takeaccount of the very recently opened Gloucester Quays Designer Outlet, which hassignificantly increased the City's retail offer and is changing the retail offerin Gloucester significantly.

While tourism is not as important to the economy of Cheltenham and Gloucester as it isto other areas of the South West like Devon and Cornwall with only 7.6% of theCheltenham workforce and 5.6% of Gloucester's workers are employed in tourismrelated jobs it is an area of growth. Gloucester however at present struggles to attractovernight visitors, with hotel provision in the city centre limited, meaning many visitorsspend only a day in the City or leave it in the evening and to elsewhere. Those visitorsthat do come to the area are very well catered for in terms of attractions. Gloucester'svisitors come for the historic docks and Cathedral throughout the year, the successfulrugby club during the season and for annual events like the Gloucester Festival andTall Ships. In Cheltenham, tourists and day visitors come to take in the Regencyheritage and grand building such as the Pittville Pump Room, enjoy a day at the racesor experience the Jazz, Literature or Science Festival. Cheltenham currently provideswell for visitor accomodation through a number of hotels. The Cheltenham Racecoursealso provides a significant environmental asset of national importance.

Outside the major urban areas of Gloucester and Cheltenham, the Joint Core Strategyarea contains a number of important settlements across Tewkesbury Borough. Ofthese settlements, Tewkesbury and Ashchurch, on both sides of junction 9 of the M5are the largest and provide a focus for economic activity in the Borough. BishopsCleeve and Woodmancote (to the north of Cheltenham) and Winchcombe (in theCotswolds) are also important centres providing services for their own populations andlarge rural areas. Elsewhere, the built up areas of Brockworth, Hucclecote,Churchdown, Innsworth and Longford look to Gloucester for services, while villages likeShurdington, Badgeworth and Uckington look to Cheltenham. Smaller villages andhamlets like Snowshill, Stanton and Boddington are dotted throughout TewkesburyBorough, some containing valuable local services like village schools, shops, pubs andcommunity halls.

Tewkesbury is an important historic market town with a wealth of medieval featuresand timber framed buildings. The town centre is dominated by its distinctive Abbeyoverlooking the point at which the Rivers Severn and Avon meet, a sight made famousby coverage of the 2007 event. The town centre is vibrant and contains a good mix ofshops and services, including many independent stores, and a popular marketattracting locals and visitors alike.

Tewkesbury and neighbouring Ashchurch, with its mainline railway station, arestrategically positioned either side of Junction 9 of the M5 and are therefore attractivelocations for business, especially storage and distribution. They, and Bishop's Cleeveprovide a focus for a complex economy, which represents the Borough's uniqueposition as a predominantly rural area wrapping around two large urban areas. As in


Cheltenham and Gloucester, the Public Sector is the largest sector but its dominance islessened by a strong concentration of financial services jobs, primarily in Bishop'sCleeve.

Tourism plays a role in the Tewkesbury Borough economy, with many visitors attractedto the Cotswolds Area of Outstanding Natural Beauty part of which is within theBorough. Tewkesbury, with its impressive Abbey, the pretty town of Winchcombe andpicturesque villages like Snowshill and Stanton are major tourism draws so it issurprising that only 7.6% of the workforce is employed in tourism related work - wellbelow the average of 9.2% for the South West.

Unsurprisingly, Tewkesbury Borough does not have the same high rate of self-containment as its urban neighbours. Only 40% of the workforce lives and works withinthe Borough boundary, with many commuting in to Gloucester and Cheltenham oroutside the Joint Core Strategy Area to Worcester or Evesham.

The importance of Gloucester, Cheltenham and Tewkesbury/Ashchurch to the JointCore Strategy area should not obscure the fact that it is predominantly rural. Indeed,this is one of the most attractive features of the area and one of the reasons why itsurban areas are attractive places to live and work.

The landscape of the Joint Core Strategy area is dominated by two major features. TheRiver Severn and its tributaries have eroded soft Lias Clay to form the Severn andAvon Vales, while the harder limestone has remained forming the steep escarpmentand uplands of the Cotswolds in the east of the area. Dotted around the Vale are theoutliers of the escarpment such as Robinswood Hill and Chosen Hills and the smallerriver terrace hillocks such as Hempsted and Lassington Hill.

The area is rich in biodiversity and supports a number of important habitats such aslowland wet grassland, reedbeds, standing water, canals and rivers, traditionalorchards, woodlands, wood pastures, limestone grasslands and beech woodlands.These habitats and important landscape features have resulted in the Joint CoreStrategy area being heavily protected by a number of statutory designations. Theseinclude:

• 2 Special Areas of Conservation: Cotswolds Beechwood and Dixton Wood;• Cotswolds Area of Outstanding Natural Beauty;• 21 Sites of Special Scientific Interest;• 9 Local Nature Reserves; and• 70 Key Wildlife Sites

The downside of living alongside the River Severn and beneath the Cotswoldsescarpment is flood risk. The flooding events of July 2007 brought Tewkesbury, inparticular, and the wider Joint Core Strategy area to national attention. The floodhighlighted the vulnerability of the area and the importance of maintaining means ofaccess during flooding events, with areas of Tewkesbury town centre and othersettlements becoming cut off by flood waters for several days.


Tewkesbury lies at the confluence of the Severn and Avon rivers. In combination, theyand their tributaries drain a huge catchment area, including upland areas of Mid andNorth Wales, the Peak District and the Cotswolds. As a result Tewkesbury andGloucester often experience peak flows some days after peak rainfall. By contrast, theeastern fringe of the JCS area is characterised by short and steep sided river valleysdraining the Cotswolds escarpment. This landscape and the proximity of theescarpment, leads to rapid water run-off rates and can cause flash flooding. This wasparticularly evident in July 2007, when the River Chelt overtopped a 1 in 100 year floodalleviation scheme at Sandford Park and caused widespread flooding in Cheltenhamtown centre. Winchcombe and Tewkesbury area also affected by surface water run off.

Gloucester City is protected from the River Severn by extensive flood defences.However, smaller rivers and brooks draining into the main river can be subject toflooding and this is often exacerbated by high flows in the main river restricting theability of smaller watercourses to discharge. The Sud and Whaddon Brooks were bothidentified as being at risk from this type of flooding.

Please provide your comments on the above Portrait outlining any areas whereyou feel it should be amended. Please also provide any further information orevidence on how you believe the Portrait could be amended to talk morespecifically about the area of the JCS you are interested in.

From the above portrait and JCS evidence base it has been possible to identify anumber of Key Issues for the JCS.

Key Issues

1. Significant areas of environmental value exist across the JCS area. Restrictedaccess to them and lack of funding for management deters them from beingused as an environmental resource for the general public as well as limitinghabitat creation and landscape enhancement

2. As the JCS's population expands it is essential that the concept of self-relianceis maintained to avoid an increase in commuting. This is particularly importantto the creation of new and diverse communities.

3. The JCS area needs to plan for development in a manner that seeks to reducecarbon emissions and secure viable initiatives for the generation of renewableenergy.

4. New homes will need to reflect both the need and demands of the current andfuture population to support greater economic prosperity and address housingaffordability.

5. Across the JCS area locations currently experience economic deficits andimbalances in employment provision with a high degree of inequality of skills.This impedes the ability of settlements to maintain andincrease competitiveness.

6. There is a limited supply of employment land opportunities within the urbanareas to meet the needs of the JCS area and for continued economic growth.

7. The JCS must capitalise upon its unique range of tourism features in order toincrease the visitor numbers to the area.

8. There is a need for the provision of adequate visitor accommodation acrossthe area to serve a cross-section of needs.


9. All the settlements in the JCS area need to come together to compete moreeffectively in the market place.

10. The JCS area contains a significant amount of built and natural heritage that isin need of protection and enhancement which in turn has the opportunityto significantly contribute to tourist opportunities of the area.

11. There is a tendency for particular communities and key infrastructure within thearea to become segregated and isolated during flood events.

12. It is important that the urban regeneration initiatives of both Gloucester andCheltenham are realised to provide vital and viable centres of activity.Tewkesbury is also in need of enhancement reflective of its unique characterand sensitivity.

13. The success of sustainable communities within the JCS area is dependentupon the provision of appropriate health and community infrastructure.

14. There is a need to improve important transport links to other regions such asthe A417/419 (missing link) and the redualling of the railway linke betweenSwindon and Kemble along with improving transport links betweenGloucester, Cheltenham and Tewkesbury.

It is essential that the JCS process refines these isses to talk about specific placeswithin the JCS and seeks to address them as part of a development strategy for thefuture of the area to the year 2026.

Are the above issues the right issues for the JCS area and how do they relate tothe area of the JCS that you are particularly interested in?


Vision and ObjectivesThis part of the document deals with the future of the Joint Core Strategy area and howthe strategy can deal with the Key Issues set out previously. The first stage of thisprocess is to outline a possible Vision for the area in 2026.

Why is the Vision important?

It is essential in establishing a strategy for the Joint Core Strategy area that there is aclear Vision setting out how the area will look in the year 2026. The Vision for the JointCore Strategy will be informed by the Sustainable Community Strategy for each of theauthorities and the Local Strategic Partnership Visioning Workshop held in 2008.

What is the Spatial Vision for the JCS area?

The Vision for the JCS will evolve over the course of the preparation of the documentand it is important to start that process now. Below are some of the things that theVision will need to include or consider that have been identified through the LSPStakeholder Workshop, the ongoing evidence base and the challenges arising from theSpatial Portrait.

By 2026 the city and towns of the Joint Core Strategy area will be regenerated and willhave grown to create a thriving sub-region of self-reliant and interlinked communitiesthat complement one another.

The city and town centres of Gloucester, Cheltenham and Tewkesbury will haveundergone major regeneration and their vitality and viability will have been significantlyenhanced, strengthening their role as the focus for employment, leisure and tourism. InGloucester City, the Gloucester Heritage Urban Regeneration Company (GHURC) inpartnership with the City will have completed the bringing forward a number of keydevelopment sites by 2016 inspired by the City's unique historic character and, buildingon the success of Gloucester Quays, attracted people and businesses back to thecentre. People will be able to walk or cycle safely around the City Centre andneighbourhoods linked to an efficient public transport system that will provide rapidaccess from the suburbs to a revamped bus station adjoining a revitalised King'sSquare.

Civic Pride, in Cheltenham, will have been successful in intensifying the use ofunderused Town Centre sites like North Place and Royal Well and in redevelopingexisting iconic buildings such as the Municipal Offices. Civic Pride will also haveintegrated peripheral parts of the town centre like the Lower High Street and theBrewery to the Central Promenade and it will be possible to walk all the way from NorthPlace to Montpellier along a central regency boulevard.

In Tewkesbury, the town centre will need to retain the medieval character whilstallowing for some sensitive redevelopment.


The Vision will also need to consider the scale and manner in which Urban Extensionsmay come forward and how the could create attractive and sustainable places to live.

The Vision will need to set out how all development, be it in regenerated centres ornew urban areas, will need to minimise its contribution to climate change and maximisethe use of renewable energy sources, passive solar gain and natural ventilation. It willalso have to set out the manner in which flood risk and water management isaddressed.

It is also important that within the Vision the JCS sets out how the provision of newhomes will have met the needs and demands of the locality in providing the requiredmix and balance of both affordable and market of homes. The design and quality ofnew homes will also need to encourage opportunities for home working and enable theright type of accommodation to be provided in the right location. Lifetime homes willneed to be considered to provide for the needs of an elderly population.

The provision of new homes across the JCS area will need to be balanced by a step-change in employment provision and opportunities to maintain historically high rates ofself-containment and reduce dependency on the private car. The regeneration ofGloucester, Cheltenham and Tewkesbury will also need to focus on making themattractive and exciting places to set up business, with opportunities in the servicesector as well as traditional industries.

It is important that the Vision that emerges from this consultation processdescribes quite clearly how the various locations within the JCS are will havechanged. Therefore how would you like to see the Vision express the things thatare important to you and the area of the JCS that you are interested in?

Do you think there should be separate Vision statements for particular locationswithin the JCS? If so what would you like these to say?

In formulating and developing the Vision there are a number of things that will guide itsdevelopment and the strategy itself. These are set out below as Strategic Objectives:

Strategic Objectives

1. To mitigate contributions to climate change and ensure effective adaptationsare developed to help improve the resilience of the JCS area to the impacts ofclimate change.

2. To reduce the risk of flooding and its impact, particularly in reducing thelikelihood for the segregation of communities and key infrastructure.

3. If the RSS is published it will be necessary to meet the requirements of theRSS and the local communities in the provision of new homes that meet thevariety of housing needs across the JCS area, in particular, ensuring that theprovision of new homes facilitates the attraction and retention of skilled peoplelinked to economic growth.

4. To protect, manage and enhance biodiversity, the natural environment andformal/informal recreation through the development of a Green InfrastructureStrategy and the potential idea of a Regional Park to increase the value andaccessibility of the JCS environment for the benefit of the natural environmentand the improved health and well being of the JCS population.


5. To further build upon the current high levels of self-reliance in respect ofemployment within the JCS area through the provision of an employment landportfolio that seeks to facilitate employment sectors that are already strongwithin the JCS area for all of the existing workforce and attract additionalsectors that will help retain and attract skilled workers.

6. To facilitate the development of the skills agenda for people of all ages tomatch the future employment offer within the JCS area and seek to retain ahigher proportion of those people qualifying locally.

7. To effectively encourage the physical regeneration of the urban and rural areasthat capitalises upon Gloucester Heritage Urban Regeneration Company andCivic Pride sites within the Central JCS Core area and the market townfunction of Tewkesbury.

8. To facilitate improvements to, and the accessibility of healthcare andcommunity facilities.

9. To deliver effective solutions for transport, planning and urban design toreduce the dependency upon the private motor car and achieve greatercomplementarily between the functions of differing settlements.

10. To realise regeneration aspirations and to establish the JCS area as a singleattraction that caters for a diverse range of retail, cultural, educational, leisureand tourism needs by capitalising on the unique strengths of each settlement.

11. To ensure that development protects, preserves and enhances the importanthistoric environment and the distinctive townscape qualities of the JCS area,including protection of key views and accessibility of historic locations alongwith important vistas around the JCS area.

12. To maintain and build upon the existing tourism economy of the JCS area byimproving accessibility to existing attractions, by encouraging the developmentof new attractions in accessible locations that are appropriate in the scale andnature to their location, and by providing services to facilitate growth in thetourism industry.

13. To promote self-reliant communities by maintaining, enhancing and developinglocal and district shopping centres that provide for the day-to-day shopping andcommunity service needs of the local population and promoting appropriatedevelopment that supports their function.

Do you consider that these are the right Strategic Objectives for the JCS area?

How can they be refined to address more specifically the areas of the JCS whichare of interest to you?


Strategic Spatial Policy Areas

Development in the JCS Area

The proposed Joint Core Strategy will ultimately sit in the middle of a hierarchy of plansthat will set out the parameters for development in the area covered by the threeCouncils, taking into account the eventual published RSS.

Informing the Joint Core Strategy

In addition to the RSS there are a number of other influences that play their part inthe preparation of the final Core Strategy. These may be summarised as:-

• National Planning Policies set out in government circulars regulations andpolicy statements

• The Evidence Base comprising data and spatial analysis of the situation atpresent in the JCS area

• Local Priorities determined by consultation with stakeholders and the widergeneral public

• Sustainable Community Strategies prepared by the LSPs

The three local authorities have also produced Sustainable Community Strategieswhich set out the vision each authority has for the development of their local area. TheJoint Core Strategy should also be mindful of these visions in the course ofits preparation.

Regional Spatial Strategy


The South West Regional Spatial Strategy remains important to the production of theCore Strategy and will set out the levels of housing and employment provision neededfor each area of the South West up to the year 2026.

The Draft RSS was published in April 2006 and the Examination in Public of thedocument commenced a year later in April 2007. In July 2008 the Secretary of Statepublished the Proposed Modifications she intended to make following receipt of thePanels Report. This document represents the most up to date thinking about theRegional Strategy but the final version of the RSS remains as yet unpublished. Theprovisions set out in the proposed modifications form the basis for this participationdocument but this should neither imply acceptance or agreement with these provisionsby the constituent authorities in the JCS area.

Acknowledging the contentious nature of the emerging RSS growth proposals, thehousing figures contained within it comprise

• 34,200 additional houses to be provided for in the JCS area up to 2026. 11500of these to be in Gloucester, 8100 in Cheltenham and 14,600 in Tewkesbury

• 5 possible Urban Extensions in the JCS area to provide up to 11300 of thetotal housing set out above

• 10,750 new jobs to be provided for in the Cheltenham Travel to Work Area and39Hectatres of additional employment land to be provided. 11,700 new jobs inthe Gloucester Travel to Work Area and an additional 79 Hectares ofemployment land.

The Proposed Changes RSS also includes a possible urban extension to the South ofGloucester CIty, mostly within the District of Stroud. This is not part of the JCS but willbe addressed jointly with Stroud District Council should it be retained within theeventual published RSS.

Flexibility

Whatever the final provisions are of the RSS they remain a snapshot of what is thoughtlikely to be required over nearly 20 years. Both the RSS and the Core Strategy whenadopted will be constantly reviewed and monitored and changes made ascircumstances change.


Gloucester City Urban Area

The Context

National Planning Policy

• PPS1: Planning Sustainable Development• SPPS1: Planning and Climate Change - Supplement to Planning Policy

Statement 1• PPS3: Housing• PPS6: Planning for Town Centres• DPPS4: Planning for Sustainable Economic Development

Regional Spatial Strategy for the South West - Proposed Changes

• CSS: The Core Spatial Strategy• Development Policy A: Development at Strategically Significant Cities and

Towns (SSCTs)• HMA3: Gloucester and Cheltenham HMA• ES1: Sustainable Economic Prosperity• ES2: Providing for Employment land and Premises• ES3: Review of Employment Sites

Regional Spatial Strategy for the South West - Proposed Modifications (RSS-SW)

Gloucester is identified in Draft Development Policy A of the Regional Spatial Strategy(RSS) for the South West (Proposed Changes) as a Strategically Significant City orTown (SSCT). Towns and Cities have been identified within the Draft RSSas strategically significant due to the crucial role they play in the region as focal pointsfor housing, employment, shops, services, facilities and public transport provision. Inaccordance with the principles of the policy, the Draft RSS identifies locations fordevelopment in and around Gloucester recognising that the urban area of Gloucestercannot itself accommodate entirely the needs and demands for homes and jobs withinthe City.

While the Draft RSS identifies a number of areas to accommodate the future expansionof the City, it also sets out a separate requirement of 11,500 new homes to be providedwithin the City administrative boundary (urban area) between the years 2006 to 2026.In considering this, it must be acknowledged that the requirement runs from the year2006 and therefore a significant amount of housing will already have already beencompleted over the past three years, in addition to existing planning permissions thathave not yet been built.

In addition to housing requirements, it is also acknowledged that Gloucester has beenunderperforming economically in relation to the rest of the South West for a number ofyears and that economic performance needs to be improved, if it is to compete with


other cities and towns in the South West and West Midlands. The current draft of theRSS also requires the 11,700 jobs to be provided across the Gloucester City Travel toWork Area. It is necessary therefore for the JCS to identify the manner in which theCity and the SSCT can also grow economically.

Strategic Objectives: 3 / 5/ 7

Key Issues : 4 / 5 / 6 / 9 / 12 / 13 / 14

Issues affecting the JCS area

As set out above, the Draft RSS (Proposed Changes) states that 11,500 new homesshould be provided within Gloucester City's administrative boundary up to 2026. Whilstthe Joint Core Strategy will not in itself allocate specific sites for all of the developmentrequired, it is critical that it considers the strategic context of how this developmentcould be delivered.

Consideration must therefore be given to where this new development could beaccommodated. A key driver for the delivery of an element of the City's requirement forhomes and jobs is the Gloucester Heritage Urban Regeneration Company (GHURC)which was established in 2004. The 'area of influence' of the GHURC is known as the'Central Area' and includes a significant amount of brownfield land within the City.While your views on the manner in which the Joint Core Strategy should assist urbanregeneration within the remit of the GHURC is sought in the Urban RegenerationSection of this consultation document, this section seeks to gain your views on the wayin which homes and jobs can be provided within the City both within and outside theremit of the GHURC.

Early evidence informing the JCS has identified that the City is likely to be able toaccommodate the Draft RSS housing requirement within its administrative boundary.However, consideration must be given the challenge of achieving this and thesignificance of not being able to achieve it. For example, many of the sites locatedwithin the GHURC regeneration area are affected by a variety of constraints, suchas contaminated land, or poor accessibility, that make them difficult to bring forward fordevelopment. Non-delivery of these sites may have an adverse impact on the Citybeing able to achieve the Draft RSS housing requirement.

Yor views are therefore sought on the how the current requirement couldbe achieved in the city.

Things To consider Outcomes

The JCS could maximise theamount of housing providedon urban sites throughincreased densities for allsites.

While high density development may provide theopportunity to increase the amount of housing providedwithin the urban area it may not provide the right type andrange of housing required to meet the needs anddemands. This may affect the deliverability of a number ofCity Centre urban sites.


Where the City cannotprovide enough deliverablesites to meet the draft housingrequirement it should seek toprovide them as close to theCity as possible.

This could result in an element of the City's housingrequirement being found within the urban extensionsproposed on the edge of the City in order to ensure thathousing development is retained within the GloucesterSSCT.

The JCS should identify areasor sites within the City wherehigher densities may beappropriate.

Development in this context is likely to be primarilyconcentrated in the central area of the city, with someadditional appropriate peripheral sites identified.

How do you think the city can best accommodate its housing requirement?

Sustainability Impact

The following Sustainability Objectives are of particular importance: 10 / 11 / 15


Cheltenham Urban Area

The Context




Regional Spatial Strategy for the South West - Proposed Changes


Towns (SSCTs)• HMA3: Gloucester and Cheltenham HMA• ES1: Sustainable Economic Prosperity• ES2: Providing for Employment land and Premises• ES3: Review of Employment Sites

Cheltenham Town is identified in Draft Development Policy A of the Regional SpatialStrategy (RSS) for the South West (Proposed Changes) as a Strategically SignificantCity or Town (SSCT). Towns and cities have been identified within the Draft RSSas strategically significant due to the crucial role they play in the region as focal pointsfor housing, employment, shops, services, facilities and public transport provision. Inaccordance with the principles of the policy, the Draft RSS identifies locations fordevelopment in and around Cheltenham recognising that the urban area cannot itselfaccommodate entirely the needs and demands for homes and jobs.

At present the current emerging Draft RSS identifies a number of areas aroundCheltenham that it proposes should accommodate the future expansion, it alsoidentifies a separate requirement of 8,100 new homes to be provided within theadministrative boundary of Cheltenham between the years 2006 to 2026, of which6,500 should be within the urban area. In considering this, it must be acknowledgedthat the requirement runs from the year 2006 and therefore a significant amount ofhousing will already have already been completed over the past three years, in additionto existing planning permissions that have not yet been built.

In addition to housing requirements, it is also acknowledged that Cheltenham needs tocompete with other cities and towns in the South West and West Midlands. The currentdraft of the RSS also requires the 10,750 jobs to be provided across the Cheltenham


Travel to Work Area. It is necessary therefore for the JCS to identify the manner inwhich the SSCT can provide this is a sustainable manner.

The approach to the areas proposed for development outside of the town'sadministrative boundary are discussed elsewhere in this document (Sustainable UrbanExtensions Section) and this section seeks your views on how Cheltenham shouldaccommodate new development itself.

Strategic Objectives: 3 / 5/ 7

Key Issues : 4 / 5 / 6 / 9 / 12 / 13 / 14


Historically Cheltenham has been seen as an attractive place to live and work with agood quality of life and areas of high architectural worth. Cheltenham town centre andits retailing over many years has performed better than neighbouring Gloucester butrecently new development such as the Gloucester Quays has significantly raisedGloucester's retail competitiveness and illustrated the need for Cheltenham to continueto move forward to maintain a collective approach to prosperity. Housing andemployment provision still remains a priority for the town and there is a particular needto provide higher levels of affordable housing.

The "Civic Pride" initiative in Cheltenham aims to regenerate and improve the viabilityof a number of town centre sites whilst at the same time increase the vitality andattractiveness of town centre locations.

Things to consider Outcome

The JCS could maximisethe amount of housingprovided on urban sitesthrough increaseddensities for all sites.

While high density development may provide the opportunity toincrease the amount of housing provided within the urban areait may not provide the right type and range of housing requiredto meet the needs and demands of Cheltenham or the HousingMarket Area. This may affect the deliverability of a number ofurban sites. It may not also be appropriate to provide high-density development in some areas of the Borough.

Should Cheltenham notbe able to identifysufficient sites within theurban area to meet itshousing requirements itshould seek to providethem as close to theurban area as possible.

This could result in an element of Cheltenham's housingrequirement being need to be found on the periphery of theurban areas and/or within urban extensions to ensure thathousing development is retained within the Cheltenham SSCT.

The JCS should identifyareas or specificsites within Cheltenhamwhere more intensive

Development in this context is likely to be primarilyconcentrated in the central area of the town, with someadditional appropriate peripheral sites identified.


development or higherdensities may beappropriate.

Should development bepermitted within theCheltenham Green Belt?

Within Cheltenham Borough there are areas designated asGreen Belt. Should development be permitted to in these areasto reduce pressure on other parts of the urban area?

How do you think Cheltenham can best accommodate its housing requirement?


The following Sustainability Objectives are of particular importance: 10 / 11 / 15


Tewkesbury Borough

The Context




Regional Spatial Strategy for the South West - Proposed Changes (RSS-SW)


Towns (SSCTs)• ES1: Sustainable Economic Prosperity• ES2: Providing for Employment land and Premises• ES3: Review of Employment Sites

In the Draft Revised Regional Spatial Strategy 2,900 houses are proposed to beprovided outside of the SSCT area of Gloucester and Cheltenham within TewkesburyBorough Council's administrative area. Of the 2,900 houses 500 are already providedfor on committed sites. Within the Borough Tewkesbury is identified as a principlesettlement therefore one option to accommodate the level of growth required, up to2026, would be to identify Tewkesbury/Ashchurch as an area for growth. The secondoption would be to identify Tewkesbury/Ashchurch again and Winchcombe, which is amarket town with a high level of community facilities. The third option for considerationis to identify both Tewkesbury/Ashchurch and Winchcombe as well as a number oflarger villages for some growth in order that they can retain their school and/or localshop and other facilities.

Strategic Objective: 3/5/7

Key Issue: 1 / 2 / 5 / 9 / 11 / 12 / 14

Issues facing the JCS Area

The Draft Regional Spatial Strategy for the South West sets out that 14,600 newdwellings and a significant proportion of employment land should be provided withinTewkesbury's administrative boundary up to 2026. Whilst the Joint Core Strategy will


not in itself allocate specific sites for housing or employment development, it is criticalthat it considers the strategic context within which this development is delivered.

Within Tewkesbury Borough, outside the Urban Extensions, there are several ways ofaccommodating the level of growth set out in the Regional Spatial Strategy, namely the2,900 dwellings figure for sites elsewhere in the Borough.


Identify Tewkesbury/Ashchurch as the area forgrowth

All growth would be concentrated adjacent to the built up areaof Tewkesbury/Ashchurch, some smaller settlements wouldnot have the opportunity for limited growth to help maintainservices.

Identify Tewkesbury/Aschurch andWinchcombe as areas forgrowth

All growth would be concentrated adjacent to the built upareas of Tewkesbury/Ashchurch and Winchcombe, somesmaller settlements would not have the opportunity for limitedgrowth to help maintain services.

Identify Tewkesbury/Ashchurch, Winchcombeand some larger villagesas areas for growth

Growth would be directed to a larger number of settlementsbased on their level of services and accessibility. Lower levelsof growth would help to maintain the level of services in thesmaller settlements.

JCS Option 1

JCS Option 2


JCS Option 3

Looking at the table and alternatives above, do you have any views on wheredevelopment should be focussed in the rural areas?

Do you think there are any alternatives that have not been considered? If so,what are they?


The following Sustainability Objectives are of particular importance: 10 / 15


Sustainable Urban Extensions

The Context

The Draft RSS (Proposed Changes) sets out that that the Gloucestershire Green Beltwill continue to maintain the separate identities of Cheltenham and Gloucester, but thenecessary requirement for new homes in both locations and along with the need tomaintain and grow the economic potential of the SSCTs mean that this need cannot bemet solely within the existing urban areas.

The RSS says that the most sustainable solution is to provide for urban extensions(commonly known as Sustainable Urban extensions or SUEs). The Secretary of State'sProposed Changes to the Draft RSS identifies five areas of search for such SUEs .These areas of search are shown diagrammatically in the RSS plan but it is possible todiscern their general location from the text. The five areas are :-

1. North of Gloucester around Longford/Innsworth2. NW Cheltenham around Swindon Village3. South of Cheltenham around Shurdington/Leckhampton4. North of Bishops Cleeve5. Land North of Brockworth

The original draft of the RSS proposed only two areas of search, namely those at NorthWest Cheltenham and North of Gloucester. The remaining three areas of search wereadded after the Examination in Public by the Secretary of State in her ProposedChanges.

If the RSS is adopted it will ultimately be for the Joint Core Strategy to more preciselydefine the boundaries of these urban extensions and to set out policies for the designand development of these areas including infrastructure provision and phasing. Theprecise number of SUEs required and the level of development they will be expected toaccommodate will be dependant upon the publication of the RSS. The Council's would,however, reiterate their objection to the contents of the Draft RSS Proposed Changes.

Issues for SUEs

It is possible at this stage to make estimates based on the latest version of the RSS toasses the potential development capacity of each of the SUEs and to give a generalindication of what associated facilities could be accommodated in each of the urbanextensions. Three of the potential areas of search are partly located within existingGreen Belt (NW Cheltenham, North Gloucester and Leckhampton /Shurdington) andthere is an expectation in the RSS that Green Belt boundaries would have to beredrawn to accommodate the development proposed in these areas.

All of the SUEs potentially have detailed development issues that need to beaddressed before they could be developed satisfactorily; such issues could includematters such as road and transport hierarchies, landscaping provision, detailed designguidance. ecological and habitat protection and many other such detailedconsiderations that accompany any new development. At this stage however the focus


of the participation exercise is to look at the more fundamental principles associatedwith the possible development of such sites should the RSS be published with them inas currently proposed.

1. North of Gloucester

• Development of this area would require an alteration to Green Belt boundaries.• Up to 2500 new homes could be provided on this land and approximately 10ha

of land could be used for open space requirements, 3ha of land for educationaluses5.5ha for employment use and nearly 3.5 ha of land could be utilised forcommunity purposes. Another 3.5 ha of land could be required for additionalinfrastructure requirements.

2. NW Cheltenham

• This area of search was included in both the draft RSS and in the proposedmodifications in the former document it was expected to accommodate 4,000additional houses whilst in the latter version this total has risen to 5000.

• Assuming that 5000 houses are built in this area the area could alsoaccommodate approximately 11 ha of employment land 20 ha of open space ,provide in excess of 14ha for educational use and over 6.5ha for communityuses. Around 7.5 ha would be required to meet other infrastructure needs.

• Green Belt boundary revisions would be needed to develop this area ofsearch.

3. South of Cheltenham

• This area of search was not included in the Draft RSS but in the ProposedChanges document it is said to have a capacity of around 1300 new homes.

• In addition to the 1300 new homes the site could provide over 5ha of openspace1.6 ha of space for educational needs, nearly 3 ha of employment landand 1.75 ha for community uses. Additional infrastructure needs could takearound 1.9 ha of land.

• Development in this area of search may necessitate a revision of existinggreen belt boundaries.

4. North of Bishops Cleeve

• This area of search was not included in the draft RSS.• Up to 1000 new homes could be built in this location with just over 1 ha being

provided for educational purposes and 2.2 ha and 1.35ha being used foremployment and community purposes . Nearly 1.5 ha could be required forinfrastructure needs.


5. Land North of Brockworth

• The RSS proposes that up to 1500 homes can be accommodated in this areaof search which is an addition to the draft RSS provision. Nearly 6ha of openspace could be provided with 2ha and 3.3ha respectively being provided foropen space and employment uses. Just over 2 ha could provide for communityuses and a similar land take could be utilised for other infrastructurerequirements.

• This area would require an alteration to the Green Belt Boundary.

Sustainability and SUEs

These potential urban extensions are seen by the latest version of the RSS as beingthe most sustainable option to accommodate additional housing growth outside of theexisting urban areas. The paragraphs above give approximate theoretical calculationsof the land required in each of the areas of search to accommodate some of the morebasic components of sustainable living. It does not follow however that all of thesecomponents will be provided in all of the SUEs. Some of these areas because of theirrelative size and relationship to existing urban areas may well be more sustainable ifmost facilities are provided within the SUE. Other areas may be located close toexisting schools or centres of employment and in those instances the most sustainablesolution may well be to utilise existing faculties rather than trying to provide them allanew within the urban extension.

All of the housing capacity figures mentioned in the paragraphs above should include asubstantial element of affordable housing.


Things to consider Outcomes

Should SUEs be selfsufficient in terms oftheir own needssuch as shopscommunity facilitiesand schools?

Such facilities would not be provided initially at the beginning ofdevelopment and would only be provided as developmentprogresses. In some instances the amount of development proposedmay be too small to justify provision or provide sufficient range offacilities and adjoining urban areas might provide such facilitiesmore effectively.

Should employmentbe provided in theSUEs proportionateto their size?

A principle of sustainable living is to try and reduce journeys to work.It may therefore be desirable to provide employment within the SUEssufficient for their needs. There may however be economies of scaleinvolved in such provision and the smaller SUEs may not be able toprovide a sufficient range of employment opportunities.

What role to you see each of the SUEs having within the wider JCS area?


The following Sustainability Objectives are of particular importance: 10 / 14 / 15 / 17


Priorities for Delivery Through Development

The Context

National Planning Policy Statement 1: Delivering Sustainable Development sets out theGovernment's commitment to developing strong, vibrant and sustainable communitiesand the requirement for development plans to carefully consider the relationshipbetween social inclusion, protecting and enhancing the environment, the prudent use ofnatural resources and economic development. It advises that this should beundertaken through bringing together and integrating policies for the development ofland with other land policies and programmes that influence the nature of places andhow they can function.

The emerging RSS has set out in the Proposed Changes the Government's proposalsfor the JCS area to the year 2026. While at present the three authorities of Gloucester,Cheltenham and Tewkesbury object to a number of policies within the RSS in particularthe areas of search, it is important in planning the future of the area, whatever theoutcome of the RSS, that the planning framework for the area sets out what thepriorities are for sustainable mixed communities in the future for the JCS area.

Strategic Objective: 1 / 2 / 3 / 4 / 8 / 9 / 10

Key Issue: 4 / 3 / 12 / 13 / 14


At present the JCS area contains a wide variety of mixed communities that aresupported by a range of community infrastructure such healthcare, open space, parksand gardens, transport and education. Much of these are provided alongsidedevelopment through developer contributions in association with other public funding toensure that communities have access to a range of community needs. In planning thefuture of the JCS area the plan must seek to ensure that not only is this infrastructuremaintained and improved upon but also look to how it can deliver a wider sustainableenvironment for people to live in.

In seeking to achieve this, it is going to be necessary for the JCS to set out what thepriorities are for the provision of a whole range of community infrastructure. While, thiswill be very much informed by the current Sustainable Community Strategies for thethree JCS authorities it is appropriate to consult on this as part of the emerging JCS,particularly where urban extensions will create new communities.

Listed below is a selection of the components of developer contributions that could besecured through development:

• Affordable housing• Education• Community facilities• Formal sport and recreation


• Informal sport and recreation including open space• Flood prevention• Walking and cycling improvements• Public transport improvements• New roads and highways• Rail improvements• Public realm improvements• Climate change measures• Renewable energy initiatives• Other (please specify)

Please choose which six of the above that you would make the priority to besecured through development proposals.

Sustainability Appraisal

The following Sustainability Objectives are of particular importance: 1 / 2 / 4 / 5 / 8 / 12 /14 / 15 / 15 / 17


Urban Regeneration

The Context

• PPS1: Delivery of Sustainable Development• Gloucester Heritage Urban Regeneration Company (GHURC)• Civic Pride

Key Issues: 4 / 5 / 12

Strategic Objectives: 5 / 8 / 10


The current draft of the RSS has indicated a five areas of search for extensions to theurban areas of Gloucester and Cheltenham in addition to a requirement for the urbanareas to provide additional housing and employment. While the JCS authoritiescurrently object to a number of policies within the most recent draft of the RSS thereare a number of urban regeneration initiatives that are being promoted withinGloucester and Cheltenham, namely the Gloucester Heritage Urban RegenerationCompany and Civic Pride.

It is important that in bringing forward urban regeneration schemes which are primarilybrownfield sites and urban extension on the edge of settlements that they are done soin a complementary manner rather than conflicting. Given the proposals set out in thecurrent version of the Draft RSS, the level of house building that will need to comeforward on an annual basis is likely to be higher than that which can be achieved fromthe urban areas alone. In the same vein it is not appropriate to release large areas ofgreenfield land on the edge of the urban areas at the expense of the widerregeneration of the urban areas.

The urban areas of Gloucester and Cheltenham are the nucleus of the JCS economyand must be revitalised if they are to continue and improved to be attractive places forpeople to visit, work and live. The JCS must therefore consider the manner in whichurban sites and greenfield urban extensions can be brought forward in an integratedmanner over the plan period.

In order to bring forward and promote urban regeneration the JCS could identify anddefine key regeneration areas within the JCS area and identify a suite of policies foreach that will help shape the way sites are able to come forward. Such areas couldinclude the extent of the Gloucestershire Heritage Urban Regeneration Company'sremit and one that could incorporate the initiatives of the Civic Pride initiative inCheltenham.

The following illustration demonstrates the indicative extent of the GHURC area alongwith the key sites within it. The JCS will need to develop a policy framework that allowsthese sites to come forward in parallel to peripheral greenfield sites.


JCS Regeneration of urban areas


The JCS could identifykey areas of GloucesterCity and Cheltenham asregeneration areas andinclude a suite ofpolicies specific to themto bring forwarddevelopment schemes.

The area delineating the remit of the Gloucester Heritage UrbanRegeneration Company and an area outlining the extent ofCheltenham's Civic Pride could be included within a JCS Policy.

These policies could also identify a number of key sites that willbe brought forward as part of the regeneration area, along withspecific design and infrastructure requirements included.

While the regeneration areas would have specific policies forthem guiding development proposals, they would not bestrategic allocations. This would allow a greater range offlexibility in bringing the whole area forward. This may,however, result in less certainty.


Rather than identify aregeneration area, theJCS could includespecific strategicallocations for siteswithin the urban areasand bring forwarddevelopment on a site-by-site basis.

This would set out a series of development policies specific tokey sites within the JCS area. This would require a greaterdegree of certainty in terms of delivery than the above option forbringing sites forward. It would identify fewer areas fordevelopment than the above option as it would only identifythose sites that are fundamental to the delivery of the JointCore Strategy. This would provide a degree of certainty todevelopment but give less flexibility.

The JCS could adopt anapproach where itseeks to introduceregeneration initiativeswithin Tewkesbury itselfor the rural areas

While there is no active vehicle for regeneration within the ruralareas or Tewkesbury this could build upon the Healthy TownsInitiative and / or foster greater opportunities for theregeneration of rural areas.

What approach do you think should be used to bring forward urban regenerationsites?

Managing Urban Regeneration

The JCS will need to consider how it manages the release of land across the JCS area.In order to manage bringing forward urban sites in a complementary way withgreenfield sites on the edge of the urban areas, a phasing policy could be includedwithin the JCS. This could be used to ensure that sites within the urban area are eitherbought forward in advance of greenfield sites on the edge of the urban areas or at thesame time as them.

Things to consider Outcomes

The JCS could include aphasing policy thatensures that sites withinthe urban area are broughtforward in advance ofthose on the edge of theurban areas.

This would provide an approach that focuses on urban brownfieldland before greenfield land. This may be a difficult policy toimplement on the basis that urban sites can be more difficult tobring forward than greenfield sites on the edge of the urban area.It may also restrict sites that are in are sustainable locations inpreference for sites within the urban areas.

The JCS could include aphasing policy that allowsboth urban and greenfieldsites on the edge of theurban area to comeforward together at thesame time

This would need to be implemented in a co-ordinated manner thatis focused upon bringing forward sites based upon their ability tocreate and contribute to sustainable communities. Sites would beincluded within the JCS housing trajectory on the basis of this andbrought forward in a manner that seekst to ensure that urbanareas are revitalised and regenerated as planned.


The JCS could beprepared without a phasingpolicy and allow sites tocome forward as andwhen.

This would not require the JCS to include a policy on phasing at alland allow the market to determine when a site shall be broughtforward. It would not provide the clarity or certainty required fromthe devleopment plan process.

How do you think that the JCS should manage urban regeneration in the contextof greenfield development?


Topic Based Policy Areas

Affordable Housing

The Context


PPS1: Delivering Sustainable Development

PPS3: Housing: Sets out the everyone should have the opportunity of living in a decenthome, which they can afford, in a community where they want to live. As part of this,the Government is committed to providing high quality housing for people who areunable to access or afford market housing as well as making the step from affordablehousing into home ownership. PPS3 states that Regional Spatial Strategies should setout the regional approach to addressing affordable housing needs, including affordablehousing target for the region.

Regional Spatial Strategy for the South West - Proposed Modifications

• H1: Housing Affordability

Strategic Objective: 3

Key Issues: 2 / 4

Issues Facing the JCS area

The Cheltenham and Gloucester sub-region has been identified as a Housing MarketArea (HMA) which broadly covers the whole of Gloucestershire. Within this,Gloucester, Cheltenham and Tewkesbury Borough have been identified as a housingsub-market area that contains approximately 132,000 households. Each area withinthe JCS has varying issues regarding housing and provision, however, affordability hasand is an increasing problem across the entire JCS area and there is demand for moreaffordable housing of all sizes. Both Cheltenham and Gloucester also experience highlevels of overcrowding, which can be a sign of lack of larger affordable units.

PPS3 requires the JCS to set out an affordable housing target. The choices that needto be considered therefore relate to, what that target should be and the way affordablehousing could be delivered. The JCS will have to, however, balance the the need tocreate mixed and balanced communities with the realities of economic viability ofsecuring affordable housing through private sector developer contributions. Evidence todetermine the level of affordable housing required as part of the JCS is theGloucestershire HMA which also subject to an affordable housing viability assessment.The HMA and viability assessment are currently being updated and will inform thedevelopment of the emerging affordable housing policy. The choices set out below


seek to gain your views on the potential ways the JCS could provide affordablehousing.

The majority of affordable housing will be delivered as part of mixed open marketdevelopment across the JCS area, although 'exception sites' may be used to providepurely affordable housing development in locations where housing would normally notbe permitted. In such instances exceptions can be made due to the community benefitof the affordable housing. Most exception sites are likely to be in the rural areas of theJCS adjacent to an existing settlement or within the smaller rural settlementsthemselves. It is possible therefore to consider an option for delivering affordablehousing through exceptions sites within the JCS.

Given the above, when considering new housing schemes we need to decide on theminimum size of site that where affordable housing will be required and the amount ofaffordable housing to be provided. This is expressed as a percentage of the sitecapacity. The options are presented below for your consideration, however, they arealso dependent upon the Councils taking viability advice on the feasibility of theirimplementation.

Provison of Affordable Housing

To consider Outcome

1. Adopt the Draft RSSrequirement of 35% asa minimum.

This is the draft RSS reqirement and should be the minimum sought in theJCS area.

2. Adopt a JCS widetarget of 40% or higher.

Higher affordable housing requirements have the potential to providemore affordable housing where viabile. A percentage higher than 40%may however become unviable, especially on some brownfield sites.Higher targets also may reduce the contributions sought for infrastructureprovision.

3. Establish differentpercentage targets forgreenfield andbrownfield sites.

This would allow a flexible approach to providing affordable housing thatconsiders the viability of bringing forward different land types.

4. Have specific targetsfor particular sites withinthe JCS area and a JCSwide target forelsewhere.

This would allow higher provision to be provided on sites where it wasdeemed viable as part of the development plan process.

What approach to securing affordable housing should be adopted in the JCS?


Should all sites contribute to affordable housing or should a threshold beintroduced, if so what should that threshold be?

What should a threshold for the provision of affordable housing be in the ruralareas if one is necessary?


The following Sustainability Objectives are of particular importance: 12 / 15


Sustainable Buildings

The Context

• PP

jcs issues and questions consultation -...

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