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Gloucester Cheltenham Tewkesbury Joint Core Strategy (GCT JCS): Examining Inspector’s Final Report

Gloucester Cheltenham Tewkesbury Joint Core Strategy (GCT JCS): Examining Inspector’s Final Report

The Gloucester Cheltenham Tewkesbury Joint Core Strategy (GCT JCS) has been produced by Gloucester City Council, Cheltenham Borough Council and Tewkesbury Borough Council. The JCS plan period is 2011 – 2031. When the GCT JCS is adopted, all three local planning authorities will commence work on individual district-wide local plans. The Inspector’s final report is being taken to individual full councils for them consider whether to accept the main modifications and formally adopt the JCS. The dates of the full council meetings are provided below.

Gloucester City Council

23rd November 2017

Tewkesbury Borough Council

5th December 2017

Cheltenham Borough Council

11th December 2017

 

Strategic Housing Market Assessment

The table below sets out a number of scenarios that have influenced the housing requirement for each district and the overall housing need for the GCT JCS administrative boundary.

 

Demographic Scenario

Economic Led Scenario

Final Housing Requirement

Gloucester City Council

13,290 dwellings

13,675 dwellings

14,359 dwellings

Tewkesbury Borough Council

8,640 dwellings

9,425 dwellings

9,899 dwellings

Cheltenham Borough Council

9,900 dwellings

10,395 dwellings

10,917 dwellings

Total

31,830

33,495

35,175

 

The demographic scenario forms the basis of the SHMA assessment. The economic led scenario factors into the scenario the delivery of 39,500 jobs over the plan period on top of the housing requirement arising from demographic changes. The final housing requirement, which is the Objectively Assessed Housing Need (OAHN) for the GCT JCS, is a composition of demographic changes, economic led and a 5% uplift to the total housing requirement. The 5% uplift has been included as a result of the affordable housing need not being met through the market housing schemes, even where they are proposing to deliver a policy compliant level of affordable housing. The 5% is there to try and address this deficiency.

In addition to the above, other accommodation needs will be required over the plan period, including older persons accommodation. The OAHN has factored into its calculation 1,456 Use Class C3 retirement/sheltered housing units and 1,011 Use Class C2 extra care units (see final requirement table above). However, a further 1,558 non-specified institutional Use Class C2 bed spaces over the plan period in addition to the OAHN.

Housing Land Supply

Whilst the OAHN has been established as 35,175 dwellings, the JCS is delivering 31,824 dwellings. The shortfall equates to 3,351 dwellings. This shortfall is apportioned to Gloucester City Council (1,346 dwellings) and Tewkesbury Borough Council (approx. 2,400). Tewkesbury Borough Council’s deficit has primarily arisen following the withdrawal of the MOD Ashchurch site as an allocation for residential development.

In terms of housing land supply calculations, the following table sets out the housing land supply position and the applicable buffers for each respective authority.

 

Housing Land Supply at Adoption

Buffer

Gloucester City Council

5.8 yrs

5%

Tewkesbury Borough Council

5.3 – 6 yrs

20%

Cheltenham Borough Council

6 yrs

20%

 

Monitoring and Reviews

A review of Gloucester City and Tewkesbury Borough Council’s housing requirement is to be commenced immediately following adoption of the JCS.

In accordance with central government guidance, all development plans will be required to be reviewed every 5 years to ensure the contents is kept up to date.

Solely for monitoring purposes, the Inspector has added an additional 10% buffer is to be added to the housing requirement on an annual basis. If completions fall below 110% of the supply trajectory, then this was considered by the Inspector to act as an early warning system to review and take corrective action.

Another approach that will be used to monitor the JCS will be through assessing whether cumulatively strategic allocations are delivering 75% of their projected completions over three consecutive years. Where the 75% threshold is not being achieved this would trigger the requirement for the Council’s to consider a partial or full JCS review.

RCA Regeneration Comments:

The terminology of ‘consider’ undertaking a partial or full review of the JCS review is significant. Essentially, the Council could be delivering, for example 70%, but is currently undertaking corrective action in the form of a Call for Sites or SHLAA and deem that a review is unnecessary due to other ongoing work to address such deficiencies.

There is still an unmet requirement of 1,558 Use Class C2 institutional bed spaces required over the plan period.

As some of you are aware, RCA Regeneration has also undertaken analysis of the implications of the Government’s proposed standardised OAHN calculation.  While our initial analysis has focused upon the West Midland Authorities, we have undertaken the same analysis on the 3 authorities of the GCT JCS.  Ultimately, the Council has calculated that their OAHN is 1,759 dwellings per annum.  Despite this, the plan is currently only delivering 1,572 dwellings per annum because of the aforementioned shortfalls.  However, in tallying up the Government’s proposed housing requirement, we get an annualised total of 1,792 dwellings per annum.  This figure exceeds the current calculated OAHN by approximately 2%.  However, the Government’s standardised methodology is only the minimum figure to be used in assessing OAHN and makes no allowance for economic growth.  Importantly, the GCT JCS has incorporated a percentage increase to meet economic growth.  Such a percentage increase would therefore appear necessary to be added to the standardised methodology.  Furthermore, the standardised OAHN exceeds the annualised housing target of the GCT JCS by approximately 14.0%.  As such, if the plan is deemed out of date in one of the authority areas, the standardised figures are to be used in the 5 year calculation.  On that basis, it is highly likely that the authority would struggle to demonstrate the minimum 5 year housing land supply.  

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