JCS Issues and Questions Consultation

Foreword

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

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

Cheltenham Borough, Gloucester City and Tewkesbury Borough together with Gloucestershire County Council have various significant objections to key aspects of the RSS, particularly in relation to unjustified urban extensions and unnecessary incursion into the Green Belt arising from its proposals for increased growth to unprecedented levels.. Although the Councils remain opposed to the RSS, we feel it is vital to put plans in place to help secure proper infrastructure should applications come forward for proposals within the Draft RSS.

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

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

JCS Issues and Questions Consultation Page 1 JCS Issues and Questions Consultation Page 2 Introduction

This document has been produced by Gloucester, Cheltenham and Tewkesbury Councils. Its purpose is to raise awareness of the Key Issues that the area faces and to generate debate about how these could be addressed. The document is the first step towards a Joint Core Strategy that will set out the strategic planning framework for the three 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 each authority.

Preparing a Joint Core Strategy will mean making choices about how the area will develop over the period from now until 2026. As part of the preparation of the JCS it is important to consult stakeholders and communities on what they see as the issues for today and the solutions for the future. This document is the first stage in the preparation of the Joint Core Strategy and the Councils are seeking your views on a number 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 Country Planning (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 and Tewkesbury 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 the evidence that has been collected for the area. It ends by detailing what are considered to 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 potential Vision for the area for 2026 and a set of Strategic Objectives which would need to be met to achieve a Vision. The second part also outlines the possible policy areas that the Joint Core Strategy will need to cover in order to achieve the Vision and seeks your views on them. Each topic area includes a brief description of relevant national or regional policy as appropriate.

JCS Issues and Questions Consultation Page 3 Why a Joint Core Strategy?

The decision to produce a Joint Core Strategy was made by all three Councils in July 2008. Working jointly means a plan can be prepared at a strategic level for the future of the area to ensure that urban locations complement each other rather than compete. This is particularly important for Gloucester and Cheltenham because, by working together, they can act as a sub-regional centre and attract investment and jobs. it will also 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 of Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils. As such it will 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 the three Councils' Local Development Frameworks (LDFs). LDFs were introduced as part of the new statutory planning process under the 2004 Planning and Compulsory Purchase Act and will replace the Local Plans for each of the authorities. For more information on Local Development Frameworks and the new planning system please visit http://www.planningportal.gov.uk/uploads/ldf/ldfguide.html

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

JCS Issues and Questions Consultation Page 4 RSS is the Secretary of State's Proposed Changes version that was published following 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 a wide range of other plans and programmes prepared by each of the Councils and other stakeholders. For example it must have regard to the Housing Strategies prepared by each authority and the Economic Development Strategies and initiatives in existence. In particular for Gloucester and Cheltenham, the Joint Core Strategy will need to reflect upon the initiatives and proposals coming forward as part of the Gloucester Heritage Urban Regeneration Company and Civic Pride respectively. As can be seen, the JCS will therefore need to have regard to a whole range of strategies and programmes and seek to deliver the spatial elements of them all, where appropriate to the development of 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 the four (including the county-wide) Sustainable Community Strategies produced by the Local Strategic Partnerships (LSP) and the Gloucestershire Conference. A facilitated LSP Workshop was held in November 2008 where the LSPs set out what they wished to see included within the JCS. The outcomes of that workshop are listed below.

1. Develop strong and complementary relationships between communities whilst retaining the local distinctiveness of the City, Spa Town, rural communities and suburbs. 2. Improved retail offer (shops) 3. Meeting the variety of housing needs of the communities across the JCS area 4. Innovative solutions for transport, planning and urban design to increase the use of public transport. 5. Develop the employment portfolio of Gloucester, Cheltenham and Tewkesbury 6. Develop the skills agenda for people of all ages 7. Enhance the cultural, leisure and tourism offer 8. Mitigate contributions to climate change and ensure effective adaptations to help improve the resilience of the JCS area 9. Reduce the risk of flooding and its impact 10. Protect, manage and enhance biodiversity and the natural environment 11. Deliver effective and ongoing social, economic and physical regeneration of Gloucester 12. 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 Joint Core Strategy LSP Workshop Report, included within the evidence base for the Core Strategy.

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

What else will influence the Joint Core Strategy?

JCS Issues and Questions Consultation Page 5 Decisions taken in the Joint Core Strategy will need to be based on a strong understanding of the area and robust evidence. How, when and where the necessary level of infrastructure can be provided will also be a key determinant. At present the three Councils are preparing a range of evidence base studies. If you would like to view the 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 issues raised. This will then be used to help prepared a draft Joint Core Strategy. The timetable 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.

JCS Issues and Questions Consultation Page 6 Sustainability Appraisal

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

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

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

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

Making Comments

This document is all about getting your views. To make this easier, an online consultation system has been provided that allows you to read the document and comment 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 the document and a response form will be sent to you. Response forms and any general comments you have can be sent to the following email address: [email protected]

Or by post to: Joint Core Strategy Team Municipal Offices Promenade Cheltenham GL50 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 the document please contact us.

Introduction

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

JCS Issues and Questions Consultation Page 7 Vision and Objectives ...... 18 Strategic Spatial Policy Areas ...... 21

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

Topic Based Policy Areas ...... 42

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

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

JCS Issues and Questions Consultation Page 8 Policy Context

Although the Joint Core Strategy will be the key document in the three Councils' Local Development Frameworks, it is also important to understand that it needs to conform to national and regional policy. In addition and importantly, one of the changes brought in by the new planning system in 2004 is that local documents should not repeat national and regional policy. One of the things that is being consulted on with this document is what local issues are sufficiently covered by national policy and what are those that 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 out national policy. This change essentially replaced previous guidance in the form of Planning 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 of Practical Guides that explain how policy should be implemented.

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

What are Regional Spatial Strategies?

Regional Spatial Strategies are planning policy documents prepared at a regional level and set the strategic framework for development at local level. Once published, the Regional Spatial Strategy forms part of the statutory development plan for every local planning authority in that region. As such, all local level planning policy documents have to be in general conformity with the Regional Spatial Strategy. In practice, this means that Regional Spatial Strategies set out broad policies for the future of their region, such as the number of houses to be built in each area, the number of jobs to be provided and what level of infrastructure is required. It is then for local authorities to decide how best to implement them. The Joint Core Strategy area is situated in the South West region and therefore must be in general conformity with the Regional Spatial 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 June 2006 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 the Secretary of State's Proposed Changes to the draft in July 2008. The Regional Spatial Strategy for the South West was due to be finalised and published in June 2009 but this has been delayed. As yet, no revised adoption date has been set.

JCS Issues and Questions Consultation Page 9 What does the Draft RSS propose for the JCS area?

In the absence of a finalised Regional Spatial Strategy for the South West, Government advice 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 on transport, 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 sets out five areas of search for extensions to the existing urban areas. These areas of search are predominantly in Tewkesbury Borough but relate to the existing urban areas of Gloucester and Cheltenham; both of which are designated as Strategically Significant Cities and Towns in the Draft Regional Spatial Strategy. This relationship is one of the key reasons for working together on a Joint Core Strategy. Indicative locations for the proposed urban extension are illustrated on the diagram below.

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

JCS Issues and Questions Consultation Page 10 This consultation document is the first stage in producing the joint development plan and has regard to the latest Draft of the Regional Spatial Strategy (RSS) for the South West. Despite Government promises, the RSS has still not been formally published. The Government advises that the Draft RSS should be used as a material planning consideration in the planning process when considering applications for proposals contained within it. The development industry therefore may not wait for the Government to publish the RSS and the Planning Inspectorate is likely to come under pressure to make decisions on planning appeals in advance of its publication.

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

JCS Issues and Questions Consultation Page 11 Spatial Portrait and Issues

What is a Spatial Portrait?

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

It is vitally important that the Spatial Portrait provides an accurate snapshot of the Joint Core Strategy area. As part of the process so far, a significant evidence base has been collated to understand the area. This evidence base includes specialist studies into the economy of the area, its housing market, the leisure and retail industry, as well as technical 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 statistics on social, economic and environmental issues collected as part of the Joint Core Strategy Sustainability Appraisal process.

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

The Spatial Portrait

Within the Joint Core Strategy area Gloucester City and Cheltenham together account for approximately 75% of the area's population and provide a focus for economic activity across the whole county. Their similarity in terms of size and population means that individually they are equally important to the functioning of the area. However, due to 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 one another. Gloucester dates back to Roman times and has a longer history of habitation than Cheltenham. Its position on the River Severn at the point where the river becomes an estuary meant it was a strategically important place. Gloucester was a natural port and retains a location important maritime heritage. To this day, its docks and quay remain a focus for the city, and now ship building and repairs take place alongside dockside flats and an exciting new retail destination. Away from the docks, Gloucester is dominated by its 11th Century Cathedral and evidence of earlier occupants in its Roman "gate" streets, historic central cross and medieval lanes, much of this is however, 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.

JCS Issues and Questions Consultation Page 12 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 town in Britain. Cheltenham is also characterised by a series of formal and semi-formal parks, gardens and green spaces, which give its centre an open feel and play host to numerous festivals and events. Away from the City and Town centres, both settlements have expanded greatly in the 19th and 20th centuries and both have become major urban areas and centres for the employment, services, shops and education.

Both settlements demonstrate a very high rate of self-reliance for employment, with almost 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 the town and makes them both relatively sustainable in respect of journey times. Both have access to the M5 motorway which passes directly between them along with mainline railway stations in both centres. Gloucestershire Airport also provides a hub for business 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 economies are very different and there remains a large gap in terms of earnings and general affluence. On average, earnings in Gloucester are 18% lower than those in Cheltenham. However, this disparity is somewhat offset by the difference in house prices 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 two centres. In Cheltenham, almost 40% of the workforce is qualified to degree level or higher and only 8% have no qualifications. In Gloucester, however, only 23% of the workforce 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 has areas within the top 10% most deprived in the country, while Gloucester has 5. The Town and City each have a further 10 and 17 Super Output Areas in the top 25% most deprived respectively. These pockets of deprivation demonstrate the inequalities that exist 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 both areas. Beyond this dominant sector, however, the two economies are distinctively different. Cheltenham's economy is concentrated within finance and in services such as hotels, retail and restaurants, with relatively low levels of manufacturing, construction, communications and distribution. Gloucester, by contrast, has a more balanced economy, with more employment in the manufacturing, construction and communications sectors and significantly less in the service industries and finances. The Tewkesbury rural area which surrounds Cheltenham and Gloucester City also contains a significant number of influential industries important to the local economy.

The recession has affected both settlements and unemployment has risen steadily from January 2008 and through 2009. The percentage claiming Job Seekers Allowance reached 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

JCS Issues and Questions Consultation Page 13 claimants. However Gloucester Quays has recently opened in Gloucester and produced a significant number of new jobs in the City.

In both settlements the importance of the service sector is rising. Cheltenham has developed a reputation as a retail destination and is ranked as the 23rd most important retail 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 take account of the very recently opened Gloucester Quays Designer Outlet, which has significantly increased the City's retail offer and is changing the retail offer in Gloucester significantly.

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

Outside the major urban areas of Gloucester and Cheltenham, the Joint Core Strategy area contains a number of important settlements across Tewkesbury Borough. Of these settlements, Tewkesbury and Ashchurch, on both sides of junction 9 of the M5 are the largest and provide a focus for economic activity in the Borough. Bishops Cleeve and Woodmancote (to the north of Cheltenham) and Winchcombe (in the Cotswolds) are also important centres providing services for their own populations and large rural areas. Elsewhere, the built up areas of Brockworth, Hucclecote, Churchdown, Innsworth and Longford look to Gloucester for services, while villages like Shurdington, Badgeworth and Uckington look to Cheltenham. Smaller villages and hamlets like Snowshill, Stanton and Boddington are dotted throughout Tewkesbury Borough, some containing valuable local services like village schools, shops, pubs and community halls.

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

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

JCS Issues and Questions Consultation Page 14 Cheltenham and Gloucester, the Public Sector is the largest sector but its dominance is lessened by a strong concentration of financial services jobs, primarily in Bishop's Cleeve.

Tourism plays a role in the Tewkesbury Borough economy, with many visitors attracted to the Cotswolds Area of Outstanding Natural Beauty part of which is within the Borough. Tewkesbury, with its impressive Abbey, the pretty town of Winchcombe and picturesque villages like Snowshill and Stanton are major tourism draws so it is surprising that only 7.6% of the workforce is employed in tourism related work - well below 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 within the Borough boundary, with many commuting in to Gloucester and Cheltenham or outside the Joint Core Strategy Area to Worcester or Evesham.

The importance of Gloucester, Cheltenham and Tewkesbury/Ashchurch to the Joint Core 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 its urban areas are attractive places to live and work.

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

The area is rich in biodiversity and supports a number of important habitats such as lowland wet grassland, reedbeds, standing water, canals and rivers, traditional orchards, woodlands, wood pastures, limestone grasslands and beech woodlands. These habitats and important landscape features have resulted in the Joint Core Strategy area being heavily protected by a number of statutory designations. These include:

• 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 Cotswolds escarpment is flood risk. The flooding events of July 2007 brought Tewkesbury, in particular, and the wider Joint Core Strategy area to national attention. The flood highlighted the vulnerability of the area and the importance of maintaining means of access during flooding events, with areas of Tewkesbury town centre and other settlements becoming cut off by flood waters for several days.

JCS Issues and Questions Consultation Page 15 Tewkesbury lies at the confluence of the Severn and Avon rivers. In combination, they and their tributaries drain a huge catchment area, including upland areas of Mid and North Wales, the Peak District and the Cotswolds. As a result Tewkesbury and Gloucester often experience peak flows some days after peak rainfall. By contrast, the eastern fringe of the JCS area is characterised by short and steep sided river valleys draining the Cotswolds escarpment. This landscape and the proximity of the escarpment, leads to rapid water run-off rates and can cause flash flooding. This was particularly evident in July 2007, when the River Chelt overtopped a 1 in 100 year flood alleviation scheme at Sandford Park and caused widespread flooding in Cheltenham town 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 to flooding and this is often exacerbated by high flows in the main river restricting the ability of smaller watercourses to discharge. The Sud and Whaddon Brooks were both identified as being at risk from this type of flooding.

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

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

Key Issues

1. Significant areas of environmental value exist across the JCS area. Restricted access to them and lack of funding for management deters them from being used as an environmental resource for the general public as well as limiting habitat creation and landscape enhancement 2. As the JCS's population expands it is essential that the concept of self-reliance is maintained to avoid an increase in commuting. This is particularly important to the creation of new and diverse communities. 3. The JCS area needs to plan for development in a manner that seeks to reduce carbon emissions and secure viable initiatives for the generation of renewable energy. 4. New homes will need to reflect both the need and demands of the current and future population to support greater economic prosperity and address housing affordability. 5. Across the JCS area locations currently experience economic deficits and imbalances in employment provision with a high degree of inequality of skills. This impedes the ability of settlements to maintain and increase competitiveness. 6. There is a limited supply of employment land opportunities within the urban areas 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 to increase the visitor numbers to the area. 8. There is a need for the provision of adequate visitor accommodation across the area to serve a cross-section of needs.

JCS Issues and Questions Consultation Page 16 9. All the settlements in the JCS area need to come together to compete more effectively in the market place. 10. The JCS area contains a significant amount of built and natural heritage that is in need of protection and enhancement which in turn has the opportunity to significantly contribute to tourist opportunities of the area. 11. There is a tendency for particular communities and key infrastructure within the area to become segregated and isolated during flood events. 12. It is important that the urban regeneration initiatives of both Gloucester and Cheltenham are realised to provide vital and viable centres of activity. Tewkesbury is also in need of enhancement reflective of its unique character and sensitivity. 13. The success of sustainable communities within the JCS area is dependent upon the provision of appropriate health and community infrastructure. 14. There is a need to improve important transport links to other regions such as the A417/419 (missing link) and the redualling of the railway linke between Swindon and Kemble along with improving transport links between Gloucester, Cheltenham and Tewkesbury.

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

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

JCS Issues and Questions Consultation Page 17 Vision and Objectives

This part of the document deals with the future of the Joint Core Strategy area and how the strategy can deal with the Key Issues set out previously. The first stage of this process 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 a clear Vision setting out how the area will look in the year 2026. The Vision for the Joint Core Strategy will be informed by the Sustainable Community Strategy for each of the authorities 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 document and it is important to start that process now. Below are some of the things that the Vision will need to include or consider that have been identified through the LSP Stakeholder Workshop, the ongoing evidence base and the challenges arising from the Spatial Portrait.

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

The city and town centres of Gloucester, Cheltenham and Tewkesbury will have undergone major regeneration and their vitality and viability will have been significantly enhanced, strengthening their role as the focus for employment, leisure and tourism. In Gloucester City, the Gloucester Heritage Urban Regeneration Company (GHURC) in partnership with the City will have completed the bringing forward a number of key development sites by 2016 inspired by the City's unique historic character and, building on the success of Gloucester Quays, attracted people and businesses back to the centre. People will be able to walk or cycle safely around the City Centre and neighbourhoods linked to an efficient public transport system that will provide rapid access from the suburbs to a revamped bus station adjoining a revitalised King's Square.

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

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

JCS Issues and Questions Consultation Page 18 The Vision will also need to consider the scale and manner in which Urban Extensions may 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 or new urban areas, will need to minimise its contribution to climate change and maximise the use of renewable energy sources, passive solar gain and natural ventilation. It will also have to set out the manner in which flood risk and water management is addressed.

It is also important that within the Vision the JCS sets out how the provision of new homes will have met the needs and demands of the locality in providing the required mix and balance of both affordable and market of homes. The design and quality of new homes will also need to encourage opportunities for home working and enable the right type of accommodation to be provided in the right location. Lifetime homes will need 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 of self-containment and reduce dependency on the private car. The regeneration of Gloucester, Cheltenham and Tewkesbury will also need to focus on making them attractive and exciting places to set up business, with opportunities in the service sector as well as traditional industries.

It is important that the Vision that emerges from this consultation process describes quite clearly how the various locations within the JCS are will have changed. Therefore how would you like to see the Vision express the things that are 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 locations within 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 its development and the strategy itself. These are set out below as Strategic Objectives:

Strategic Objectives

1. To mitigate contributions to climate change and ensure effective adaptations are developed to help improve the resilience of the JCS area to the impacts of climate change. 2. To reduce the risk of flooding and its impact, particularly in reducing the likelihood for the segregation of communities and key infrastructure. 3. If the RSS is published it will be necessary to meet the requirements of the RSS and the local communities in the provision of new homes that meet the variety of housing needs across the JCS area, in particular, ensuring that the provision of new homes facilitates the attraction and retention of skilled people linked to economic growth. 4. To protect, manage and enhance biodiversity, the natural environment and formal/informal recreation through the development of a Green Infrastructure Strategy and the potential idea of a Regional Park to increase the value and accessibility of the JCS environment for the benefit of the natural environment and the improved health and well being of the JCS population.

JCS Issues and Questions Consultation Page 19 5. To further build upon the current high levels of self-reliance in respect of employment within the JCS area through the provision of an employment land portfolio that seeks to facilitate employment sectors that are already strong within the JCS area for all of the existing workforce and attract additional sectors that will help retain and attract skilled workers. 6. To facilitate the development of the skills agenda for people of all ages to match the future employment offer within the JCS area and seek to retain a higher proportion of those people qualifying locally. 7. To effectively encourage the physical regeneration of the urban and rural areas that capitalises upon Gloucester Heritage Urban Regeneration Company and Civic Pride sites within the Central JCS Core area and the market town function of Tewkesbury. 8. To facilitate improvements to, and the accessibility of healthcare and community facilities. 9. To deliver effective solutions for transport, planning and urban design to reduce the dependency upon the private motor car and achieve greater complementarily between the functions of differing settlements. 10. To realise regeneration aspirations and to establish the JCS area as a single attraction that caters for a diverse range of retail, cultural, educational, leisure and tourism needs by capitalising on the unique strengths of each settlement. 11. To ensure that development protects, preserves and enhances the important historic environment and the distinctive townscape qualities of the JCS area, including protection of key views and accessibility of historic locations along with important vistas around the JCS area. 12. To maintain and build upon the existing tourism economy of the JCS area by improving accessibility to existing attractions, by encouraging the development of new attractions in accessible locations that are appropriate in the scale and nature to their location, and by providing services to facilitate growth in the tourism industry. 13. To promote self-reliant communities by maintaining, enhancing and developing local and district shopping centres that provide for the day-to-day shopping and community service needs of the local population and promoting appropriate development 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 which are of interest to you?

JCS Issues and Questions Consultation Page 20 Strategic Spatial Policy Areas

Development in the JCS Area

The proposed Joint Core Strategy will ultimately sit in the middle of a hierarchy of plans that will set out the parameters for development in the area covered by the three Councils, 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 in the preparation of the final Core Strategy. These may be summarised as:-

• National Planning Policies set out in government circulars regulations and policy statements • The Evidence Base comprising data and spatial analysis of the situation at present in the JCS area • Local Priorities determined by consultation with stakeholders and the wider general public • Sustainable Community Strategies prepared by the LSPs

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

Regional Spatial Strategy

JCS Issues and Questions Consultation Page 21 The South West Regional Spatial Strategy remains important to the production of the Core Strategy and will set out the levels of housing and employment provision needed for 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 the document commenced a year later in April 2007. In July 2008 the Secretary of State published the Proposed Modifications she intended to make following receipt of the Panels Report. This document represents the most up to date thinking about the Regional Strategy but the final version of the RSS remains as yet unpublished. The provisions set out in the proposed modifications form the basis for this participation document but this should neither imply acceptance or agreement with these provisions by the constituent authorities in the JCS area.

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

• 34,200 additional houses to be provided for in the JCS area up to 2026. 11500 of 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 the total housing set out above • 10,750 new jobs to be provided for in the Cheltenham Travel to Work Area and 39Hectatres of additional employment land to be provided. 11,700 new jobs in the Gloucester Travel to Work Area and an additional 79 Hectares of employment land.

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

Flexibility

Whatever the final provisions are of the RSS they remain a snapshot of what is thought likely to be required over nearly 20 years. Both the RSS and the Core Strategy when adopted will be constantly reviewed and monitored and changes made as circumstances change.

JCS Issues and Questions Consultation Page 22 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 or Town (SSCT). Towns and Cities have been identified within the Draft RSS as strategically significant due to the crucial role they play in the region as focal points for housing, employment, shops, services, facilities and public transport provision. In accordance with the principles of the policy, the Draft RSS identifies locations for development in and around Gloucester recognising that the urban area of Gloucester cannot itself accommodate entirely the needs and demands for homes and jobs within the City.

While the Draft RSS identifies a number of areas to accommodate the future expansion of the City, it also sets out a separate requirement of 11,500 new homes to be provided within 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 year 2006 and therefore a significant amount of housing will already have already been completed over the past three years, in addition to existing planning permissions that have not yet been built.

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

JCS Issues and Questions Consultation Page 23 other cities and towns in the South West and West Midlands. The current draft of the RSS also requires the 11,700 jobs to be provided across the Gloucester City Travel to Work Area. It is necessary therefore for the JCS to identify the manner in which the City 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 homes should be provided within Gloucester City's administrative boundary up to 2026. Whilst the Joint Core Strategy will not in itself allocate specific sites for all of the development required, it is critical that it considers the strategic context of how this development could be delivered.

Consideration must therefore be given to where this new development could be accommodated. A key driver for the delivery of an element of the City's requirement for homes 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 urban regeneration within the remit of the GHURC is sought in the Urban Regeneration Section of this consultation document, this section seeks to gain your views on the way in which homes and jobs can be provided within the City both within and outside the remit of the GHURC.

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

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

Things To consider Outcomes

The JCS could maximise the While high density development may provide the amount of housing provided opportunity to increase the amount of housing provided on urban sites through within the urban area it may not provide the right type and increased densities for all range of housing required to meet the needs and sites. demands. This may affect the deliverability of a number of City Centre urban sites.

JCS Issues and Questions Consultation Page 24 Where the City cannot This could result in an element of the City's housing provide enough deliverable requirement being found within the urban extensions sites to meet the draft housing proposed on the edge of the City in order to ensure that requirement it should seek to housing development is retained within the Gloucester provide them as close to the SSCT. City as possible. The JCS should identify areas Development in this context is likely to be primarily or sites within the City where concentrated in the central area of the city, with some higher densities may be additional appropriate peripheral sites identified. appropriate.

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

JCS Issues and Questions Consultation Page 25 Cheltenham Urban Area

The Context

National Planning Policy

Regional Spatial Strategy for the South West - Proposed Changes

Cheltenham Town is identified in Draft Development Policy A of the Regional Spatial Strategy (RSS) for the South West (Proposed Changes) as a Strategically Significant City or Town (SSCT). Towns and cities have been identified within the Draft RSS as strategically significant due to the crucial role they play in the region as focal points for housing, employment, shops, services, facilities and public transport provision. In accordance with the principles of the policy, the Draft RSS identifies locations for development in and around Cheltenham recognising that the urban area cannot itself accommodate entirely the needs and demands for homes and jobs.

At present the current emerging Draft RSS identifies a number of areas around Cheltenham that it proposes should accommodate the future expansion, it also identifies a separate requirement of 8,100 new homes to be provided within the administrative boundary of Cheltenham between the years 2006 to 2026, of which 6,500 should be within the urban area. In considering this, it must be acknowledged that the requirement runs from the year 2006 and therefore a significant amount of housing will already have already been completed over the past three years, in addition to existing planning permissions that have not yet been built.

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

JCS Issues and Questions Consultation Page 26 Travel to Work Area. It is necessary therefore for the JCS to identify the manner in which the SSCT can provide this is a sustainable manner.

The approach to the areas proposed for development outside of the town's administrative boundary are discussed elsewhere in this document (Sustainable Urban Extensions Section) and this section seeks your views on how Cheltenham should accommodate new development itself.

Strategic Objectives: 3 / 5/ 7

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

Issues affecting the JCS area

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

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

Things to consider Outcome

The JCS could maximise While high density development may provide the opportunity to the amount of housing increase the amount of housing provided within the urban area provided on urban sites it may not provide the right type and range of housing required through increased to meet the needs and demands of Cheltenham or the Housing densities for all sites. Market Area. This may affect the deliverability of a number of urban sites. It may not also be appropriate to provide high- density development in some areas of the Borough. Should Cheltenham not This could result in an element of Cheltenham's housing be able to identify requirement being need to be found on the periphery of the sufficient sites within the urban areas and/or within urban extensions to ensure that urban area to meet its housing development is retained within the Cheltenham SSCT. housing requirements it should seek to provide them as close to the urban area as possible. The JCS should identify Development in this context is likely to be primarily areas or specific concentrated in the central area of the town, with some sites within Cheltenham additional appropriate peripheral sites identified. where more intensive

JCS Issues and Questions Consultation Page 27 development or higher densities may be appropriate. Should development be Within Cheltenham Borough there are areas designated as permitted within the Green Belt. Should development be permitted to in these areas Cheltenham Green Belt? to reduce pressure on other parts of the urban area?

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

Sustainability Impact

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

JCS Issues and Questions Consultation Page 28 Tewkesbury Borough

The Context

National Planning Policy

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

• CSS: The Core Spatial Strategy • Development Policy A: Development at Strategically Significant Cities and 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 be provided outside of the SSCT area of Gloucester and Cheltenham within Tewkesbury Borough Council's administrative area. Of the 2,900 houses 500 are already provided for on committed sites. Within the Borough Tewkesbury is identified as a principle settlement therefore one option to accommodate the level of growth required, up to 2026, would be to identify Tewkesbury/Ashchurch as an area for growth. The second option would be to identify Tewkesbury/Ashchurch again and Winchcombe, which is a market town with a high level of community facilities. The third option for consideration is to identify both Tewkesbury/Ashchurch and Winchcombe as well as a number of larger villages for some growth in order that they can retain their school and/or local shop 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 new dwellings and a significant proportion of employment land should be provided within Tewkesbury's administrative boundary up to 2026. Whilst the Joint Core Strategy will

JCS Issues and Questions Consultation Page 29 not in itself allocate specific sites for housing or employment development, it is critical that it considers the strategic context within which this development is delivered.

Within Tewkesbury Borough, outside the Urban Extensions, there are several ways of accommodating the level of growth set out in the Regional Spatial Strategy, namely the 2,900 dwellings figure for sites elsewhere in the Borough.

Things to consider Outcome

Identify Tewkesbury/ All growth would be concentrated adjacent to the built up area Ashchurch as the area for of Tewkesbury/Ashchurch, some smaller settlements would growth not have the opportunity for limited growth to help maintain services. Identify Tewkesbury/ All growth would be concentrated adjacent to the built up Aschurch and areas of Tewkesbury/Ashchurch and Winchcombe, some Winchcombe as areas for smaller settlements would not have the opportunity for limited growth growth to help maintain services. Identify Tewkesbury/ Growth would be directed to a larger number of settlements Ashchurch, Winchcombe based on their level of services and accessibility. Lower levels and some larger villages of growth would help to maintain the level of services in the as areas for growth smaller settlements.

JCS Option 1

JCS Option 2

JCS Issues and Questions Consultation Page 30 JCS Option 3

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

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

Sustainability Impact

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

JCS Issues and Questions Consultation Page 31 Sustainable Urban Extensions

The Context

The Draft RSS (Proposed Changes) sets out that that the Gloucestershire Green Belt will continue to maintain the separate identities of Cheltenham and Gloucester, but the necessary requirement for new homes in both locations and along with the need to maintain and grow the economic potential of the SSCTs mean that this need cannot be met 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's Proposed 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 to discern their general location from the text. The five areas are :-

1. North of Gloucester around Longford/Innsworth 2. NW Cheltenham around Swindon Village 3. South of Cheltenham around Shurdington/Leckhampton 4. North of Bishops Cleeve 5. Land North of Brockworth

The original draft of the RSS proposed only two areas of search, namely those at North West Cheltenham and North of Gloucester. The remaining three areas of search were added after the Examination in Public by the Secretary of State in her Proposed Changes.

If the RSS is adopted it will ultimately be for the Joint Core Strategy to more precisely define the boundaries of these urban extensions and to set out policies for the design and development of these areas including infrastructure provision and phasing. The precise number of SUEs required and the level of development they will be expected to accommodate 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 to asses the potential development capacity of each of the SUEs and to give a general indication of what associated facilities could be accommodated in each of the urban extensions. Three of the potential areas of search are partly located within existing Green Belt (NW Cheltenham, North Gloucester and Leckhampton /Shurdington) and there is an expectation in the RSS that Green Belt boundaries would have to be redrawn to accommodate the development proposed in these areas.

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

JCS Issues and Questions Consultation Page 32 of the participation exercise is to look at the more fundamental principles associated with the possible development of such sites should the RSS be published with them in as 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 educational uses5.5ha for employment use and nearly 3.5 ha of land could be utilised for community purposes. Another 3.5 ha of land could be required for additional infrastructure requirements.

2. NW Cheltenham

• This area of search was included in both the draft RSS and in the proposed modifications in the former document it was expected to accommodate 4,000 additional houses whilst in the latter version this total has risen to 5000. • Assuming that 5000 houses are built in this area the area could also accommodate approximately 11 ha of employment land 20 ha of open space , provide in excess of 14ha for educational use and over 6.5ha for community uses. Around 7.5 ha would be required to meet other infrastructure needs. • Green Belt boundary revisions would be needed to develop this area of search.

3. South of Cheltenham

• This area of search was not included in the Draft RSS but in the Proposed Changes 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 open space1.6 ha of space for educational needs, nearly 3 ha of employment land and 1.75 ha for community uses. Additional infrastructure needs could take around 1.9 ha of land. • Development in this area of search may necessitate a revision of existing green 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 for employment and community purposes . Nearly 1.5 ha could be required for infrastructure needs.

JCS Issues and Questions Consultation Page 33 5. Land North of Brockworth

• The RSS proposes that up to 1500 homes can be accommodated in this area of search which is an addition to the draft RSS provision. Nearly 6ha of open space could be provided with 2ha and 3.3ha respectively being provided for open space and employment uses. Just over 2 ha could provide for community uses and a similar land take could be utilised for other infrastructure requirements. • 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 being the most sustainable option to accommodate additional housing growth outside of the existing urban areas. The paragraphs above give approximate theoretical calculations of the land required in each of the areas of search to accommodate some of the more basic components of sustainable living. It does not follow however that all of these components will be provided in all of the SUEs. Some of these areas because of their relative size and relationship to existing urban areas may well be more sustainable if most facilities are provided within the SUE. Other areas may be located close to existing schools or centres of employment and in those instances the most sustainable solution may well be to utilise existing faculties rather than trying to provide them all anew within the urban extension.

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

JCS Issues and Questions Consultation Page 34 Things to consider Outcomes

Should SUEs be self Such facilities would not be provided initially at the beginning of sufficient in terms of development and would only be provided as development their own needs progresses. In some instances the amount of development proposed such as shops may be too small to justify provision or provide sufficient range of community facilities facilities and adjoining urban areas might provide such facilities and schools? more effectively. Should employment A principle of sustainable living is to try and reduce journeys to work. be provided in the It may therefore be desirable to provide employment within the SUEs SUEs proportionate sufficient for their needs. There may however be economies of scale to their size? involved in such provision and the smaller SUEs may not be able to provide a sufficient range of employment opportunities.

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

Sustainability Impact

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

JCS Issues and Questions Consultation Page 35 Priorities for Delivery Through Development

The Context

National Planning Policy Statement 1: Delivering Sustainable Development sets out the Government's commitment to developing strong, vibrant and sustainable communities and the requirement for development plans to carefully consider the relationship between social inclusion, protecting and enhancing the environment, the prudent use of natural resources and economic development. It advises that this should be undertaken through bringing together and integrating policies for the development of land with other land policies and programmes that influence the nature of places and how they can function.

The emerging RSS has set out in the Proposed Changes the Government's proposals for 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 particular the areas of search, it is important in planning the future of the area, whatever the outcome of the RSS, that the planning framework for the area sets out what the priorities 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

Issues affecting the JCS area

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

In seeking to achieve this, it is going to be necessary for the JCS to set out what the priorities are for the provision of a whole range of community infrastructure. While, this will be very much informed by the current Sustainable Community Strategies for the three 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 be secured through development:

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

JCS Issues and Questions Consultation Page 36 • 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 be secured through development proposals.

Sustainability Appraisal

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

JCS Issues and Questions Consultation Page 37 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

Issues affecting the JCS area

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

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

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

In order to bring forward and promote urban regeneration the JCS could identify and define key regeneration areas within the JCS area and identify a suite of policies for each that will help shape the way sites are able to come forward. Such areas could include the extent of the Gloucestershire Heritage Urban Regeneration Company's remit and one that could incorporate the initiatives of the Civic Pride initiative in Cheltenham.

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

JCS Issues and Questions Consultation Page 38 JCS Regeneration of urban areas

Things to consider Outcome

The JCS could identify The area delineating the remit of the Gloucester Heritage Urban key areas of Gloucester Regeneration Company and an area outlining the extent of City and Cheltenham as Cheltenham's Civic Pride could be included within a JCS Policy. regeneration areas and include a suite of These policies could also identify a number of key sites that will policies specific to them be brought forward as part of the regeneration area, along with to bring forward specific design and infrastructure requirements included. development schemes. While the regeneration areas would have specific policies for them guiding development proposals, they would not be strategic allocations. This would allow a greater range of flexibility in bringing the whole area forward. This may, however, result in less certainty.

JCS Issues and Questions Consultation Page 39 Rather than identify a This would set out a series of development policies specific to regeneration area, the key sites within the JCS area. This would require a greater JCS could include degree of certainty in terms of delivery than the above option for specific strategic bringing sites forward. It would identify fewer areas for allocations for sites development than the above option as it would only identify within the urban areas those sites that are fundamental to the delivery of the Joint and bring forward Core Strategy. This would provide a degree of certainty to development on a site- development but give less flexibility. by-site basis. The JCS could adopt an While there is no active vehicle for regeneration within the rural approach where it areas or Tewkesbury this could build upon the Healthy Towns seeks to introduce Initiative and / or foster greater opportunities for the regeneration initiatives regeneration of rural areas. within Tewkesbury itself or the rural areas

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

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 with greenfield sites on the edge of the urban areas, a phasing policy could be included within the JCS. This could be used to ensure that sites within the urban area are either bought forward in advance of greenfield sites on the edge of the urban areas or at the same time as them.

Things to consider Outcomes

The JCS could include a This would provide an approach that focuses on urban brownfield phasing policy that land before greenfield land. This may be a difficult policy to ensures that sites within implement on the basis that urban sites can be more difficult to the urban area are brought bring forward than greenfield sites on the edge of the urban area. forward in advance of It may also restrict sites that are in are sustainable locations in those on the edge of the preference for sites within the urban areas. urban areas. The JCS could include a This would need to be implemented in a co-ordinated manner that phasing policy that allows is focused upon bringing forward sites based upon their ability to both urban and greenfield create and contribute to sustainable communities. Sites would be sites on the edge of the included within the JCS housing trajectory on the basis of this and urban area to come brought forward in a manner that seekst to ensure that urban forward together at the areas are revitalised and regenerated as planned. same time

JCS Issues and Questions Consultation Page 40 The JCS could be This would not require the JCS to include a policy on phasing at all prepared without a phasing and allow the market to determine when a site shall be brought policy and allow sites to forward. It would not provide the clarity or certainty required from come forward as and the devleopment plan process. when.

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

JCS Issues and Questions Consultation Page 41 Topic Based Policy Areas

Affordable Housing

The Context

National Planning Policy

PPS1: Delivering Sustainable Development

PPS3: Housing: Sets out the everyone should have the opportunity of living in a decent home, 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 are unable to access or afford market housing as well as making the step from affordable housing into home ownership. PPS3 states that Regional Spatial Strategies should set out the regional approach to addressing affordable housing needs, including affordable housing 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 Market Area (HMA) which broadly covers the whole of Gloucestershire. Within this, Gloucester, Cheltenham and Tewkesbury Borough have been identified as a housing sub-market area that contains approximately 132,000 households. Each area within the JCS has varying issues regarding housing and provision, however, affordability has and is an increasing problem across the entire JCS area and there is demand for more affordable housing of all sizes. Both Cheltenham and Gloucester also experience high levels 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 need to be considered therefore relate to, what that target should be and the way affordable housing could be delivered. The JCS will have to, however, balance the the need to create mixed and balanced communities with the realities of economic viability of securing affordable housing through private sector developer contributions. Evidence to determine the level of affordable housing required as part of the JCS is the Gloucestershire HMA which also subject to an affordable housing viability assessment. The HMA and viability assessment are currently being updated and will inform the development of the emerging affordable housing policy. The choices set out below

JCS Issues and Questions Consultation Page 42 seek to gain your views on the potential ways the JCS could provide affordable housing.

The majority of affordable housing will be delivered as part of mixed open market development across the JCS area, although 'exception sites' may be used to provide purely affordable housing development in locations where housing would normally not be permitted. In such instances exceptions can be made due to the community benefit of the affordable housing. Most exception sites are likely to be in the rural areas of the JCS adjacent to an existing settlement or within the smaller rural settlements themselves. It is possible therefore to consider an option for delivering affordable housing through exceptions sites within the JCS.

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

Provison of Affordable Housing

To consider Outcome

1. Adopt the Draft RSS This is the draft RSS reqirement and should be the minimum sought in the requirement of 35% as JCS area. a minimum. 2. Adopt a JCS wide Higher affordable housing requirements have the potential to provide target of 40% or higher. more 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 infrastructure provision. 3. Establish different This would allow a flexible approach to providing affordable housing that percentage targets for considers the viability of bringing forward different land types. greenfield and brownfield sites. 4. Have specific targets This would allow higher provision to be provided on sites where it was for particular sites within deemed viable as part of the development plan process. the JCS area and a JCS wide target for elsewhere.

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

JCS Issues and Questions Consultation Page 43 Should all sites contribute to affordable housing or should a threshold be introduced, if so what should that threshold be?

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

Sustainability Impact

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

JCS Issues and Questions Consultation Page 44 Sustainable Buildings

The Context

• PPS1 Delivering Sustainable Development • PPS1 Climate Change Supplement • PPS25 Flood Risk • RSS RE5 Development Policy G • The Code for Sustainable Homes • Climate Change Bill

Strategic Objective:1

Key Issue: 3

The Issues facing the JCS Area

Approximately half of the carbon emissions in the UK are down to buildings. If transport between them is considered, then it is not difficult to see that development can have a significant impact upon climate change. Buildings can be designed to waste less energy and also, they can create their own energy. They can also be designed such that they are resilient to climate change in terms of increased temperatures and weather events.

For many years Building Regulations have provided a basis for standards with regard to insulation, water use etc. In an attempt to raise the bar, and increase performance across a range of sustainability measures, the Government has recently introduced the Code for Sustainable Homes. This not only looks at thermal performance but has high standards for the use of water, recycled materials and other sustainable criteria. Buildings are rated on scale of 1 to 6 where Code 1 is broadly the standard of existing Building Regulations code 6 is very sustainable and will have to be Zero Carbon.

The Code is currently being rolled out with standards expected to increase over the next 7 years. While currently Code level 3 is only compulsory for all social housing this is soon set to change as building regs are upgraded to accommodate the new standards.

Commercial buildings too will have to reach new standards. For them the existing BREEAM (Buildings Research Establishment Environmental Assessment Methodology) standard will be utilized. In terms of Energy, through Building Regulations they will be expected to be 25 more efficient by April 2010 and zero carbon by 2019.

The timetable is ambitious and it will propel the UK from a poorly performing nation in terms of sustainable construction to somewhere near the top. There is still room, however, for flexibility and it needs to be clear as to whether or not there should be

JCS Issues and Questions Consultation Page 45 negotiation regarding certain aspects of the Code. For example if in a particular area water availability is not a problem, are such tight restrictions on water usage needed?

In addition to the above, local authorities are being encouraged to adopt 'Merton style' rules where a certain percentage of the building's energy is generated through renewable or low carbon means. A floor of 10% is being set by the RSS for large scale development. Any increase from this will have to be justified (see renewable energy).

Sustainable buildings are, however, about more than the Code and BREEAM, they must contribute to a high quality of life and feeling of well-being. While some of these are part and parcel of regulations others are not. Adaptation to climate change is also increasingly important and there is an expectation that development will need to address freak weather events better, and be capable of keeping cool during more intense heat waves.

The core strategy will need to address how all these aspects of sustainability are incorporated into new buildings. It should not, however, just duplicate national policy but adapt it too meet local requirements and the local market. There is also a balance to be achieved in adopting standards between the requirement for energy efficient buildings and the need to secure other infrastructure contributions from development and ensuring that schemes remain viable.

Things to Consider Outcome

Rely on national This would result in buildings that are more energy efficient then those building standards. constructed historically. Viability is less of an issue as this requirement would be aligned to national Regulations.

Pursue local variations While leading to varying levels of sustainability it will mean that sites depending upon can come forward and be built to local sustainable needs. This may market conditions and have an impact upon scheme viability and contributions sought for other sustainable need This things such as infrastructure and affordable housing. would be on specific sites. Pursue a more rapid This would require developers to accept an increased timetable for timetable for the adoption of the Code or that certain aspects or the Code/BREEAM were adoption of standards to be accelerated. It would require that the market could deliver and across the JCS area. that it was not excessively burdening the development industry. Bring forward The code does not cover all aspects of sustainability. This could for additional example require significant measures in terms of adaptation to climate requirements not change, such as green roofs and significant tree planting. This would included within the introduce a range of other climate change adaption measures but may Code/BREEAM affect scheme viability and contributions sought for other things such as assessment relating to infrastructure and affordable homes. the buildings environments.

JCS Issues and Questions Consultation Page 46 What approach should the JCS take to creating sustainable buildings?

JCS Issues and Questions Consultation Page 47 Renewable Energy

The Context

• PPS 22: Renewable Energy • PPS 1 Climate Change Supplement • Planning Bill - the proposals for an infrastructure commission and national infrastructure policy statements • Climate Change Bill • RSS RE1 RE3 RE4 and RE5 (Draft RSS)

Strategic Objective:

Key Issue(s) being address:

The Issues facing the JCS Area:

Climate change and energy security are two of the main issues to impact upon the JCS area in the coming years. The Climate Change Bill makes clear the threats from Climate Change and the sort of response that is needed. Currently the JCS area is generally dependant upon imported largely fossil fuels to provide its energy. Not only is this unsustainable but results in significant leakage of capital out of the area impacting upon the local economy.

At present very little renewable energy is generated in the JCS area, the notable exceptions being the landfill gas sites at Hempsted and Wingmore Farm, together these provide 6.75 Mega Watts of Energy. There are smaller facilities such as the biogas at Netheridge and heat is now generated from wood chip at a number of sites with largest being the facility at the Star College Cheltenham. On the positive side many small-scale photovoltaic roofs, solar hot water, ground source heat pumps and wind turbines have now being installed promoted by generous national and local grants.

Government and Regional Policy are geared very much to encouraging renewable energy with very ambitious targets being agreed. For example the South West the target is 509 - 611 MW by 2010 of which Gloucestershire is expected to take 40 - 50 MW. Although not disaggregated by district the county is nowhere near hitting this. The 2020 target is for 850 MW. Nationally as part of a 20% EU wide target we have a legally binding target of 15% of our energy to come from renewables by 2020, a 7-fold increase in just 10 years.

The JCS does have significant renewable resources. Not only in wind but also in low head hydro (the river Severn could produce significant energy if the existing weirs were exploited) and biomass. On a smaller scale woodchip can provide heat for buildings and the use of solar hot water, photovoltaics and ground source heat pumps is becoming common place. Although the RSS requires on site renewables as part of development a more vigorous take up could be promoted.

JCS Issues and Questions Consultation Page 48 The challenge for the JCS is to facilitate the development required to achieve these much needed targets in a manner that ensures the most appropriate sites are exploited taking into account competing interests.

While the proposed Infrastructure Commission will deliberate on large-scale schemes, the vast majority of the proposals that come forward will be determined by the District Authorities (or the County in relation to some waste related development). It is important therefore that the Joint Core Strategy sets out a strategic approach for renewables to guide development in the wider public interest.

Things to Outcome consider

Seek to exceed UK This would require an open market approach to the provision of renewable and South West energy. Invariably the windiest sites are likely to be exploited. New weirs may targets by adopting have to be constructed across the Severn. Energy from waste would be a very proactive promoted. response A measured This would identify the most appropriate areas of search not only for wind but proactive approach low head hydro and potentially other renewables. This would provide certainty for developer and community alike. On its own it may not be enough.

Business as usual This essentially means a very constraining approach to renewables. The corollary of this may be planning by appeal as developers understand national policy will over-ride local objection - This could result in the most economic sites being exploited as developers will focus resources where returns are greatest.

What approach should the JCS take to renewable energy?

Sustainability Impact

The following Sustainability Objectives are of particular importance: 2 / 6

JCS Issues and Questions Consultation Page 49 Flooding

The Context

• PPS 1 Delivering Sustainable Development: • PPS 1 Climate Change Supplement: • PPS 25 Development and Flood Risk: • RSS Policy F1: • The Pitt Report • Draft Flood and Water Bill

Strategic Objective: 1 / 2

Key Issue: 3 / 11

The Issues facing the JCS Area:

June and July 2007 saw significant flooding in the JCS area. The Event of 27th July saw significant surface water flooding and small streams leaving their channels, often into homes and businesses. This was followed a few days later by the Severn over topping its defences to cause even more flooding, primarily in Tewkesbury. Events were exacerbated by stresses on critical infrastructure namely the Mythe Water works at Tewkesbury and the Electricity Substations at Castlemeads and Walham. For those that experienced the flooding first hand this is clearly the key issue facing the JCS.

Lesser floods at the turn of the 20th Century precipitated an update of national planning guidance and PPS 25 was published in 2006. This gave a clear policy direction for planning authorities and is still the basis on which flood related issues are determined today. Inappropriate development is not allowed on the flood plain, and it has to be said that the vast majority of dwellings subject to flooding were built at a time when these issues were not prevelant as today.

The challenge now is to determine exactly where flooding could occur, as it will vary depending on the type of flood, and with regard to surface water it is even harder to predict as it can be caused by the failure of a culvert or discarded mattress being in the wrong place at the wrong time.

To try and better understand which land is more vulnerable to flood a Level 1 and Level 2 Strategic Flood Risk Assessments have been commissioned. The first has been reported and on the second is awaited. These will provide more detail as to where flooding will occur. The work will also add a factor in for climate change as it is understood that weather events will be more intense as the planet slowly warms up simply putting more energy into weather systems. Sea level rise may also have an impact, as tides get higher as the oceans expand and ice sheets/glaciers melt.

With regard to surface water a Surface Water Management Plan has been commissioned. This will provide more information as to which areas are more

JCS Issues and Questions Consultation Page 50 vulnerable to surface water flooding and should help in the planning of future developments.

Once all these areas are mapped then it will be possible to apply policy with more certainty and rigour and ensure that the events of the past are minimised.

As well as mapping better the likely areas subject to flood there is a need to ensure those areas that have in past been vulnerable become less so. Occasionally this may require new defences, however, it may be better to increase capacity elsewhere or in the case of the Severn at Gloucester increase flow out into the Estuary. Development may have a role here in that it may fund managed retreat opportunities along the Severn or enable attenuation basins to be constructed upstream of problem brooks.

The final piece of the jigsaw is how development deals with its own surface water. When a field, garden or other green space is developed, surface water that would have percolated into ground water is intercepted by roofs and other hardstanding. This has to be managed so as it does not (possibly incrementally) lead to streams and sewers being over burdened. For a number of years large developments have achieved this through balancing ponds and underground storage tanks. These fill up in times of flood and drain down often mimicking green field discharge rates. There is a move locally and by government to ensure that all development deals with its own water and does as near to source as possible in a sustainable manner. This methodology called Sustainable Urban Drainage and is expected to become standard practice over the years to come.

The following outlines some of the outcomes to the questions raised.

Things to Outcome consider

Business as This carries on using PPS25 and any successor as the basis for spatial usual planning decisions where flooding is concerned. While considered to be adequate there are expectations that the Core Strategy would move beyond this

Adopt a more This could involve re-classifying the type of building appropriate within a precautionary certain flood zone. For example at the moment PPS 25 classifies shops and approach restaurants as 'Less vulnerable' and therefore potentially acceptable in the 1in100 flood zone (3a) These uses could be moved into the 'More vulnerable' category. Alternatively the flood zones could be extended by say 10 metres. This would ensure a belt and braces approach.

Sustainability Appraisal

The following Sustainability Objectives are of particular importance: 2 / 3 / 4

What approach should the JCS take to Flood Prevention?

JCS Issues and Questions Consultation Page 51 Employment

The Context

National Planning Policy

• PPS1: Delivering Sustainable Development • PPS4 (draft consultation document)

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) • Development Policy B - Development at Market and Coastal Towns • Development Policy C - Development at Small Towns and Villages • HMA 3 - Gloucester and Cheltenham HMA • RTS6 - Airports and Heliports • ES1 - Sustainable Economic Prosperity • ES2 - Providing for Employment Land and Premises • ES3 - Review of Employment Sites • TO1 - Sustainable Tourism • TO2 - Safeguarding and Investing in Tourism Destinations • TO3 - Major New Tourism Facilities • ADD1 - Priorities for Addressing Deprivation and Disadvantage

Regional Economic Strategy for the South West 2006-2015

Gloucestershire Integrated Economic Strategy 2009 - 2015

Strategic Objective 5/6/12:

Key Issue: 2, 3, 4, 6, 7, 10, 11, 13

Issues facing the JCS Area:

The economic downturn has generated considerable uncertainty in relation to the broader economic context within which the economy of the JCS area will develop over the Core Strategy period. A key question for the JCS is not merely, therefore, what kind of land and premises to provide to meet projected needs based upon past performance and current context, but what kinds of needs should be met in the future, and what economic interventions should be undertaken in order to achieve a desired 'direction of travel'?

The Integrated Economic Strategy for Gloucestershire has been recently published by Gloucestershire First on behalf of its partners. Employment priorities in the emerging

JCS Issues and Questions Consultation Page 52 delivery plans will therefore form an element of the evidence base for the emerging Joint Core Strategy.

In establishing an approach for the JCS area it is going to be necessary to balance the needs of the urban areas and those of the rural areas, where an emphasis for possible economic development may be tourism, in addition to wider economic growth objectives. Strengthening and developing the tourism sector in both rural and urban locations could be a part of the approach to the economic development of the JCS area. This is particularly important to ensure that the rural economy does not become unduly dependent upon lower paid and potentially seasonal opportunities.

A further key balance to be addressed within the JCS area is the extent to which new residents are to be encouraged into the area in order to improve its economic performance, as against the extent to which the skills of existing residents are to be developed in order to allow them to attract and take up developing employment opportunities.

Due to the complexities and number of options available, some relatively polarised scenarios are presented as 'options' below, with further options of a mixed or divergent approach.

Things to consider Outcome

The JCS endorses a centralised and The key hub of Cheltenham and Gloucester would specialised economy, with the emphasis in experience the majority of employment growth. rural areas being primarily upon services to meet local need and tourism.

Land is allocated to meet the needs of key Development of economic specialism(s) could may sectors at and adjacent to Cheltenham and be associated with the development of key Gloucester, with more limited land allocations economic 'clusters', creating a significant for employment uses in more rural areas. contribution to economic growth.

The approach risks a less dynamic rural economy, and initiatives relating to the development of land and premises would have to be coordinated with interventions such as skills development in order to ensure that local economies did not become more polarised (depending upon the specialisms in question).

JCS Issues and Questions Consultation Page 53 The JCS could endorse a continuation of a A greater proportion of economic growth is dispersed and diverse economy, including experienced in the rural areas, but potentially to the 'flexible' allocations and a greater variety of detriment of environmental sustainability objectives employment allocation in its more rural areas.

A specialist economy is endorsed, with high Existing residents may be able to derive greater emphasis upon meeting the employment needs benefit from economic growth, but if skills- of the existing population. Specialisms are development and other interventions are not chosen and allocated for on the basis of the successful then development of specialisms potential of the existing population for through inward investment may be hampered. participation, including through measures such as skill development A specialist economy is endorsed, with a high A greater degree of aggregate prosperity may be emphasis upon attracting a new population with achieved, but this approach would have to be the associated skills needed to develop the carefully coordinated with other planning policy selected specialisms. areas and interventions in order to ensure that existing residents benefited sufficiently from this prosperity.

What aproach should the JCS take to secure better economic growth?

Sustainability Appraisal

JCS Issues and Questions Consultation Page 54 City and Town Centres

The Context

National Planning Policy

• PPS1: Planning Sustaible Development • Planning and Climate Change - Supplement to Planning Policy Statement 1 • PPS3: Housing • PPS6: Planning for Town Centres • Draft PPS4: 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 • TC1: City and Town Centres • C1: Regional and Sub-regional Cultural Infrastructure • TO1: Sustainable Tourism • TO2: Safeguarding and Investing in Tourism Destinations • T3: Major New Tourism Facilities

Strategic Objectives: 3/5/6/7/10/12/13

Key Issues: 7/8/12

Issues Facing the JCS area

Gloucester and Cheltenham town centres are of regional significance, both providing for a range of town centre uses including retail, leisure and entertainment, tourism, employment and housing.

In terms of retail and leisure, the offering of the two centres has traditionally differed quite considerably. Cheltenham for example, is the South West's second most influential retail centre behind Bristol, and has a retail offer, catchment and expenditure far greater than that which would normally be expected of a town of it's size. Cheltenham attracts shopping visitors from a significant distance, and more recently 'shopping weekends' involving an overnight stay have become popular. Cheltenham is also renowned for having a very good evening and night-time economy, with a choice of restaurants and bars, and cultural facilities such as the Everyman Theatre and Town Hall.

In both retail and leisure terms, Gloucester plays a more localised role, having less retail and leisure offer than would normally be expected of a city of its size. The evening economy in Gloucester is currently rather limiting, lacking a variety of different

JCS Issues and Questions Consultation Page 55 activities and venues to cater for a cross-section of tastes and lifestyles. In terms of tourism, Gloucester attracts a significant number of day-time visitors, but struggles to attract overnight tourism visitors. This is illustrated by the fact that there is currently very little hotel accommodation in the city centre, and particurly of higher quality.

That said, the opening of Phase 1 of the Gloucester Quays Designer Outlet Centre has provided an important addition to the retail and leisure offer in the city, and is proving to be a big success in attracting visitors to the city from near and far.

Looking forward, it is important that the role of Cheltenham town centre as one of the south west's principal retail destinations in the south west is maintained. There is considerable scope to improve the retail, leisure and cultural offer in Gloucester, making the best of it's unique assets. It will also be important to ensure a complementary function is developed between the city centre and Gloucester Quays.

In both centres, the ongoing regeneration iniatives through 'Gloucester Rennaissance' and 'Civic Pride'

Choice Outcome

Regeneration Sites Only. Town Centre sites This would result in a concentrated town centre that are located within regeneration areas though it could restrict some uses from locating in (GHURC and Civic Pride) would be the centre for example through a lack of available prioritised for the development of town sites. centre uses. Expansion of Town Centres. Town Centre Town Centre sites that are located within sites that are located within regeneration regeneration areas (GHURC and Civic Pride) areas (GHURC and Civic Pride) would be would be prioritised for the development of town prioritised for the development of town centre uses, but extension(s) to the centre would centre uses, but extension(s) to the centre be identified. This could provide more flexibility would be identified. and choice within the centre.

Should town centres be expanded or should the focus be on regenerating existing town centre sites?

If you think town centres should be expanded, where do you think would be the most appropriate location?

Should the focus of the JCS be on improving retail offer, or a more diverse range of attrcations and facilities?

What should the future roles and relationship be between Gloucester City and Cheltenham?

Sustainability Impact

JCS Issues and Questions Consultation Page 56 The following Sustainability Objectives are of particular importance: 7 / 10 / 11 / 12 / 15 / 17 / 18

JCS Issues and Questions Consultation Page 57 Green Infrastructure

The Context

• PPS 1 Delivering Sustainable Development • PPS9 Biodiversity and geological conservation. • PPG17 Planning for open space, sport and recreation • RSS GI1 ENV1 ENV4 • Natural England Green Infrastructure Guidance

Strategic Objectives: 1/2/4/10/12

The Issues facing the JCS Area: 1

The landscape of the JCS area has been formed by the interaction of the rivers Severn and Avon on the underling geology, the resulting habitat types and settlement pattern reflecting these processes. The softer lias Clay typically being eroded away creating the Severn and Avon Vales with the harder and porous limestone rising up forming a steep scarp to the east of the JCS area. Dotted around the Vale are the outliers of the escarpment such as Robinswood and Chosen Hills and the smaller river terrace hillocks such as Hempsted and Lassington Hill.

Significant protection is already afforded many of the habitats and landscapes within the JCS area through a myriad of local and national designations. Planning has typically protected these assets while a more proactive approach to land use management has being delivered in somewhat random manner with perhaps the exception of the Cotswold AONB. This is actively managed through co-operation of landowners and the Cotswold Conservation Board.

There are also a number of key locations with the JCS area that have a significant influence on the wider landscape such as Cheltenham Racecourses that provides a significant national tourist attraction as well as partly defining the local landscape.

While Planning has in the past addressed the needs of physical infrastructure ensuring roads, sewers and electricity can be adequately provided for Green Infrastructure has not been planned for in a co-ordinated manner. Although local authorities are familiar with negotiating Pubic Open Space on large developments, and ensuring precious assets are protected, what has been lacking is the need to connect these up in an integrated manner and ensuring they relate to, and are part of the wider countryside.

It could be a given for example that everyone in new development is able to walk out of their dwelling and into an open green area within a couple of minutes. This green area would then connect with more probably multifunctional space and ultimately into the wider countryside. Ideally like the AONB this countryside should be subject to a management plan and be looked after for the benefit of access, wildlife and landscape.

JCS Issues and Questions Consultation Page 58 Not only will this provide a green living space for new and existing residents but should go a long way to increasing the connectivity and resilience of existing habitats especially in the light of climate change that will force species to migrate out of their current range.

A useful definition for GI is given the RSS it states that GI 'consists of strategic networks of accessible multifunctional sites (including parks woodland, informal open spaces, nature reserves and historic sites) as well as linkages (such as river corridors and greenways). These contribute to people's well-being and together comprise a coherent managed resource responsive to evolving conditions'

In the JCS area we need to look at how development can deliver its own GI as well understanding the strategic dimension. For this we are assuming that towards the East of the area the Cotswold AONB provides this strategic GI function admirably, the main challenge here is ensuring new and existing development is properly 'plugged into' it.

For the West of the area the JCS authorities are considering the idea of a Strategic Green Infrastructure asset broadly correlating with the washlands of the river Seven and the tributaries that flow into it. To give the area an identity and a feeling of permanence this could be called a Regional Park, Severn park or similar.

This would complement the work being done by the Gloucestershire Wildlife Trust in their Living Landscapes project, the Strategic Infrastructure process being undertaken by the County and other work to develop the area for Tourism and land based economic development.

Things to consider Outcome

Concentrate effort within On large developments All green infrastructure (POS allotments development SUDS etc) are negotiated in an integrated manner. Existing assets are protected and linked by SUDS features and other green links. No-one is more than a couple of minutes walk/cycle from the GI network Identify a Strategic Green Strategic Green Infrastructure is identified (AONB in the east. Infrastructure network. Severn (Regional) Park in the West). River corridors connecting Development will need to new development to these will be identified. relate to this and potentially fund improvements to it. Identify existing Green Existing Green Infrastructure (parks open spaces allotments etc. Infrastructure in urban areas. Are mapped and assessed. Pinch points and connectivity problems are identified and a schedule drawn up for improvement. Development funds improvements. Business as usual Open space is negotiated on a site-by-site basis. Areas of ecological/geological/Archaeological interest are protected and

JCS Issues and Questions Consultation Page 59 often form part of the adopted open space. Allotments, SUDS infrastructure are provided for on a fairly ad hoc basis

What approach should the JCS take to providing Green Infrastructure?

Sustainability Appraisal

The following Sustainability Objectives are of particular importance: 1 / 5 / 14 / 16

JCS Issues and Questions Consultation Page 60 Gypsy and Traveller Provision

The Context

National Planning Policy

• Planning Policy Statement 3: Housing • Circular 01/2006: Planning for Gypsy and Traveller Caravan Sites • Circular 04/2007: Planning for Travelling Showpeople

Regional Spatial Strategy for the South West - Proposed Modifications

• GT1: Gypsy and Traveller Pitch Requirements • GT2: Travelling Showpeople Pitch Requirements • Review of Additional Pitch Requirements for Gypsies and Travellers (April 2008)

Strategic Objectives: 3

Key Issues: 2/4

Issues Facing the JCS Area

National Planning Policy is clear in setting out that where there is an identified need for new Gypsy and Traveller Sites it is not acceptable to rely on criteria based policies and allocations should be made. The need for Gypsy and Traveller accommodation in Gloucestershire has been determined through the Gypsy and Traveller Accommodation Assessment (GTAA). The GTAA forms part of the technical evidence that has been used to inform the Draft RSS for the South West (Proposed Changes).

The RSS sets out the following need requirements:

Gypsies and Traveller Requirements to 2011

Gloucester Cheltenham Tewkesbury Permanent 18 27 75 Transit 5 10 10 Total 23 37 85

Travelling Showpeople Reguirements to 2011

Gloucestershire total: 26

JCS Issues and Questions Consultation Page 61 Since the publication of the RSS Proposed Changes planning permission has been granted for 17 pitches for Travelling Showpeople at Gotherington in Tewkesbury Borough. However, this is a temporary planning permission only and there is still a need to identify permanent pitches for need as set out in the RSS.

While Cheltenhams provision for sites will be provided in association with new development proposals, initial indicative locations for the provision of Gypsy and Traveller and Travelling Showpeople are suggested below.

Gypsy Families

• Oxenton - 6 pitches • Tewkesbury - 5 pitches • Elmstone Hardwick - 6 pitches • Fiddington - 9 pitches

Travelling Showpeople

• Teddington Hands - 8 pitches • Newton Farm - 6 pitches • Norton - 2 pitches

Do you consider the level of provision is appropriate within the RSS requirement for 145 pitches for Gypsy and Travellers and 26 pitches for Travelling Showpeople?

Should Gypsy and Traveller / Travelling Showpeople Sites be integrated into the sustainable urban extensions or should they be accommodated elsewhere? Where could these sites be accommodated?

In identifying locations, is it appropriate to provide a large number of smaller sites or concentrate on providing a smaller number of larger sites?

Sustainability Impact

The following Sustainability Objectives are of particular importance: 15

JCS Issues and Questions Consultation Page 62 Other Policy Areas

There are a number of other topic areas within the JCS area which have not yet been covered specifically. These include; the Historic Environment; Areas of Outstanding Natural Beauty (AONBs); Biodiversity and Habitats and; Retail. Whilst these are very important topics and clearly merit consideration, they are already covered comprehensively by national and regional planning policy and/or national legislature. It is not necessary to duplicate national or regional policy and the government is quite clear on this issue as set out in Planning Policy Statement 12 (PPS12) - Local Spatial Planning.

National and regional policy shall continue to provide the steer on these topics and will remain a material consideration in determining applications in respect of these topic areas. Below is a summary of each of these topic areas setting out what existing guidelines are in place in each case:

The Historic Environment

The historic environment is protected by national Planning Policy Guidance note (PPG15) - Planning and the Historic Environment. This covers a range of aspects from listed buildings to historic parks and gardens, historic battlefields and conservation areas for instance. In summary, this policy aims to ensure that none of these features are adversely affected by any development proposals and, where possible, are enhanced.

Areas of Outstanding Natural Beauty

Areas of Outstanding Natural Beauty (AONBs) were brought into being by the National Parks and Access to the Countryside Act of 1949. The Countryside and Rights of Way Act 2000 strengthened the conservation and management of AONBs in partnership with local authorities. Furthermore, PPS7 - Sustainable Development in Rural Areas provides the Government's stance on proposals which affect the AONB. In summary, it sets out that significant weight should be given to the preservation of AONBs in determining any proposals which might affect them.

Biodiversity and Habitats

PPS9 - Biodiversity and Geological Conservation sets out the Government's policies on protection of biodiversity and geological conservation through the planning system. This covers features such as Sites of Special Scientific Interest (SSSIs), Ancient Woodland and Other Important Natural Habitats. It gives significant protection to these features and aims to ensure that biological and geological diversity are conserved and enhanced as an integral part of social, environmental and economic development.

In summary, the main focus of the policy is to promote town centres for retail development. In respect of retail development away from town centres, PPS6 suggests that unless there is a proven need for additional retail development beyond the town centre, such proposals cannot be considered. Where there is a proven need then this

JCS Issues and Questions Consultation Page 63 can only proceed if it can be shown that it would not adversely affect the vitality and viability of the town centre.

Q22 Should any of the above topics have specific policies within the JCS?

Q23 Are there any other topics that you think should be covered by the JCS?

JCS Issues and Questions Consultation Page 64 Deliverability

The Context:

PPS1: Delivering Sustainable Development

A key consideration in the delivery of the strategy for the JCS area is the manner in which infrastructure is planned and provided. National planning policy, as set out in Planning Policy Statement 12 requires Core Strategies to identify and plan positively for the infrastructure that will support the development of their area.

The definition of infrastructure is now wide ranging and includes many of the typical physical elements such as new highways and physical linkages but also encompasses the provision of wider environmental, utility, health, social and cultural infrastructure. All of these elements of infrastructure together contribute to creating sustainable communities.

The emerging Draft RSS requires local authorities to plan positively for all types of infrastructure, particularly through Draft Policies HMA3, C1, GI1, HE1 and CS1. This consultation document considers in other sections the provision of the infrastructure requirements as set out in the Draft RSS Policies, however, within this section of it is important to gain public feedback on the manner in which the funding for infrastructure can be collected.

The Community Infrastructure Levy

At present securing developer contributions to the provision of infrastructure is principally undertaken through a negotiation process known as planning obligations. This is a process by where developer contributions are secured from each development proposal individually in the context of the impact that the development is likely to have upon existing and already planned infrastructure.

This can, however, be a lengthy process and does not assist with long term infrastructure planning. The Government therefore intends to introduce a new method of securing developer contributions to infrastructure provision called the Community Infrastructure Levy (CIL). The Government has recently consulted on how this may work and proposes to implement it in April 2010. CIL could be a single standard charge that is paid by developers for all forms of development across an authority's area for both residential and non-residential proposal. CIL, however, is unlikely to be mandatory and local authorities can choose to adopt a single levy style charge for all development through CIL or continue with the current planning obligations process.

While CIL will provide authorities the opportunity to collect funds for infrastructure, it will not fund affordable housing. This will remain a separate process secured through the existing planning obligations process.

Strategic Objective: 1/8/9

Key Issue(s) being address: 1/13/14

JCS Issues and Questions Consultation Page 65 The Issues

The three authorities of Gloucester, Tewkesbury and Cheltenham are working collaboratively with Gloucestershire County Council to plan positively for the full range of infrastructure required to support the strategy for the future development of the JCS area. This work will inform the infrastructure delivery component of the Joint Core Strategy and will assist in ensuring the strategy for the area is appropriately supported by the timely provision of necessary infrastructure.

In progressing the Joint Core Strategy the three authorities are consulting on the current manner in which developer contributions are sought and the practicalities of adopting a Community Infrastructure Levy style approach as currently envisaged by Government or retaining the existing planning obligations procedure.

This will require each of the authorities to prepare a charging schedule separate to the JCS that sets out a standard fee to be paid by those promoting development upon the grant of planning consent. This standard levy could then be used collectively to contribute to the provision of infrastructure proposals set out in the Joint Core Strategy. It is important to note, that while CIL may provide an element of funding for infrastructure, its purpose is not to fund infrastructure entirely but supplement existing infrastructure funding accordingly.

In setting a standard charge for all development, the JCS must have regard to the viability of setting such a levy on development and there may be circumstances where the charge could be lower in order to ensure that development proposals still remain viable. The Councils are therefore also consulting on whether this is appropriate or not.

Things to consider Outcomes

To continue to Infrastructure planning will remain a critical component of the JCS in order negotiate developer to demonstrate that development can be delivered in tandem with contributions for infrastructure provision. T there may be, however, less certainty as to infrastructure provision when infrastructure may be funded. There are also fewer opportunities to on a site by site basis provide strategic infrastructure in a co-ordinated manner. Adopt a standard levy Infrastructure planning may be provided in a more co-ordinated manner charge for development than the current process. It will also enable infrastructure funds to be proposals based upon provided across the authority's area and not necessarily associated with the emerging the development proposal that it is collected from. This will provide a Community greater opportunity to comprehensively plan infrastructure. Infrastructure Levy

How should the JCS ensure that sufficient funding comes forward so that development is supported by the provision of associated infrastructure?

JCS Issues and Questions Consultation Page 66 Things to consider Outcomes

A charge should be A charge that is applied at the same rate for all development across applied uniformly across the JCS area would ensure that all development contributed equally to the JCS area to ensure the provision of infrastructure. While this would assist in ensuring that all development consistency across the JCS area it may result in locations becoming contributes equally to the unviable and contributions being negotiated. This may slow down the provision of delivery of development and infrastructure along with impacting upon infrastructure. overall delivery. A charge could be An overall charge that makes an allowance for development within reduced in defined urban certain locations to pay a reduced levy where viability evidence regeneration areas illustrates that proposals will not come forward with a levy charged at where land values may 100%. This option may result in a higher overall charge for areas make development outside of regeneration areas to ensure that the cost of infrastructure proposals unviable where is met. a 100% charge is applied.

If the JCS should adopt a CIL approach are there any areas or circumstances where a reduced charge could be appropriate?

JCS Issues and Questions Consultation Page 67 Glossary of Terms

Area Action Plan (AAP): A Development Plan Document that may be used by the local planning authority to provide a planning framework for areas of change and areas of conservation. Intended to deal with specific areas and specific requirements such as the redevelopment of an area of derelict land and buildings.

Core Strategy: A Development Plan Document setting out the spatial vision and strategic objectives of the planning framework for an area, having regard to the Community Strategy.

Development Plan Document (DPD): Development Plan Documents are prepared by local planning authorities and outline the key development goals of the Local Development Framework. Development Plan Documents include the Core Strategy and, where needed, Area Action Plans. There will also be an adopted proposals map which illustrates the spatial extent of policies that must be prepared and maintained to accompany all DPDs.

Evidence Base: The information and data gathered by local authorities to justify the "soundness" of the policy approach set out in Local Development Documents, including physical, economic, and social characteristics of an area.

Examination in Public (EiP): Development Plan Documents and the Statement of Community Involvement will be subjected to independent scrutiny by way of an Examination in Public. This is essentially a public inquiry that may be dealt with in a number of ways including written representations, round table sessions, informal hearings and formal inquiry sessions (with legal representation present)

Flood Risk Assessment: An assessment of the likelihood of flooding in a particular area so that development needs and mitigation measures can be carefully considered.

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Key Diagram: The diagrammatic interpretation of the spatial strategy as set out in a local authority's Core Strategy. (As distinct from a Structure Plan Key Diagram prepared to explain its policy content).

Local Development Documents (LDD): Sit within the LDF portfolio and comprise Development Plan Documents (DPDs) that have been subject to independent testing and have the weight of development plan status and Supplementary Planning Documents (SPDs) which are not subject to independent testing and do not have development plan status.

Local Development Framework (LDF): The Local Development Framework is a constantly evolving portfolio of local development documents which will provide the local planning authority’s policies for meeting the community’s economic, environmental and social aims for the future of there area where this affects the development and use of land.

Local Development Scheme (LDS): The local planning authority's time-scaled programme for the preparation of Local Development Documents that must be agreed with government and reviewed every year.

Local Strategic Partnership (LSP): A Local Strategic Partnership (LSP) is a single non-statutory, multi-agency body, which matches local authority boundaries, and aims to bring together at a local level the different parts of the public, private, community and voluntary sectors.

Planning and Compulsory Purchase Act (2004): The Act updates elements of the 1990 Town & Country Planning Act. The Planning and Compulsory Purchase Act 2004 introduces: - a statutory system for regional planning - a new system for local planning - reforms to the development control and compulsory purchase and compensation systems - removal of crown immunity from planning controls.

Planning Policy Guidance (PPG): National Statements of Planning Policy providing guidance on a range of different topics including housing, retail, employment, transport and so on. To be replaced by Planning Policy Statements.

JCS Issues and Questions Consultation Page 69 Planning Policy Statements (PPS): Replace Planning Policy Guidance notes (PPGs). Designed to be more succinct, to separate policy guidance from practical implementation and to distinguish policy from advice.

Regional Planning Body (RPB): Responsible for the preparation of the Regional Spatial Strategy. In the case of Gloucester, the RPB is the South West Regional Assembly.

Regional Spatial Strategy (RSS): Replaced Regional Planning Guidance (RPG) and forms part of the development plan for the purpose of determining planning applications. Prepared by the Regional Planning Body. The Local Development Framework must be in general conformity with the RSS.

Statement of Community Involvement (SCI): A statement setting out how the Council will involve the community and other interested stakeholders in the preparation of the Local Development Framework.

Strategic Environmental Appraisal (SEA): A generic term used internationally to describe environmental assessment as applied to policies, plans and programmes.

Supplementary Planning Document (SPD): Local Development Document that has not been subject to independent testing and does not have the weight of development plan status. Replaces Supplementary Planning Guidance.

Supplementary Planning Guidance (SPG): Supplementary Planning Guidance may cover a range of issues, both thematic and site specific and provide further detail of policies and proposals in a development plan.

Sustainability Appraisal (SA): Sustainability appraisal is as a systematic and iterative appraisal process, incorporating the requirements of the Strategic Environmental Assessment Directive. The purpose of sustainability appraisal is to appraise the social, environmental and economic effects of the strategies and policies in a local development document from the outset of the preparation process.

Sustainable Community Strategy (SCS): Prepared by Local Strategic Partnerships as a set of goals and actions which they, in representing the residential, business, statutory and voluntary interests of a local area, wish to promote. The SCS should inform the Local Development Framework and act as an umbrella for all other strategies devised for the local area.

JCS Issues and Questions Consultation Page 70 Urban Extension: Involves the planned expansion of a city or town and can contribute to creating more sustainable patterns of development when located in the right place, with well-planned infrastructure including access to a range of facilities, and when developed at appropriate densities.

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