Statement on behalf of Barratt Homes and North Tewkesbury Land Consortium for SWDP Stage 1 hearing

Transcription

1 Statement on behalf of Barratt Homes and North Tewkesbury Land Consortium for SWDP Stage 1 hearing Matter 2: Duty to Co-operate - The duty to co-operate in the planning of sustainable development Main issues: Whether or not the legal requirements imposed by S33A of the Planning and Compulsory Purchase Act 2004 (as amended) have been met in the preparation of the Plan. 1. Introduction 1.1 RPS Planning & Development (RPS) represents Barratt Homes and the North Tewkesbury Land Consortium (NTLC) in respect of their land interests at Mitton, to the north of Tewkesbury. 1.2 Mitton is land identified on Plan RPS 1 (Appendix 1) which is an area of land suitable for a comprehensive urban extension to the Tewkesbury urban area in a location which is close to the town centre, employment areas and secondary school. It has a substantial development area outside, and well above, the significant constraint of the floodplain which affects much of the land around the town. 1.3 The land is in two main ownerships who are co-operating in bringing the area forward for development. RPS has prepared an Illustrative Masterplan which indicates how the land could be developed for 1,100 homes, a primary school, a local centre, local office space and business units, and very extensive green infrastructure space. The Illustrative Masterplan has been informed by technical studies and public consultation in January 2012 which can be viewed on RPS believes that, had land at Mitton not been in a cross-boundary location in Wychavon District, but rather within Tewkesbury Borough, it is very likely that the land would have been developed by now. Indeed, the existing residential area of Mitton in Tewkesbury Borough was formerly within Wychavon District. 1.5 This Duty to Co-operate (DtC) Hearing Statement demonstrates that there has been no effective co-operation between either Wychavon District Council and Tewkesbury Borough Council or, more importantly, between the South Worcestershire Development Plan (SWDP) authorities and the Gloucester, Cheltenham and Tewkesbury Joint Core Strategy (GCT-JCS) authorities in assessing the sustainability or suitability of Mitton in addressing the growth needs of the GCT authorities. 2. Matter 2(i) Is there clear evidence that, in the preparation of the Plan, the Councils have engaged constructively, actively and on an ongoing basis with neighbouring authorities and prescribed bodies on strategic matters and issues with cross-boundary impacts? 2.1 This question evidently takes its lead from the legal framework as outlined in Appendix 2. In the case of Gloucestershire cross-boundary issues, emphatically there is no clear evidence that 1

2 the Councils have engaged constructively, actively and on an on-going basis with their counter-parts at Gloucester Cheltenham and Tewkesbury (GCT). Indeed, there is more evidence to demonstrate that they have not engaged effectively, as set out in Appendices 3 and Despite this, RPS on behalf of NTLC for a period of at least 7 years has sought to foster effective cross-boundary engagement through participation in the Regional Spatial Strategies for the South West and the West Midlands Regions and through all relevant consultative stages of the local development plans for the South Worcestershire and the GCT areas. 2.3 The work that RPS has undertaken led the independent Panel into the West Midlands RSS to acknowledge the issue directly, including a clear recommendation to the Secretary of State that a direct policy reference be included in the RSS relating to cross-boundary co-operation between Wychavon District and Tewkesbury Borough to determine the most sustainable location for growth. Although this policy recommendation has not been pursued to adoption, it is a material consideration that when this matter was last independently scrutinised the importance of cross-boundary co-operation was identified as a matter meriting a specific policy reference. 2.4 Since that recommendation joint plans are being prepared for the South Worcestershire and North Gloucestershire. Accordingly, the onus on co-operation must now fall on all the joint authorities rather than just on Wychavon and Tewkesbury. On this basis and at this stage of plan making, RPS would expect to see a Memorandum of Understanding signed by all GCT and SWDP authorities, or a clear statement published that has been endorsed by all parties. This expectation is supported by the Government s advice on DtC as repeated below. No such document is in place. Where Local Plans are not being taken forward in the same broad time frame it will be important for the respective local planning authorities to enter into formal agreements, signed by their elected members, demonstrating their long term commitment to a jointly agreed strategy on cross boundary matters. Inspectors will expect to see these agreements at the examination. A key element of the examination will be to ensure that there is sufficient certainty through the agreements to ensure that an effective strategy will be in place for strategic matters when the relevant Local Plans are adopted National Planning Practice Guidance RPS has examined the South Worcestershire Authorities' Statement at Submission stage on the DtC. This attempts to address the lack of co-operation between the SWDP authorities and their counterparts for the GCT area by citing 5 meetings that have occurred, claiming to be key parts of the DtC process. It states that at all meetings it was considered that land at Mitton was not required to serve the Tewkesbury area but that a dialogue would continue over cross boundary issues. The assertion that these meetings have been effective and constructive engagement in respect of the DtC, and that all meetings concluded that land at Mitton is not required to meet the needs of GCT authorities is fundamentally incorrect, as set out in the evidence contained in Appendix 1. In examining the Preferred Option GCT-JCS, there is no DtC 2

3 Statement or evidence published by the North Gloucestershire authorities. It is a fundamental failing that two development plans can reach the stage that they have and no evidence or Memorandum of Understanding/Formal Agreement be published, despite a significant amount of precedent on this matter from other plans. 2.6 It can be seen from the record of evidence in Appendix 1, that the reference in the SWDP DtC Statement is seeking to imply that there is evidence of constructive, active and on-going cooperation that results in land at Mitton not being required, whereas in fact, it is just a list of meetings where no minutes are available and no formal SWDP / GCT position is established on Mitton. In fact the evidence is actually contrary to the position implied by the SWDP DtC Statement that no decision on Mitton has or could be reached, despite the assertion that it has. This is based upon observations made by RPS as set out in Appendix Given the above, it is clearly evident that while the SWDP DtC Statement claims that there is clear agreement between the SWDP and GCT authorities that land at Mitton is not required to meet either plan s needs, and that this has been a longstanding agreement, the evidence illustrates that the contrary is true. 2.8 There are also technical failings in this assumption in that no formal agreement on whether Mitton is required or not, could be agreed until the GCT authorities establish their own need and it is tested at examination, which they are still yet to do. 2.9 This point was clarified by Tewkesbury Council s Chief Executive on 3 September 2013 when the Council considered its Draft Preferred Option Plan. In response to a Member s question on what activities have been undertaken with neighbouring authorities, he confirmed that the authority was just at the point of establishing its own need and had just written to neighbouring authorities to start this process. This point is also contained within the Tewkesbury Borough Council covering report that states Whilst the draft Joint Core Strategy seeks to meet the needs of the JCS area, the extent of those needs and the constraints in meeting them, pose difficult challenges for the longer term and discussions with neighbouring authorities about the best way to help meet those needs will now be commenced. Two clear references that the DtC process has not been in operation effectively to date has and only just commenced If therefore as the SWDP DtC Statement sets out, that there has been a longstanding agreement that land at Mitton is not required, without first establishing the need for new homes, then this is prejudicial to the consideration of land at Mitton as the need for housing is only being presented to GCT Councils in September 2013 and the DtC process for North Gloucestershire authorities only just starting. On this basis there cannot and should not have been any prior agreement to discount the consideration of land at Mitton as claimed by the SWDP authorities DtC Statement It is therefore demonstrated that the list of meetings referred to in the SWDP DtC Statement have in fact been hastily assembled with no minutes available to give the Inspector the impression of longstanding dialogue and agreement that the need for land at Mitton is not required. This is factually and procedurally incorrect and how all this can be evidence of constructive, active and on-going engagement escapes RPS. 3

4 3. Matter 2(ii) Does the Plan taken adequate account of development requirements that cannot be wholly met in neighbouring areas, including the West Midlands conurbation and north Gloucestershire? 3.1 This response understandably focuses on north Gloucestershire. The West Midlands conurbation issues can be addressed through an early review process as also envisaged in other hinterland plan areas around the conurbation, as recently considered for example at Lichfield District's Local Plan Strategy Examination. Objectively Assessed Need for Housing in the GCT-JCS area 3.2 On 24 August 2013, through the publication of Tewkesbury Borough Council Agenda Papers, the Draft GCT-JCS as recommended by officers for the three authorities (with involvement from a steering group of elected councillors) is available. This will have been considered by all three Councils to approve for consultation, prior to the SWDP hearing sessions in early October The officers' report and Draft Plan proposes a housing requirement of 33,200 net additional dwellings for the plan period of 2011 to However, this contrasts with: the advice from the GCT-JCS's retained housing consultant that advised the Council that the objectively assessed level of housing need is 37,400 dwellings 1 ; and The Gloucestershire Local Enterprise Partnership s (LEP) Economic Growth Plan which would require the GCT-JCS area to plan for a level of growth also of 37,400 dwellings to meet its economic aspirations which is a DtC failing itself by the GCT-JCS authorities; and The requirements of paragraph 47 of the NPPF which sets out that the authorities should have an up to date SHMA, which the Gloucestershire authorities do not have. 3.3 There is therefore a clear difference of opinion between the Council, its retained specialist housing consultant, the Gloucestershire LEP and the requirements of the NPPF. There are also considerable outstanding objections to the plan and it is still at an early stage. There is therefore considerable debate to be held over the evidence of objectively assessed need and the robustness of the GCT Councils current plan. RPS contests that it is far from robust. GCT-JCS strategy 3.4 In considering the Draft GCT-JCS it is noted that currently the plan has not identified any crossboundary requirement and adopted an approach that is very heavily reliant on the release of development land from the Green Belt. Land at Mitton on the edge of Tewkesbury in Wychavon District is not in the Green Belt. 1 Paragraph 4.1, Gloucester, Cheltenham and Tewkesbury Assessment of Housing Needs Addendum

5 3.5 RPS's case on behalf of Barratt Homes and NTLC is that a further strategic site is needed at Tewkesbury to contribute appropriately towards housing delivery and that, in comparative assessments, land at Mitton has already scored highly. There are also considerable uncertainties over delivery of development at the Ashchurch MOD site, particularly in the shorter term when there is a most pressing need to boost house-building significantly. 3.6 Furthermore, there is a strong case, with the Ashchurch site's railhead, for greater use of the site for strategic employment (for which there is a substantial need and for which 14ha of greenfield land are proposed south of the A46 through Ashchurch which could be provided on suitable brownfield land within the MOD site). There are few sites with a railhead on the strategic road network, and to use a potentially surplus public asset for housing in such a context rather than seek to make the most effective use for rail-based freight would seem short-sighted. RPS understands that the camp has recently provided over 600 civilian jobs and this further supports seeking to maximise the employment potential of this land. 3.7 The proposed strategy for delivering 33,200 dwellings relies on the successful construction of over 4,800 new homes on a single urban extension at North West Cheltenham on current Green Belt land by RPS recognises that the Green Belt boundary can be considered for review in this location. However, the deliverability of this scale of development in the next 17.5 years, allowing for the planning lead period and average yield of an ambitious 250 dwellings per year over say 15 years, would yield only 3,750 dwellings in the plan period to It is acknowledged 2 that other urban extensions cannot deliver at these rates and the plan will be short by 1,092 dwellings from within the plan period. Therefore considering the shortfall of some 1,000 dwellings at this urban extension in the plan period, the GCT-JCS plan appears to be some 2,000 dwellings short of its requirement. 3.8 In total, the strategic sites identified in the Preferred Option GCT-JCS include over 11,700 dwellings on land currently in the statutory Green Belt. Under the NPPF, and long standing national Green Belt policies, there is a requirement that exceptional circumstances are identified to justify any use of Green Belt land, let alone the 292.5ha of Green Belt needed for these homes at the 40 dwellings per hectare average density sought in the emerging GCT-JCS (Draft Policy SA1(A) refers). 3.9 It is also noted that a third and late recommendation was added to the GCT authorities Council decisions in September which clarified that the distribution is still to be reviewed before Pre-Submission as the current strategy does not conform to the GCT-JCS core principle of meeting need where it arises. At present there are imbalances in this with where authorities are over or undersupplying against their need. At the Cheltenham s Council meeting (5 September) it was clarified that this may result in less development in the Green Belt around Cheltenham of some 800 dwellings to be distributed elsewhere. Under this principle the redistribution of some 800 dwellings should at first consider non-green belt sites and ensure that the distribution within Tewkesbury Borough also meets need where it arises. The focus therefore should be a greater distribution to Tewkesbury Town using the 800 dwellings acknowledged that is over provided in the Green Belt at Cheltenham. RPS would 2 GCT-JCS Draft Consultation (pre-council decision) paragraph

6 expect that given this further uncertainty in the additional GCT-JCS recommendation, the need and distribution of growth in the GCT-JCS area is still subject to cross-boundary discussion with authorities outside of the GCT-JCS area, and a full option appraisal process isrequired that will need to include Mitton. Consideration of Land at Mitton as a reasonable alternative 3.10 To meet the legal requirements of considering all reasonable alternatives, the SWDP and GCT- JCS should publically consult on site specific spatial options once they have established their respective housing need. This should include both selected and rejected sites, of which we understand that Mitton is currently in the latter category. This is so that the authorities can meet their legal responsibility to appraise and ensure that the public are aware, and can comment on the alternatives that have been considered. Cross-boundary options should be included openly in this process In this context and while it is accepted that the earlier stages of the South Worcestershire Core Strategy and Development Plan included alternative growth options which identified land at Mitton as having planning merit and potentially suitable for meeting cross-boundary needs, there is little evidence that the authorities have jointly appraised this site subsequently and equally to that of their preferred sites, and consulted on those findings as is required by recent case law. What evidence does exist indicates that it is a suitable and sustainable location RPS is aware that despite the information as set out in Appendix 2, at no point in either the GCT-JCS or SWDP has the site been presented for public consultation or jointly appraised within SA/SEA process, despite new alternatives in the Green Belt now being included. RPS has consistently made representations to the RSS, GCT-JCS and SWDP process and would have expected the site to have been jointly appraised and included within spatial options consultations and SA process. The Draft Plan being considered by GCT-JCS Councils in September is not at this time accompanied by a Sustainability Appraisal, Consultation Report as was raised by a Tewkesbury Member s concerns on 3 September 2013, nor is the site included as an option within the SWDP or GCT-JCS as a selected or rejected site, further demonstrating the lack of assessment of this site within the public realm. RPS is also aware that the site has not been subject to any detailed site assessment work on parity with the other GCT-JCS selected and rejected sites, nor has clear evidence been presented to demonstrate the decision making process for the rejection of the site. It is therefore not evident how the further in-depth assessment and consultation with the public has been undertaken at this stage by either planning process, despite earlier GCT-JCS SA evidence stating it should be considered in the Preferred Option assessment work In this context, RPS understands that the only scenario in which Tewkesbury Borough Council was willing to assess land at Mitton was through infrastructure testing as an alternative to the Ashchurch MOD site east of Tewkesbury which is proposed in conjunction with adjoining 6

7 greenfield land to the north (opposed by the SWDP authorities) for the combined delivery of 2,125 dwellings by There has never been a site specific options public consultation process within the GCT-JCS for the consideration of options and alternatives and given that the DtC Statement sets out that there has been agreement since 2009 that land at Mitton was not required, RPS believes the process has further prejudiced the consideration of land at Mitton as a realistic option. At each stage the plan making process Land at Mitton should have been considered as a reasonable alternative for accommodating development alongside Ashchurch and other strategic sites in the GCT area within both joint planning documents. Site Specific evidence 3.15 Land at Mitton, on the edge of the Tewkesbury urban area must be considered as a reasonable option in the context ofthe lack of Green Belt around Tewkesbury, the town's strong employment base around M5 Junction 9, the desirability of improving the catchment and vitality of Tewkesbury Town Centre, as part of the need to demonstrate exceptional circumstances which should include whether there are suitable alternative sites that are located outside the Green Belt. The town would not be enhanced to the same degree by development at Ashchurch east of the M5 Junction 9 which would be likely to gravitate to Tewkesbury Road, Cheltenham for town centre uses where there is extensive free parking and comparable travel times Mitton is within walking distance of the town centre and can contribute directly and appropriately to planned new infrastructure including the urban greenway proposal between Bredon Road and Newtown across the northern side of Tewkesbury town centre, which forms a key component of the Tewkesbury Town Centre Masterplan (TTCM) investment programme. The relevant extract of the TTCM is attached at Appendix Conclusion 4.1 It is demonstrated that there has been a lack of constructive engagement over the assessment of land at Mitton within both the SWDP and GCT-JCS in the context of plan preparation, spatial options, Sustainability Appraisal and public consultation and that any longstanding agreement that land at Mitton is not required is not sound or legally compliant with the plan making requirements. The reality is that the GCT-JCS authorities have never been in a position to determine their need and any assumption to the contrary prejudices the consideration of Mitton. 4.2 RPS contends that the scrutiny process of the GCT-JCS when submitted, following further consultation on the Draft Plan this autumn, will result in the need for further consideration of housing requirements, its distribution strategy and the approach to co-operation issues. The current programme for taking the GCT-JCS through its statutory stages is as in Appendix 6 with the 'Final Plan' published in March This can be addressed through a modifications process associated with the SWDP. 7

8 4.3 Accordingly, as presented in duly made objections to the SWDP, the deferred review approach to dealing with cross-boundary issues is not sufficiently flexible to deal with the genuine prospect that cross-boundary matters will need to be addressed well before the 2018 date suggested in the submitted plan footnote. 8

9 Appendix 1: RPS Site Plan 9

10 Appendix 2: Duty to Cooperate Duty to Cooperate Requirements 2.1 The DtC was inserted into the Planning and Compulsory Purchase Act 2004 (new Section 33A) under S110 of the Localism Act 2011 and relates to the planning of sustainable development. 2.2 S33A (1) states that each person who is: (a) a local planning authority, (b)., or (c), must co-operate with every other person who is within paragraph (a), (b) or (c) in maximising the effectiveness with which activities within subsection (3) are undertaken. 2.3 Subsection (3) indicates that the activities within this subsection include (a) the preparation of development plan documents, and (e) activities that support activities within any of the paragraphs (a) to (c), so far as relating to a strategic matter. 2.4 Subsection (4) defines a strategic matter for the purposes of subsection (3) as (a) sustainable development or use of land that has or would have a significant impact on at least two planning areas, including (in particular) sustainable development or use of land for or in connection with infrastructure that is strategic and has or would have a significant impact on at least two planning areas, and (b) 2.5 The definition of planning area in Subsection (5) includes (a) the area of (i) a district council (including a metropolitan district council), (ii), or (iii), (b) 2.6 The DtC obligation requires the LPA to engage, constructively, actively and on an on-going basis as required in S33A(2). The NPPF provides statements on what is required at paragraphs 178, 179 and 181 where the latter states: Co-operation should be a continuous process of engagement from initial thinking through to implementation, resulting in a final position where plans are in place to provide the land and infrastructure necessary to support current and future levels of development. Evidently, the DtC relates to co-operation and not simply consultation and co-operation, as described in the NPPF, and needs to be applied in plan preparation. 10

11 Appendix 3: Accurate record and evidence of the meetings set out the SWLP DtC Statement The following provides an accurate record and review of the meetings referred to within the SWLP DtC Statement: There are no minutes published for any of the meetings as part of the DtC Statement, or elsewhere, to substantiate this position. On this basis there is no evidence as implied; The meeting of the 7 th of June 2011 was a GCT instigated Broad Locations meeting to discuss the merits of Mitton with RPS as part of the GCT Broad Locations process. At no point was an indication given that Mitton was not required; The meeting of the 3 rd January 2012 was not a formal SWDP / GCT, meeting but a meeting between the Chief Executives of Tewkesbury and Wychavon Councils, again with no minutes available; For the meeting of the 21 st November 2012, RPS had to request the minutes of the meeting between the respective authorities. The message and 'agreed' meeting note is contained in Appendix 5. The note in RPS's view cannot be regarded as an effective minute. It is noted that the meeting was attended by one officer from Wychavon District Council, two from Tewkesbury Borough Council and the programme manager for the GCT-JCS. The fundamentally important issues of the GCT-JCS process, evidence base and growth assessment work is dealt with in one sentence and one phrase in the note "NG updated on latest JCS Council Meetings and position. Position going forward". This update does not establish that Mitton is not required; It can be seen from the record above, that the reference in the DtC Statement is seeking to imply that there is evidence of constructive, active and on-going co-operation that results in land at Mitton not being required, whereas in fact, it is just a list of meetings where no minutes are available and no formal SWDP / GCT position is established on Mitton. Meetings with both authorities had also been initiated by RPS to make the authorities aware of the site's availability and technical work that had been undertaken to demonstrate its suitability and lack of constraints. 11

12 Appendix 4: RPS Duty to Cooperate Evidence The following is a review of the evidence available to the Inspector that demonstrates that the cooperation and engagement between the SWLP and GCT-JCS is not effective and cannot be a long standing agreement as indicated in the SWLP DtC Statement: RPS are aware that Tewkesbury Borough Council were formally advised by the Government Office for the South West in that cross boundary issues at land at Mitton should be considered as part of the GCT Plan; There is a clear statement in the GCT Developing the Preferred Options Document /12 that land north of Tewkesbury Town in South Worcestershire may be required to meet the needs of the GCT authorities. It states Tewkesbury Town may need to play a larger role in this scenario and there are opportunities for additional development to the north and east of the town that are away from existing areas of flooding ; It is further noted that the SWDP authorities sought clarification on this from the GCT authorities in their formal response to the publication as set out in Appendix 5 further exemplifying the lack of engagement; The Initial Sustainability Appraisal Report accompanying the GCT Developing the Preferred Options Document 2011/12 sets out that the land at Mitton is a suitable site for development and should be included in further assessment and Sustainability Appraisal work for the Preferred Option GCT-JCS; The GCT Broad Locations Report 2011 recommended Land at Mitton as suitable for development; The site was considered suitable in the 2011 Wychavon SHLAA and only not included in the first 5 years of supply on the basis that the GCT authorities had not requested its allocation. GCT were advised by their housing consultant in 2012 that their objectively assessed housing need was between 32,500 and 43,250 dwellings and in 2013 it is confirmed as 37,400 dwellings, all of which would clearly have required cross boundary discussion to accommodate it; Despite the assertion in the SWDP DtC Statement that all meetings concluded that Mitton is not required, the GCT authorities have not been in a position until September 2013 to identify what they believe is the objectively assessed need for the GCT area, and therefore have not been able to advise SWDP authorities that land in Wychavon is, or is not, required to meet GCT need. This is confirmed in the Tewkesbury and Gloucester City Council responses to the SWDP consultation in September where Gloucester City Council clearly stated that the SWDP should remain flexible to accommodating any need arising from the GCT authorities once this was established. 3 GCT Joint Core Strategy Developing the Preferred Option (2011/12) Paragraph Tewkesbury Executive 5 September 2012, and Gloucester City Council 27 September

13 The SWDP DtC Statement incorrectly references an extract from Gloucester City Council s report rather than the formal Council s response, the actual Council response which is repeated below: Recommendations: Members are asked to agree the following recommendations: 1. That the SWDP authorities be supported in making the amendment to the supporting text to Policy SWDP2 in respect of embracing the need to consider the National Planning Policy Framework s requirement to consider unmet cross boundary requirements from adjoining authorities; and 2. That the SWDP significant changes, as proposed, be amended so that it remains flexible in the possibility of accommodating cross boundary requirements in respect of the Joint Core Strategy, until the objectively assessed development need for the JCS area and its distribution is agreed (Gloucester City Council approved recommendation to South Worcestershire Development Plan 27 September 2012). RPS is aware that the SWDP authorities sought confirmation from all neighbouring authorities that it had discharged its DtC. However, the response to this is not correctly articulated in the SWDP DtC Statement in the context of the North Gloucestershire Authorities where the response to this request was specifically made from Gloucester City to retain flexibility in the SWDP for the consideration of land to the North of Tewkesbury on the basis of the recommendation above made on the 27 September This is not reported in the SWLP DtC Statement; Furthermore, the SWDP authorities objected to 600 dwellings of the proposed Strategic Allocation in the GCT Core Strategy at Ashchurch, which has implications for meeting Tewkesbury Towns s housing need where additional sites would need to be found adjacent to Tewkesbury, possibly in Wychavon. In this context, it is noted that the Draft GCT-JCS retains the allocation to which the SWDP authorities objected to, and supposedly still do. The development around Tewkesbury Town both within Wychavon District and Tewkesbury Borough is therefore still in dispute by both plans; It was confirmed at Tewkesbury Council s meeting on 3 September by its Chief Executive, that following a meeting with between the Councils and The Planning Minister recently that the authorities had a good framework of cooperating within the GCT area but needed to extend this to authorities beyond them. In this context letters have just been sent to all authorities surrounding the JCS area to commence this process, despite the Councils considering a Preferred Option Plan. 13

14 Appendix 5 Meeting with Wychavon District Council 21 November 2012 Present: Fred Davies Nigel Gilmore Holly Jones Jonathan Dibble Wychavon District Council Tewkesbury Borough Council Tewkesbury Borough Council Joint Core Strategy 1. NG updated on latest JCS Council Meetings and position. Position going forward. 2. Malvern Hills voted last week against plan. It was only by one vote. Wychavon still want a joint plan. Have since had joint meetings. Wychavon still taking urban extension from Worcester. Malvern Hills are taking full document on 10 th December SW operates with a common Committee report. Wychavon will take a report on pre-submission doc on 18 th Decemberif Malvern Hills vote in the plan again. Wychavon are likely to get agreement. There are 9FTEs in planning policy at Wychavon. It is likely to cost a further 100k to complete the SW plan. Fred Davies due to contact Steve Carnaby from PINS shortly. Fred Davies to share PINS feedback. There are 5 Members per authority on their panel - Joint Advisory Panel (JAP). They make informal decisions. Committee reports include Comment from Panel. Administration rotates a JAP Member is elected for one year. Joint (Officer) Steering Group meet less frequently but pick up joint officer team. 3 plus County every week. If SW go it alone, there is likely to be a 3 month delay to the programme. If there is a need to go back to Preferred Options, this delay will increase to 6 9 months k in costs. Appeal decisions Wychavon also struggling with 5 year supply issues appeal decisions 14

15 Honeybourne, Lioncourt. 10% lapse rate. Sedgefield approach vs Liverpool. 20%. 6 th December 2012 Interim Preferred Option at Wychavon Developers keen to use WM Panel Report. But this was not consulted upon. Action FD Sub If SW Plan goes to programme, looking at submission to SoS Spring 2013 Adopt Nov This will also be affected by the PINS consideration of the Development Strategy. 3. Mitton/Mythe. Fred Davies explained wording of Pre-Submission version and potential hooks for Mitton/Mythe if necessary. Wychavon has been advised that they need to formalise duty to cooperate issues and will need to take something through a committee process. They intend to take something on duty to co-operate on 10 th December. 15

16 Appendix 6: GCT-JCS published timetable October 2013 November 2013 November 2013 February 2014 March 2014 April July 2014 August 2014 October 2014 November 2014 December 2014 Public consultation on Draft Joint Core Strategy Consideration of representations and preparation of Pre-Submission Document Formal consultation on soundness of Pre-Submission Document Consideration of representations and preparation of Submission Document Submission to the Secretary of State Examination Period Receipt of Inspector s Binding Report Adoption of Joint Core Strategy and publication of final document 16

17 Appendix 7: Tewkesbury Town Masterplan Extract 17

18 18

19 Appendix 8: South Worcestershire Development Plan Authorities response to the Gloucester, Cheltenham and Tewkesbury Joint Core Strategy Developing the Preferred Options consultation 2011/12. 19