I should like to make the following comments about the Joint Core Strategy and should be obliged if this letter could be accepted as my submission.

To start with, I am concerned by the Joint Core Strategy approach and would have preferred each of the councils to draw up their own Core Strategies, as they are entitled to do. The reason for this concern is that Tewkesbury has issues which limit the opportunities for house building which the other councils do not have to the same extent, namely a large Green Belt area and much land which should be considered to be flood risk.

It also seems strange to me that three councils in Gloucestershire are developing a Joint Core Strategy whereas three others are going it alone. There is a requirement for councils to draw up their plans in consultation with bordering councils but I question the extent to which Cotswold, Stroud and the Forest have actually done this.

It appears to me that Tewkesbury Borough (under some of the Scenarios) is proposing to accept thousands of houses which would ordinarily be accommodated in Cheltenham and Gloucester. This is unacceptable for the reason I give above (i.e. Green Belt and flood risk restrictions) but also because it is reasonable to expect Cotswold, Stroud and the Forest to accept their share of houses which might otherwise be situated in Cheltenham and Gloucester. I question the extent to which this has happened because of the separate approaches being taken.

Turning to the proposals themselves, I am concerned that the four Scenarios provide for 16,200, 33,200, 36,850 and 40,500 houses. The question I would ask is why is there no fifth Scenario proposing, say, 24,000 houses? In other words, the jump in housing numbers from Scenario A to B is too large. What I feel will be the case is that many people will support Scenario A (for reasons I’ll come on to) and the councils will simply rule that option out because (in your view) it doesn’t provide for a sufficient number of houses – a sort of self-fulfilling prophecy.

Turning to the projected housing figures, I would dispute the claim that the area will need the number of houses suggested in B, C and D over the next twenty years. The figures quoted actually exceed those proposed by the defunct Regional Spatial Strategy and must be questionable for this reason alone, especially given the economic growth assumptions made during that process. Growth in our economy is likely to be very slow over the next year or two to start with and making assumptions beyond that time is very difficult. There are hundreds of thousands of houses up and down the country (including in this area) which have planning permission and are not yet built.

I would therefore have suggested that the Local Plan you are developing should prepare for the next fifteen and not the next twenty years, as predicting so far ahead is fraught with difficulties. However, I would question the reasoning behind assuming that there will be even more single person households in the future and that these figures will continue to grow. We will probably continue to live longer into the future, though the rate of increase will be slow, but it is doubtful that the divorce rate will grow. Any anyway, many people now cohabit whereas they once did not. Economic migration will depend on economic growth and extra housing requirements in this respect will only come about because of such growth in the number of jobs.

I also object to some of the sites which you are identifying as possible building land. You are proposing to build thousands of houses on land which is Green Belt or flood risk area and sometimes both. This is unacceptable and is contrary to government policy. The government has clearly stated that it wishes to protect the Green Belt and that building should not take place in flood risk areas or, crucially, in areas which, if built on, could cause flooding to occur elsewhere.

It has been claimed by the councils that they must present a “sound” plan to the Inspector or it will be dismissed. The question is what constitutes “sound”. In front of many of your councillors and officers, I recently asked the architect of much of the Localism Bill and the new planning proposals, John Howell MP, if the planned housing numbers which have been calculated through supposed evidence are reduced because of the presence of Green Belt and flood risk, would this constitute a sound plan and he unequivocally said yes it would. I therefore see no need for building to take place in Green Belt or flood risk areas.

In the government’s draft planning guidelines the crucial word is “sustainable”. There is indeed a need to provide affordable homes but everyone would agree that these have to be built in the right places or else further problems will arise in future. This is what is meant by sustainability - providing for present needs without worsening the lives of future generations. I understand that there has been a partial flood risk assessment carried out but I am not convinced by its findings. From 20th July 2007 very many people in this area saw their homes flooded, had their possessions destroyed and were forced to live in caravans for over a year. I am also concerned by the apparent ease which the JCS team are prepared to dispense with much of the Green Belt. Neither of these moves could be considered to be sustainable and should therefore not be made.

I should also like to express my concerns about the organisation of this consultation. This initial consultation is confusing and even some local councillors do not actually understand what it is about. The Questionnaire which you invite people to complete is too simplistic and leading. The consultation has been carried out over the Christmas period which has, in effect, reduced the time available to people to comment. Also, the availability of the details has been restricted; for example, your own offices stopped displaying the proposals on 16th January when the consultation period does not end until 12th February.

I am also concerned about how genuine or otherwise the consultation will be. Very many people are strongly against proposals B, C and D and are therefore, perhaps by default, supporting Scenario A as being the one to take forward. Indeed, many of your councillors take this view. It will therefore be interesting to see which Scenario emerges as your favoured option; if B, C or D is put out for further consultation I will look forward to hearing the explanation behind this decision and will seek a summary of the responses you have received.

Finally, I am also concerned about the fact that the JCS proposals have been developed by a very few people – I understand two councillors from each council – while the vast majority of the councillors were not involved in the process. This could hardly be described as democratic.

In summary:

I support Scenario A, with the provision that these housing numbers can, if necessary, be increased over the next two decades.

The JCS approach is the wrong one. Tewkesbury should have produced its own Core Strategy. The Borough should not be accepting houses which ordinarily should be allocated to Cheltenham and Gloucester.

The projections included in B, C and D are far too high and the proposals associated with them are unsustainable.

Green Belt and flood risk land should not be built on.


I hope this is helpful