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Posted 21/02/2012


9th February 2012 Dear Ms Crews, Joint Core Strategy We are writing to you in response to your recent presentation to the Chamber of Commerce and your invitation to comment on the Draft Proposals of the Joint Core Strategy. We also appreciate our recent meeting which has greatly helped to explain a number of issues which, from our point of view, needed clarification. We would start by supporting the approach of the three authorities in working together to prepare their proposals but we do regret that the other regions within the County are not working to the same time scale which would allow us to view the proposals for the County as a whole. It makes it difficult to see if there is an even distribution of development throughout the County.

Our major area of concern is the relationship between the proposed housing numbers and the allocation of employment sites. In our opinion it is vital for the strategy to view the two together and not allow the Strategy to be housing led which we understand is also the view of the house builders. It is for this reason that we do not support Scenario A which allows for existing planning permissions and allocations for housing development and makes no provision for any employment land which is urgently needed. We therefore agree with Paragraph 3.16 in the Draft Strategy.

This Paragraph states that: "The borough has an ageing stock of employment sites and in recent times companies have relocated away from the area. This could be addressed through the provision of high quality, modern premises both in the town centre and in the form of a number of appropriate scale Business Parks elsewhere in the borough in order to retain and attract investment, thereby supporting the economic resilience of Cheltenham and the wider JCS area."

However Scenario A does nothing to support this objective. It does not even make a sufficient employment land provision for the retention and expansion of existing businesses. The area of land suggested in Scenario B between the A40 and the B4063, and the area between Elmbridge Court and the railway line are both welcome but are required now to cope with existing demands. It is therefore Scenarios B, C and D which provide a more sustainable proposal as they do take into account the need to try and balance housing with job creation. However we would still question whether the amount of employment sites in the Draft Strategy are sufficient to provide "appropriate scale Business Parks" for the level of employment required to meet the proposed level of housing.

The most logical area for a future Business Park would be at Junction 10 of the M5 - but only if the Junction is up graded to a four way junction. We consider that without this improvement there is little or no chance of attracting inward investment. No successful Company is going to accept a transport route South through Princess Elizabeth Way and Coronation Square and furthermore, an increase in traffic should not be inflicted on the residents of those areas. Once the junction upgrade is complete, and only then, can this area be considered as a suitable location for a Business Park capable of providing a substantial portion of the employment needs caused by an increase in housing numbers.

This area to the West of Cheltenham is also the most logical location for the proposed quantity of new housing. There will be employment opportunities in the newly created Business Park and excellent access to other employment areas both North and South via the M5. The allocation of 1,300 houses to South West Cheltenham should be included in the West development rather than close to the A46 which is not a good route and is already congested.

Our proposal does not impact on the greenbelt between Cheltenham and Gloucester, or on Cheltenham and Bishops Cleeve which we consider should remain intact as far as possible, nor does it impact on some of the more sensitive areas to the South of the Town. Our principal concern is that creating housing without the necessary employment opportunities will make Cheltenham even more of a commuter town, serving the rest of the region and beyond. Cheltenham is an extremely attractive town and it is no surprise that people want to live here, but it is not sustainable without the appropriate level of employment to support it.

Currently the JCS proposals do not achieve this. We are keen to continue to be involved in the consultation process over future months and hope to be able to encourage other interested parties to work with the Chamber to produce a co-ordinated response to the evolving Strategy. Yours sincerely, Robert Duncan F.R.I.C.S Planning Adviser Cheltenham Chamber of Commerce

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