I have a player questioning Great Strength and whether it is implied that the 12 or less Fatigue requirements does not include Fatigue gained from Journeys.

What are people's thoughts on this in terms of their reading and overall balance? +3 Parry seems a significant benefit, but adding Fatigue from Journeys does limit the Virtue quite a bit.

I believe it includes fatigue from journeys. If they didn't want to include that, they would have said less than 12 encumbrance.

Agreed. If Journey fatigue was not included a Beorning might wander around in a buffed state constantly. As it is, with a bit of creativity, the character can instantly switch into and out of Great Strength at need.

Still, the following threads might be of further interest to you. The first two directly address Great Strength, the last is about Parry in general and mentions Great Strength.

• Great Strength (beorning) Va Missile Attacks
• Beorning Great Strength
• Parry Don't Increase With Experience?

While a search revealed a few additional threads where Great Strength is mentioned, most are passing references.