Gypsy and Traveller Plan Site Options

Gypsy and Traveller Plan Site Options May 2014

6. Site Assessment Criteria

6.1. This section sets out the approach taken to considering how the unmet needs of the District could be met, whilst ensuring appropriate consideration is given to constraints impacting upon the District.

6.2. The search for potential sites has looked at a number of sources:

  • Proposed Allocations - as put forward in the Allocations and Development Management Plan
  • Existing temporary sites
  • Increasing capacity within existing permanent sites
  • Extending existing public sites
  • Suggested sites identified in the "call for site" exercise, and
  • Currently unauthorised sites

6.3. It is proposed that potential sites should be assessed using a criteria-based approach in order to determine the suitability of each site. These criteria take into consideration national and local policy as set out in the NPPF, the national Planning Policy for Traveller Sites (PPTS), the CLG Designing Gypsy and Traveller Sites Good Practice Guide 2008 and the Core Strategy 2011. They also reflect a range of environmental, economic and social factors.

6.4. Gypsy and Traveller needs for accommodation are invariably different to that of the settled community, but the consideration of location should be similar in many ways, and have regard to the potential health, welfare and social impacts that may be caused as a result of the location.

Assessment Criteria

6.5. It is the Council's preference that potential sites meet all the below criteria. However, due to the previously mentioned planning and landscape constraints across the District, it may not be possible for all criteria to be satisfied. It may be necessary to prioritise some criteria over others to ensure that the most suitable sites are put forward as potential options to meet the requirements. Therefore, a site will not necessarily be ruled out if it fails to meet one of the criteria if sufficient justification can be put forward to satisfy other criteria considerations. In addition to being suitable in accordance with the criteria in Policy SP6, sites also need to available and achievable. 

Criteria

Location & Key Constraints

a. The site is not located in the Green Belt

b. The site is not located within an area at high risk of flooding, including functional floodplains.

c. The site should be located within or close to existing settlements with a range of services and facilities and access to public transport.  This is specifically related to access to appropriate health services and ensuring that children can attend school on a regular basis and reducing the need for long-distance travelling. It should avoid placing undue pressure on local infrastructure and services.

d. The site will provide an acceptable living environment for future occupants in terms of noise, air quality and privacy and is relatively flat

e. The development will have no significant adverse impact upon the landscape, biodiversity or heritage asset. In the AONBs, sites should only be allocated where it can be demonstrated that the objectives of the designation will not be compromised.

f. Alternative priority land uses do no exist

Impact and Design

g. Responds to local character and reflects the identity of the local surroundings and will support peaceful and integrated co existence with the local community.

h. The site would or is capable, with mitigation, of securing good standards of amenity for existing residents.

i. The site is of a scale appropriate to accommodate the facilities required. In accordance with national policy (PPTS Policy F), wherever possible, Local Planning Authorities should include traveller sites suitable for mixed residential and business uses, having regard to the safety and amenity of the occupants. The sites should be able to accommodate a large mobile touring caravan, parking for 2 vehicles, utility building small garden area per household - 500 square metres.

j. Safe and convenient vehicular and pedestrian access can be provided to the site

Deliverability

k. The site is deliverable. The ease of acquisition is considered along with indicative costing of bringing the sites forward for development.

Considerations for the deliverability of the site will include:

  • Whether or not the site is currently allocated for an alternative land use
  • The ownership - private (non-gypsy/gypsy) or public
  • Anticipated delivery costs

Consultation Questions - Criteria

Q6 Do you consider these to be an appropriate set of criteria to determine the suitability?

Q7 Do you feel any other criteria should be considered?

Q8 How do you consider that these criteria should be weighted?

 

Green Belt

6.6. The Metropolitan Green Belt covers 93% of Sevenoaks District. Core Strategy Policy SP6 'Provision for Gypsies and Travellers and Travelling Showpeople' states that "alternatives should be explored before Green Belt locations are considered". This therefore presents a large constraint to meeting the identified need.

6.7. National policy dictates that Gypsy and Traveller pitches are inappropriate development within the Green Belt. However, as with other forms of inappropriate development in the Green Belt, if very special circumstances exist then development may be acceptable. The lack of suitable sites outside of Green Belt land to meet identified needs could contribute to the justification of very special circumstances. All the existing sites in the District are in the Green Belt. It is therefore reasonable to explore Green Belt land if all other alternatives have been fully explored and exhausted before such sites are considered.

6.8. Previously the Council have lost appeal decisions due to the weight Planning Inspectors have given to the issue of identified need that has not been met. National Planning Policy (PPTS para.27) makes it clear that opportunities can arise for the granting of permanent pitches if an up-to-date five year supply of deliverable sites can not be demonstrated. Planning Policy for Traveller Sites also suggests that exceptional limited alterations to the Green Belt might need to be made through the plan-making process and allocated for a Gypsy and Traveller sites. However, the Council will consider the circumstances of each site option to determine where this may be an appropriate approach. The Council will seek to maintain the extent of the Green Belt wherever possible.

Areas of Outstanding Natural Beauty

6.9. Great weight should be given to conserving and enhancing landscape and scenic beauty in Areas of Outstanding Natural Beauty (AONBs). Gypsy and Traveller sites are not precluded from being located within Areas of Outstanding Natural Beauty. However, in order to comply with policy on AONBs, a site must not have an adverse impact on landscape and scenic beauty. In some circumstances it will be possible to overcome an impact through screening that is consistent with the local character. However, in other circumstances sites will be so visible in the landscape that no amount of mitigation will be able to overcome the impact. As the most suitable sites are selected going forward in subsequent stages of the Gypsy and Traveller Plan preparation, any design and layout guidance will need to consider how any impacts can be suitably mitigated, if possible.

 

Access to Services and Impact on Infrastructure

6.10. In terms of sustainability, sites for Gypsy and Traveller pitches would ideally be located within or close to existing settlements with a range of services (i.e. those defined as service villages or higher in the Settlement Hierarchy). The distribution of new Gypsy and Traveller pitches throughout the district should be considered. Concentrations in particular parts of the district could put a strain on infrastructure and public services and it would not be reasonable to further exacerbate any problems.

6.11. All sites have been assessed for their relative accessibility to key services, such as GP surgery, local shop, primary school and bus service, and their relative remoteness from such services. This is primarily because there are no agreed distance thresholds contained within national or local policy which can be used to reject sites purely on these grounds. Local authorities are also advised in the relevant circulars to be realistic about the availability of alternatives to the car in accessing local services.

Identifying Suitable Sites

6.12. In order to meet the identified need for a further 71 pitches to 2026 (accounting for the 1 pitch already delivered since 2012), the Council needs to identify suitable and deliverable sites to underpin this supply. The potential categories of sites are outlined in Table 2 below. These should be viewed as a series of interrelated options, as it is likely that a number of these approaches will be needed to meet the identified need.

6.13. The consultation presents an initial assessment of the site options proposed to the Council and identified by it. Inclusion in this document does not necessarily mean that a site will be taken forward as the plan progresses to examination and adoption. The Council will positively consider any proposed alternatives to the sites in this consultation document.

Table 2: Potential Categories of Sites

Potential Sources of Sites

Points of Consideration

Extensions to existing public authorised sites.

The existing public authorised sites in the District will require assessment in terms of the potential for expansion on to adjacent land, or through redevelopment or intensification within existing boundaries. The national good practice guidance 'Designing Gypsy and Traveller Sites' (2008) suggests in paragraph 4.7 that a maximum of 15 pitches for a site is conducive to providing a comfortable environment and this will be a consideration in determining the Council's final proposals. Sites should not have an adverse impact on the development of the remainder of the site or on the amenity of neighbouring land uses.

Examining whether existing temporary sites are suitable to be made permanent.

All of the sites are privately owned and it will be up to occupiers on the sites and/or landowners to submit planning applications. All applications will be assessed against their conformity with the Core Strategy and Local Plan policies as well as any applicable site specific criteria.

Examining additional capacity on existing, private sites

The national good practice guidance 'Designing Gypsy and Traveller Sites' (2008) suggests in paragraph 4.7 that a maximum of 15 pitches for a site is conducive to providing a comfortable environment and this will be a consideration in determining the Council's final proposals.

Use of part of the sites allocated in the ADMP

The viability of including this land use at this site will need to be considered. The national good practice guidance 'Designing Gypsy and Traveller Sites' (2008) suggests in paragraph 4.7 that a maximum of 15 pitches for a site is conducive to providing a comfortable environment. Sites should not have an adverse impact on the development of the remainder of the site or on the amenity of neighbouring land uses.

Examining whether unauthorised sites are suitable in planning terms to be allocated and made permanent for this land use.

Consideration will need to be given to the reasons why any unauthorised sites may not have been granted planning permission.

Granting permanent permission for these sites could be seen as circumventing the planning process.

Allocating new sites that have come forward through the Call for Sites process.

Any new sites will need to be assessed against the criteria set out in section 4. The national good practice guidance 'Designing Gypsy and Traveller Sites' (2008) suggests in paragraph 4.7 that a maximum of 15 pitches for a site is conducive to providing a comfortable environment.

6.14. The Government recognises that whilst more private traveller site provision should be promoted, it is likely that there will always be those Travellers who cannot provide their own sites. Therefore, by utilising a range of site types to meet the identified need, a range of tenures can be provided for.

Consultation Questions - Approach to Meeting Pitch Requirements

Q9 Do you consider the approach to the way in which our future pitch provision may be met is appropriate?

Q10 Are there any alternative ways in which the pitch requirements can be met?