Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Providing for Housing Choices Gypsies & Travellers Policy 11: Provision for the Gypsy and Traveller Community [View all comments on this section]
Comment ID DLPP304
Respondent Heine Planning (Alison Heine I… [View all comments by this respondent]
Response Date 05 Sep 2018
Current Status Accepted


Sevenoaks draft plan Policy 11 Gypsy Travellers

Sept 2018 comments-Heine Planning

I strongly support the inclusion of an allocation policy to address the long standing need to find suitable sites for Gypsy Travellers in this district. What is striking is how many of these allocated sites have temporary/ tolerated pitches. 

It is good to note that the proposal for additional socially provided pitches on Romani Way Edenbridge. Until recently Kent CC had over 100 families on its waiting list. We are not told what the waiting list is for sites in Sevenoaks-but I strongly suspect there is need for more pitches on socially run sites.

Policy is not clear whether it is addressing the needs of all GT community of just those who meet the PPTS definition. If this policy only addresses the need of those meeting the PPTS definition it is not clear how others with meeting the ethnic definition will have their cultural needs met. 

As all the district outside settlements is Green Belt, this should no longer be grounds to reject sites.

It is clear land has not been found in settlement areas and to use such land for GT sites would run counter to par 123  NPPF which stresses the need to make efficient use of land.  Caravan sites are low density development not suited to urban locations where high density is justified and should be prioritised to make best use of land in sustainable locations.

Guidance on development in the AONB has also changed recently. Para 172 NPPF now states that the scale and extent of development in designated areas should be limited. It is clearly accepting of the need for small scale development in the AONB. Most GT sites in Sevenoaks are small scale and of limited size-especially the small private sites.  They can be assimilated into the AONB where there is already a dispersed settlement pattern and need to provide for a balanced mix of accommodation needs.

With regards the criteria listed for site selection:

(a)I consider it wholly unreasonable to expect sites outside settlements to have access to public transport. On this basis many of the sites selected would fail. 

(c) I do not consider the need for safe and convenient pedestrian and cycle access should be a determining factor in site selection-but in any event as a planning consultant making GT applications I would not know what is expected. It would be wholly unreasonable to expect sites in many rural areas to be connected with pavements or have cycle lanes to their entrance. I can not recall seeing any cycle provision in Sevenoaks-certainly in rural areas.  Most GT sites are in the countryside off country lanes with no pavements or street lighting. I find this a very unhelpful and unrealistic criteria which will only be relied on by third parties to thwart applications.

Policy should seek to protect existing sites.

Policy needs to make provision for transit sites/ pitches.

With regards to the choice of allocated sites a total of 50 additional pitches are proposed on 14 existing sites. It makes good sense to regularise existing sites and make more efficient use of existing sites where provision exists. Many families have lived with the uncertainty of temporary consents for too long. I strongly support the inclusion of all these sites. BUT

i) Policy fails to allocate sufficient pitches to meet the need identified. The 2017 GTAA identified a 5 year need for 61 pitches (excluding turnover). If turnover on Council sites is included the need is reduced by 3 pitches per year or by 15 pitches over the first 5 years. But this is based on turnover data for just the last 3 years (see para 7.22 GTAA) which is not a very reliable indicator. Given that Kent CC has changed its allocation procedure for socially rented sites and was proposing to increase rent on the socially provided sites (which is already very high and a deterrent to those who are not in receipt of housing benefit ie still travelling for work) it seems very risky to assume such a high turnover rate. Given that the 2017 need assessment identified an immediate need for 61 pitches made up of an immediate need for 37 households on unauthorised/ temporary sites and emerging households (34) to be offset by 6 vacant pitches, I consider that the allocation of 50 pitches (on existing sites) will fail to address the immediate need both numerically and source. The need assessment assumes that13 pitches will be lost to those moving to bricks and mortar and to outside the district (lines 3c and 3d)-which may never happen if there is no suitable accommodation. There is no allowance for in migration so it is unclear why outmigration is factored in. Given the historic failure to allocate sites in this District and difficulty of securing permission for windfall sites, I think there should be a requirement to allocate more pitches than identified need and to include an element for in-migration. There is clear evidence from appeals/ applications that many families have moved to Sevenoaks. There is much demand for pitches in Kent from overcrowded sites/ housed Travellers in Greater London.

ii)I very much doubt some sites are large enough for the number of pitches indicated eg Alexis Place, Knatts Valley and Seven Acre Farm

iii) Appendix 3 indicates that some sites are to be included in the plan subject to additional information (sites edged yellow) yet for some of these sites we are not told what that additional information is. Other sites (eg GT2, GT12 and GT17 ) are included subject to issues with Ancient Woodland, landfill and noise/ air pollution. It is unclear why sites are included whilst there is uncertainty of this nature pending. If the Council is not convinced of their suitability they should not be listed. GT2, GT12 and GT17 are relied on for 13 additional pitches. The number of pitches edged yellow are relied on to provide for some 27 pitches. There would appear to be an awful lot of uncertainty still with the proposed allocations.

iv) There is no new site provision for those who do not own any of these private sites.  The 2017 GTAA identifies 37 pitches on temporary or unauthorised sites which is almost as many as there are private authorised pitches. Looking at Table 4.5 of the GTAA there are 12 unauthorised sites though one sites appears to be listed twice (Hill Top Farm). Several of these sites are not included in Policy 11 (eg Pedham Stables. Fountain Farm, Hogarden, Malt House Farm). The allocations in Policy 11 would be suitable for those who are already settled on their own sites and will help address need from household formation. But it can not be assumed that existing sites can not be relied on to address the needs of other families on other unauthorised sites, who are unlikely to be offered pitches on private family sites and are unlikely to want to share sites with other families to whom they may not be related. Nor can existing sites be assumed to meet the needs of those who may have been displaced from Sevenoaks in the past and want to return. Additional sites are needed for families still on unauthorised sites (eg the site at the Junction of Redmans Lane and Firminger Rd, Well Hill where in 2014 Eric Pickles acted unlawfully and overturned a recommendation of the Planning Inspectorate to grant consent). New sites are also need for families  forced to leave the district due to lack of site provision in Sevenoaks (eg Harber family in West Kingsdown). I do not understand why the site Fountains Farm, Redmans Ln Well Hill is not included when St George's Stables is. 

v) There is no transit provision.  Given the emphasis on the need to travel in the PPTS planning definition all local authorities with GT populations should be making some transit provision,

Proposed Changes

  1. The criteria for Policy 11 should be more realistic
  2. The additional information required for sites edged yellow in Appendix 3 needs to be provided to inform site selection
  3. Policy needs to make clear what need is being addressed ie PPTS or cultural or both.
  4. There is a need to provide greater choice of sites and not just rely on existing private sites over which the Council has no control over allocations and which may not be available to those on other unallocated unauthorised sites.
  5. The proposed allocations need to ensure immediate need is addressed with a buffer for

    -historic failure

    -because the GTAA relies on housing and other sites being found for families that may never materialise

    -neighbouring authorities have confirmed that they are unable to accommodate need arising in Sevenoaks (which is hardly surprising as I know of no Authority ever willing to accommodate GT need arising elsewhere)

    -because several sites are allocated subject to the need for additional information/ investigations which may demonstrate they are not suitable or additional information the details of which we are not told.

    -there is a need to provide more sites to meet identified need

    6.The Council are asked to justify how they think some sites are large enough for the allocations shown and what exactly they consider a pitch is as I fail to see how Knatts Valley caravan site has room for 11 pitches each with a mobile home, touring caravan, utility building and parking for 2 vehicles.