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 DLPP832
Respondent Graham Simpkin Planning (Graha… [View all comments by this respondent]
Response Date 07 Sep 2018
Current Status Accepted

Comments on behalf of Mr and Mrs Whitehead

In this representation Graham Simpkin Planning will refer to:

Policy 11: Provision for the Gypsy and Traveller Community


GT7: Merry Lees, Billet Hill, Ash

This site has been proposed for consultation in the draft Local Plan to provide 2 permanent Gypsy and

traveller pitches. GSP objects to the inclusion of Merry Lees, Billet Hill as a Gypsy and Traveller site in

the local plan


1. It is noted that the Council is expected to make provision for Gypsy & Traveller Sites. The GTAA

has identified a needs range of at least 11 pitches (based on the PPTS definition of need) to 51 (based

on a cultural definition of need) over the Plan Period.

2. It is acknowledged that it is difficult to find suitable sites for this purpose and most Council¡¯s

adopt an approach of adding pitches to existing established sites.

3. There are 2 issues arising from this general approach that need to be addressed:

1. That the site to be expanded is in a suitable location (bearing in mind that many sites

have been brought forward on a speculative/piecemeal basis) rather than through any

plan led system.

2. That there should not be a disproportionate amount of such pitches in particular parts

of the District.

4. In the context of the above criteria it is noted that there are already 34 traveller pitches within

the Parish of Ash-cum-Ridley concentrated at Barnfield Park. This site was established by

Kent County Council and Sevenoaks District Council to overcome problems arising from the

original unauthorised Swan Farm site. It is now a properly regulated site with a good quality

access from the public highway.

5. This represents a large concentration of provision of pitches in Ash and it is considered that

any over concentration of pitches can give rise to particular problems with the provision of

services such as schools, medical facilities etc., that have difficulty in coping with the

particular needs of this sector of the population.

6. It is therefore considered that the provision of additional pitches should be spread over those

parts of the District that do not have such large concentrations at present.

7. In respect of the identification of site GT7 where the documents states there is one temporary

pitch, this is subject of an on-going enforcement investigation because the site is not being

used in the manner described in the application. The permission granted is limited to

occupation by the Applicant and his family and this has not been complied with since the

permission was granted in July 2017. The permission is also subject to a temporary 3 year

permission unless it ceases to be occupied by the Applicant and his family. In this case, the

site has not been occupied by them for a period of over a year and therefore it is considered

that the permission should cease as a result of non-use as contemplated by the condition. The

Applicant has not secured approval for the drainage and refuse strategy as required by

condition and therefore this condition is currently being breached.

8. It is anticipated that enforcement action will bring this permission to an end.

9. In the absence of an operational permission this site should not be regarded as an existing

Temporary Pitch site as referred to in Policy 11. It should properly be considered as a vacant

Green Belt site.

10. In considering the suitability of the site at GT7, it is apparent that Officer¡¯s have not properly

evaluated the suitability of the site for this purpose. The following considerations demonstrate

its unsuitability:

a) The land rises steeply up from Billet Hill and then there is a small plateau before it

rises steeply up to the rear boundary. There are well established trees on the site

boundaries. It would be necessary to undertake extensive engineering works to

provide a level surface to accommodate 2 homes, space for a day room, space to

accommodate touring caravans and associated parking. This will be costly to provide,

would involve removal of spoil from the site, require extensive retaining structures

and result in the loss of tree cover. The site is therefore physically unsuitable for this


b) The access is aligned at an acute angle to Billet Hill, leading to difficulties with

providing visibility for drivers emerging from the site. The road has a restricted width

that makes it difficult for vehicles to turn west out of the access and for them to

approach the access from the west. The driveway is steep and narrow. It would be

difficult if not impossible to provide access for a modern mobile home to this site.

c) The location of the site is onto a road without footways or street lighting. This type

of use should be located on the edge of a settlement linked by roads with footways to

local facilities.

11. It is not therefore considered that this is a suitable site for this purpose.

12. It is considered that if there is a need for additional Gypsy and Traveller pitches within part of

the District then they should be located as an extension to Barnfield Park where they can share

the facilities already established on that site