Core Strategy - Consultation Draft

Comment ID 2529537/CSCD/1
Document Section Core Strategy - Consultation Draft Chapter 3: Spatial Policies Delivering Strong and Inclusive Communities CS18: Gypsies and Travellers and Travelling Showpeople CS18: Gypsies and Travellers and Travelling Showpeople View all on this section
Respondent Deleted User View all by this respondent
Response Date 01 Feb 2010
We have concerns that policy CS18 restricts itself to a commitment only to make provision identified to 2011. The RSS panel report stated:
"Overall Provision post 2011, recommendation 5 - The figures to 2011 are binding and that a 3% compound growth rate be applied after 2011 to give a basis for DPD allocations."
Hence in our view the policy should give a commitment to meeting needs post 2011 and to make allocations on the basis of a 3% compound growth rate whilst committing itself to take on board evidence coming forward from a new GTAA if and when it is produced. Unless this is done the core strategy will be internally inconsistent and will not be consistent with regional policy. The proposed growth rate does form the basis for estimating anticipated needs in the medium and longer term and should be used as such.
The issue is pressing and Central Government has found that progress in unsatisfactory countrywide. The Communities and Local Government Department Progress Report on Gypsy and Traveller Policy (July 2009) stated that:
The current position on site delivery remains unsatisfactory. It is clear that local authorities need to increase the pace at which suitable locations are identified that can be used as Gypsy and Traveller sites. Although the Government recognises the difficulties that can arise, it considers that with strong leadership at the local level, authorities can make rapid progress in addressing what is, in numerical and land-use terms, a relatively small level of need. The identification of suitable locations for authorised sites will help to reduce the number of unauthorised developments and encampments can create tensions between Gypsies and Travellers and the settled population.
Given the urgency of the need can urban extensions be relied upon to provide the necessary land for sites in a reasonable timeframe?
The policy should make clear that very special circumstances mentioned include the inability to find suitable sites outside of Green Belt.
We have some concerns about reliance on expansion of existing sites - while this may be appropriate in some circumstances, for example expansion of small private sites to accommodate growing families and new family formation we do have concerns about local authority sites in particular becoming too large. Consequent management problems may result. We would warn against seeing site expansion as being an easy win in what will be a difficult business of finding suitable new sites. The council should ensure that communication with local Gpysies and Travellers is direct and accessible so that they can give their advice on these matters.
The policy effectively lists a search sequence for sites and does not include green field locations. Circular 1/2006 is clear that rural and semi-rural locations are acceptable in principle and the policy does not relect this.
The policy lists criteria most of which are acceptable but we have concerns about the potential effect of some.
1. Whilst not gainsaying the importance of being within reasonable reach of local services this criterion could mean that otherwise suitable sites may be excluded from consideration. Circular 1/2006 recognises that rural and semi-rural sites are acceptable in principle and that local authorities should be realistic about alternatives to the car in accessing services. This criterion may be better worded by replacing 'well' by 'reasonably' and 'local services .... welfare facilities' by 'a range of services' to build in a reasonable degree of flexibility to site selection and identification.
2. This if strictly followed, would mean that all sites have to be screened whether or not it is required. This is overly onerous and should only be required if needed. The criterion should either be deleted or amended. It is the sort of issue which is best catered for as a planning condition if necessary.
3. This sort of criteria does in our view open the door to NIMBYist objections which could be sustained if this creterion is retained. If a criterion about this issue is required then it could be more sensibly worded as 'Site impact on adjoining occupiers is acceptable'.