Support recognition that provision will be made
Object strongly to the fact the Reg18 consultation has proceeded without an uptodate GTAA. How can the Council claim it is committed to meeting need when it concedes its proposed policy approach is not informed by an uptodate GTAA? This offends the Equality duty as the general housing need is reviewed and updated continuously.
I object to the policy as drafted as it is reliant and predicated on the basis that need will be assessed and updated. But you have failed to do so . You expect GTs to prove this for windfall sites. It is unclear how allocations will be included on non allocated strategic sites without proper data (para 10.80). These are meaningless policies designed to thwart provision and contrary to the aims of par 11 PPTS which requires criteria policies where there is no identified need.
The Council is still reliant on the 2017 GTAA which is out of date. ORS now acknowledge that their previous GTAAs were not robust and credible as they always claim, as many have seriously underestimated need for more pitches for a variety of reasons including incorrect household formation rates. What they still omit to accept or acknowledge is they continue to ignore or factor in in-migration as part of their studies when it is apparent this is taking place in quite a few Council areas and have historically interpreted the planning definition of GT community differently to that of Planning Inspectors and other agents doing need assessments thereby underestimating need. Hopefully this will change with PPTS 2023 definition as correctly listed in your policy.
It is pointless drafting a policy without first acknowledging the scale of need and taking that into consideration.
Adopted policy CN5 has failed to deliver the required number of pitches-and underestimated real need. I find little evidence of any commitment to assist GT community in this district
Policy failure is reflected in the high number of appeals for Traveller pitches in this District in relation to the v modest scale of need identified by ORS.
Whilst I agree that allocations on strategic sites should be considered, I question how you can claim at 10.75 that this is considered the most effective method of meeting requirements. What evidence do you have to support this claim? The fiasco that is Hounsome Fields demontrates that Greenfield Sites can not be relied on to immediate need but could be a useful source for long term needs. It is not clear if any GT pitches have been delivered (ie available now) within 5 years of the local plan being adopted in 2016. The Council should reflect on this failure and be realistic as to the likelihood need will be met this way in the short term. I have been monitoring this for the last 10 years and can inform you that nationally v few pitches have yet to be delivered on housing allocations and there are sadly many examples where it has been thwarted/ side lined and delayed.
It is astonishing that policy as drafted anticipates failure to provide as part of strategic allocations. How can you claim at 10.68 that you are committed to addressing need yet draft a policy that accepts that the main plank of provision as part of strategic sites will fail. If, as policy appears to anticipate, alternative sites will be available, why not identify and allocate these at the outset rather than rely on developers to make provision. That way Travellers can ensure sites are developed immediately to meet the need they have without reliance on unknown provision on strategic sites .
There should be another tier of provision between Strategic sites and windfall applications and that is for small private family sites on land that is not part of strategic allocations and not reliant on developers to deliver , to meet the immediate need and to meet a continuing need.
There is still no social provision in the district. This is a disgrace given that you chose to close the former site at Peak Copse and refuse to reopen it despite evidence Travellers would gladly take it over and run it. That site still benefits from permission for a Traveller site.
The criteria policy for windfall sites is welcome but given the failure of current policy criteria (f) is unacceptable as you are not prepared to update need assessments regularly and will claim need is being met on strategic allocations when it is not (as you did when you misled the appeal hearing for land at Silchester). This criteria is also contrary to para 11 PPTS which states that criteria policies are designed for situations where there is no identified need. There is no policy basis for applicants to prove otherwise.
Criteria (H) should provide guidance as to what is considered a reasonable distance. You are a largely rural district. Some rural settlements do not benefit from public transport services so a site could comply with par 10.79 and be located within or near a settlement yet have limited services to hand.
Criteria (i) is unreasonable.There is no requirement inPPTS for sites to be served by public transport and NPPF recognises that options for sites outside settlements is more limited.
Criteria L is designed to thwart provision. Given the acceptance that sites should be part of strategic allocations I question the need for this for windfall sites.
I support the need to retain sites for the purpose for which they are granted.
I question why GT sites on non allocations will only be permitted for developments of 500 homes or more. That is unlikely to deliver new sites and the Council appears to be accepting/ admitting that its housing allocations are also likely to under deliver.
It is far from clear how cultural need will be met from general housing policies within the plan. Has the Council delivered any GT sites to meet this need to date?
Para 10.76-why does this refer to pitches for sale on the open market? Why not all pitches? Why has this guidance not been followed at Hounsome Fields where provision is made for single unit statics only?
Para 10.77-I support the need for 'affordable ' pitches but what do YOU understand or mean by this. How will this be assessed. It has remained unclear to date how sites on allocations are to be disposed of to ensure they meet the need identified and are not sold to the highest bidder to meet a need that was not taken into consideration as part of the GTAA.
Para 10.78-is this really necessary? It would not be public open space if it is required for a GT site.
10.79-How are Travellers expected to review and appropriately address provision of local services such as school places or Dr/ dentist provision? That seems unreasonable. It is truly shocking how often locals will maintain schools are full/ over subscribed to justify rejecting provision for GT sites for families who are often in urgent/ dire need of such services. These kind of policy comments are only designed to thwart provision. Would you consider this for other housing exceptions such as essential rural workers accommodation?
Given how hard it has been to date for Travellers to reside in this district, the fact the one and only socially provided site was closed and not replaced thereby leading to a reduction in overall pitches displacing families to other districts , the failure of adopted policy to meet immediate need and fiasco at Hounsome Fields, I really think the Council needs a more positively worded policy informed by a proper uptodate need assessment because at present the Council is doing very little to help address the regional and sub regional need and under the duty to cooperate is failing to meet its fair share.