Gypsy and Traveller and Travelling Showpersons accommodation
Question GT 1
Do you agree with the suggested policy approach towards Gypsy and Traveller and Travelling Showpersons accommodation, as set out in GT 1 'Gypsy and Traveller and Travelling Showpersons accommodation' above? If not please suggest how it could be amended?
48 comments
| Theme | Summary |
| Evidence base – Gypsy and Traveller Accommodation Needs Assessment (GTANA) | Many respondents state that it is premature to finalise policy without an up-to-date Gypsy and Traveller Accommodation Needs Assessment, highlighting reliance on outdated evidence, lack of clear pitch targets, and heightened appeal risk without a robust and deliverable assessment of need. |
| Provision on larger residential sites | There is strong opposition to requiring traveller pitches on larger housing sites, with respondents citing lack of evidence of demand, design and integration difficulties, and calling for this requirement to be removed from the policy. |
| Green Belt and countryside policy | Views are divided on Green Belt provision, with many objecting to release except as a last resort, while others argue it may be unavoidable given the scale of the Green Belt and traveller preferences for accessible locations near urban areas. |
| Existing sites and private provision | Some respondents question the effectiveness of relying on expansion or intensification of existing private sites, noting lack of Council control, affordability issues, and the inability to compel delivery or ensure availability of pitches. |
| Plan-led and Council led provision | There is support for a plan-led approach with identified allocations and some socially provided pitches, recognising the increasing difficulty of self-provision and the need for certainty, fairness and borough-wide distribution. |
| Transit provision | Some respondents highlight the absence of transit provision and its importance in reducing unauthorised encampments, although views differ on whether this should be delivered as one larger site or multiple smaller stopping places. |
| Location, accessibility and infrastructure | The importance of appropriate site location is emphasised, particularly in relation to transport impacts, road safety and access to services, alongside concerns that overly rigid public transport requirements may be unrealistic. |
| Environmental and heritage constraints | Support is expressed for protecting heritage assets, landscape character, ancient woodland and biodiversity, with calls to explicitly exclude sensitive environmental locations from potential sites. |
| Fairness and distribution | Two respondents stress that Gypsy and Traveller provision should be fairly and proportionately distributed across the borough to avoid over-concentration and perceived inequity between communities. |
| Site management and standards | There are calls for clear standards for site layout, maintenance and management, particularly for private sites, to protect living conditions for residents and amenity for surrounding areas. |
| General Support (Qualified) | Some respondents support the principle of a plan-led approach, but this support is often qualified by caveats relating to evidence, Green Belt protection and delivery mechanisms. |
Question GT 2
If sufficient sites cannot be identified in settlements, should the new Local Plan prioritise non-Green Belt /grey belt locations?
27 comments
| Theme | Summary |
| Prioritisation of non‑Green Belt locations | A clear majority support prioritising non‑Green Belt/brownfield land first, stating Green Belt release should be exceptional and only considered if no alternatives exist. |
| Strong opposition to Green Belt and Grey Belt use | Many express firm opposition to any Green Belt/grey belt use, with some calling for an explicit prohibition. |
| Brownfield‑only approach | Some argue provision should be restricted exclusively to previously developed land to avoid countryside harm and prevent erosion of the Green Belt. |
| Conditional or sequential support for Green Belt review | A small number accept Green Belt/grey belt release only as a last resort, subject to strong evidence and protection of Green Belt purposes. |
| Need for wider planning considerations and criteria | Two respondents emphasise that prioritisation must also consider accessibility, landscape, flood risk and settlement hierarchy. |
| Heritage and environmental protection | Two respondents support for safeguarding heritage assets, landscape character, and sensitive ecological features when considering sites. |
| Concerns About Social Isolation and Accessibility | One respondent highlights risks that remote locations could reinforce social isolation and limit access to essential services. |
| Traveller site enforcement and unauthorised development | One respondent raises concern about repeated unauthorised development on countryside sites, arguing for stricter locational controls. |
| Green Belt review as necessary structural change | One detailed submission argues Green Belt policy is outdated and selective review is needed to meet accommodation needs. |
Question GT 3
Given the small scale of traveller sites, should sustainability tests be reduced so sites can be located away from identified settlements?
26 comments
| Theme | Summary |
| Sustainability tests – general approach | Respondents are split on whether sustainability tests for traveller sites should be reduced. A clear majority oppose reducing standards, arguing sustainability is essential for safety, inclusion, and access to services, while a minority support greater flexibility to enable delivery. |
| Consistency with the National Planning Policy Framework and Planning Policy for Traveller Sites (PPTS/NPPF) | Two respondents argue the Council has misinterpreted national policy, particularly Planning Policy for Traveller Sites paragraph 13 and National Planning Policy Framework footnote 57, stating these do not require rigid locational or transport-based sustainability criteria. |
| Access to services, schools and healthcare | Many respondents emphasise the importance of reasonable access to schools, healthcare and services, warning that relaxing sustainability requirements could result in isolated and unsuitable sites. |
| Transport, car dependency and traveller lifestyles | Two respondents highlight that Gypsy and Traveller households are typically car dependent due to work patterns, arguing that requirements for walking or public transport access are unrealistic and do not reflect day-to-day needs. |
| Location away from settlements | Views differ on whether sites should be permitted away from settlements. Some support flexibility due to land availability constraints, while others caution that remote locations undermine sustainability and community inclusion. |
| Scale and nature of sites | Two respondents note uncertainty over future need and site size, with some cautioning against assuming small-scale provision and others expressing a preference for smaller sites provided they remain sustainable. |
| Environmental and heritage considerations | Two respondents stress that relaxing sustainability tests should not override environmental protection, heritage conservation or the need to avoid sensitive habitats and landscapes. |
| Community impact and inclusivity | There are concerns that lowering standards could entrench exclusion, increase conflict, and reduce opportunities for integration, with calls to focus on inclusivity and community cohesion. |
| Clarity and understanding of the policy question | Two respondents state that the question or the sustainability tests being referred to are unclear, limiting their ability to comment meaningfully. |
| General Support or Agreement | A minority of respondents support reducing sustainability tests or answer in general agreement with the principle, often without detailed justification. |
Question GT 4
Should pitches / plots be required on large scale residential/housing sites or allocations?
37 comments
| Theme | Summary |
| General opposition to on‑site provision | A clear majority of respondents object to requiring Gypsy and Traveller pitches on large‑scale housing sites, considering the approach inappropriate, unworkable, and unsupported by evidence of demand from the Traveller community. |
| Policy and delivery uncertainty | Many respondents argue that tying large housing allocations to traveller provision introduces unacceptable uncertainty, as the product, delivery mechanism, and long‑term management of sites are unknown and largely outside developers’ control. |
| Commercial viability and developer resistance | Some respondents highlight strong resistance from the development industry, citing concerns over viability, mortgageability, marketability, and sales values, with developers expected to seek payment in lieu or avoid on‑site provision. |
| Integration versus community tension | Views differ on integration: some argue co‑location supports inclusion and reduces segregation, while others warn it is likely to cause friction and is inconsistent with traveller lifestyles and resident expectations. |
| Scale, thresholds and proportionality | Some respondents suggest that if pursued at all, provision should be limited to very large sites and scaled proportionately, noting that smaller developments are more manageable and workable. |
| Need for a mandatory and clearly defined policy | Two respondents stress that provision will only be delivered where it is a clear and mandatory policy requirement, supported by defined thresholds, phasing, design standards and management arrangements. |
| Evidence of limited delivery elsewhere | Two respondents note that few authorities have successfully delivered occupied traveller sites through strategic housing allocations, highlighting risks around late delivery, poor integration, and avoidance by developers. |
| Alternative approaches preferred | Two respondents favour alternative solutions, including council‑led land assembly, use of public land, or off‑site provision, arguing these approaches offer greater certainty and control over outcomes. |
| Qualified or limited support | A small minority express support for on‑site provision in principle, typically emphasising careful design, consultation, proportionate numbers and avoidance of tokenistic or peripheral layouts. |
Question GT 5
If required as part of allocations or through policy is the threshold of four pitches for every 500 dwellings appropriate?
31 comments
| Theme | Summary |
| Sustainability tests – general approach | Respondents are split on whether sustainability tests for traveller sites should be reduced. A clear majority oppose reducing standards, arguing sustainability is essential for safety, inclusion, and access to services, while a minority support greater flexibility to enable delivery. |
| Consistency with National Planning Policy Framework and Planning Policy for Traveller Sites (PPTS/NPPF) | Two respondents argue the Council has misinterpreted national policy, particularly Planning Policy for Traveller Sites paragraph 13 and National Planning Policy Framework footnote 57, stating these do not require rigid locational or transport-based sustainability criteria. |
| Access to services, schools and healthcare | Some respondents emphasise the importance of reasonable access to schools, healthcare and services, warning that relaxing sustainability requirements could result in isolated and unsuitable sites. |
| Transport, car dependency and traveller lifestyles | Two respondents highlight that Gypsy and Traveller households are typically car dependent due to work patterns, arguing that requirements for walking or public transport access are unrealistic and do not reflect day-to-day needs. |
| Location away from settlements | Views differ on whether sites should be permitted away from settlements. Some support flexibility due to land availability constraints, while others caution that remote locations undermine sustainability and community inclusion. |
| Scale and nature of sites | Two respondents note uncertainty over future need and site size, with some cautioning against assuming small-scale provision and others expressing a preference for smaller sites provided they remain sustainable. |
| Environmental and heritage considerations | Two respondents stress that relaxing sustainability tests should not override environmental protection, heritage conservation or the need to avoid sensitive habitats and landscapes. |
| Community impact and inclusivity | There are concerns that lowering standards could entrench exclusion, increase conflict, and reduce opportunities for integration, with calls to focus on inclusivity and community cohesion. |
| Clarity and understanding of the policy question | Two respondents state that the question or the sustainability tests being referred to are unclear, limiting their ability to comment meaningfully. |
| General support or agreement | A minority of respondents support reducing sustainability tests or answer in general agreement with the principle, often without detailed justification. |
Question GT 6
In relation to policy criteria for guiding the allocation of sites are there any locally specific issues that should be included in a policy?
21 comments
| Theme | Summary |
| Need for clear, workable and fair policy criteria | Two respondents emphasise the need for a clear, practical and proportionate policy that informs site allocations, applies consistent criteria, avoids unnecessary barriers to delivery, and reduces the risk of costly appeals. |
| Access to services and infrastructure capacity | Access to schools, healthcare, shops and other services is a recurring concern, alongside the capacity of infrastructure including utilities and highways to accommodate new sites without adverse impacts. |
| Impact on settled communities and residential amenity | Some respondents stress that sites should not be located adjacent to existing housing or in positions where they would dominate nearby communities, particularly small rural settlements. |
| Protection of character, heritage and landscape | There is support for including criteria to protect the historic environment, landscape character, conservation areas, areas of natural beauty and local identity from inappropriate site allocations. |
| Environmental constraints and sensitive locations | Two respondents highlight the need to avoid environmentally sensitive locations, including ancient woodland, floodplains and motorway service areas, and to ensure impacts on biodiversity and flood risk are adequately addressed. |
| Site management, cleanliness and ongoing control | Issues of site management feature prominently, with calls for requirements on cleanliness, waste disposal, recycling, access arrangements and long-term management to support community integration. |
| Planning control and enforcement | One respondent argues that robust planning control is essential, including requirements to secure planning permission before occupation and effective enforcement where unauthorised development occurs. |
| Green Belt and density of existing sites | One specific concern raised about Green Belt impacts and the expansion of existing sites, with calls to resist piecemeal Green Belt release, avoid incremental erosion, and limit intensification to clearly justified circumstances. |
| Cumulative impacts | One respondent notes that the cumulative effect of multiple smaller sites should be considered to avoid gradual over-concentration and harm to settlement character and infrastructure capacity. |
| No comment or no local issues identified | A number of respondents state that they are not aware of any locally specific issues to include, or provide no comment on this question. |
Question GT 7
Are there any areas of land you would like to put forward for allocation as a Traveller site? If yes please provide details?
18 comments
| Theme | Summary |
| No sites proposed by majority of respondents | The majority of respondents state that they do not wish to propose any land for allocation as a Traveller site at this stage, often indicating that site identification should be undertaken by the Council through a structured and criteria‑based process. |
| Support for council‑led site search and fair process | Some respondents emphasise that the Council should lead a transparent site search using agreed criteria, rather than relying on speculative or piecemeal site submissions. |
| Protection of Green Belt, countryside and nature corridors | Two respondents stress that Green Belt, countryside and nature corridors should be protected from inappropriate development, with Traveller sites subject to the same locational constraints as other forms of development. |
| Heritage, character and place identity | There is support for ensuring that Traveller site allocations conserve and enhance the historic environment, heritage assets, landscape character and the identity of settlements. |
| Concern about impacts on small settlements | One respondent expresses concern that sites located close to small market towns could create disproportionate impacts and should be directed away from such settlements. |
| General locational principles and priorities | One respondents suggests provision of high‑level guidance rather than specific sites, suggesting priority be given to brownfield land, public land near transport routes, or small extensions to existing authorised sites where impacts can be managed. |
| Specific sites put forward | Two respondents identify specific land parcels or existing Traveller‑occupied sites for consideration, acknowledging current planning status, appeals or temporary permissions. |
Please note: this summary contains content generated by Artificial Intelligence (AI). AI generated content has been reviewed by the author for accuracy and edited/revised where necessary. The author takes individual responsibility for this content.