Gypsy, Traveller and Travelling Showpeople Development Plan Document

Approach to meeting identified accommodation needs

Policy TR2: Approach to meeting accommodation needs

87. As set out in the introductory section of this DPD, the Gypsy and Traveller Accommodation Assessment (GTAA)^[24] identifies the accommodation needs for Gypsy and Traveller and Travelling Showpeople households for the period 2023-20240.

88. There are different ways for the Council to plan for the provision of new pitches and plots for siting culturally appropriate accommodation in the borough. In some instances, we will identify and allocate land where pitches/plots can be delivered. We will also identify broad locations for growth, where there is evidence to suggest that additional pitches/plots are developable. We will also need to rely on considerable levels of unallocated and unidentified 'windfall' sites to contribute to meeting identified accommodation needs.

89. For those households who meet the PPTS Annex 1 definition (see 'National context' section), national policy requires the Council to identify deliverable sites for years 1 to 5 of the plan (i.e. allocations); to identify developable sites or broad locations for years 6 to 10, and where possible 11 to 15.

90. For those households not meeting the Annex 1 PPTS definition, national policy does not require the Council to allocate land. However, given that the most recent Annex 1 PPTS definition encompasses "all other persons with a cultural tradition of nomadism or of living in a caravan", it is likely that even in instances where the planning status of a household could not be determined through the GTAA, they would meet the latest Annex 1 PPTS definition. The culturally appropriate accommodation needs of these 'undetermined' households must still be appropriately planned for through planning policies – usually criteria-based policies.

91. Advice from the consultants responsible for the production of the GTAA is that teenage children's accommodation needs can sometimes be met through provision of a touring caravan more informally within an existing pitch. Similarly, single adults may not need a formal pitch, but their accommodation needs could be met through provision of additional touring caravans.

92. Commonly there is a desire for households to remain on a family site. According to a 2022 report produced by the Office for National Statistics^[25], close relationships with family is fundamental to Gypsy and Traveller values and well-being.

93. Given the above, the Council is proposing the following sequential approach to meeting the identified accommodation needs as evidenced in the GTAA, as far as is possible:

1. The allocation of specific deliverable sites over the first five years of the plan (2023 – 2027) through:

• Review and retention of relevant LPR GT1 site allocations.
• Thorough assessment and regularisation of existing temporary and unauthorised sites where it is considered that suitable mitigation measures can be achieved to make the site suitable^[26].
• Thorough assessment and potential inclusion of suitable new sites submitted to the Council through the previous call for sites exercises. This includes both public and private sites.

There is expected to be a residual amount of unmet need in the first five years where the Council are unable to allocate sufficient deliverable sites. The intended approach to meeting this unmet need is set out below, under the 'unmet need' section.

2. The identification of developable sites or broad locations for growth in years six to ten (2028 – 2032).
   • Broad locations for growth: the Council considers that, in line with the PPTS, existing authorised permanent sites may be appropriate for intensification, reorganisation or expansion as these are (by virtue of being permitted) suitably located for development of this type, with a reasonable prospect that they will be available and could be viably developed at the point envisaged i.e. when the accommodation need arises. This is confirmed through the initial Pitch Deliverability Assessment (PDA)^[27] outcomes,which suggest that up to 45% of all identified accommodation needs could be met through the provision of additional pitches/plots on existing sites.

Therefore, all authorised permanent sites with identified accommodation needs are considered as suitable 'broad locations for growth' (i.e. developable) for years 6 to 10 of the plan.

• Further, there are the two strategic-scale sites of Heathlands and Lidsing Garden Communities. A significant amount of development is expected to occur in the locations in the longer term. Whilst the precise land parcels and detailed development proposals are not specific at this time, Garden Communities represent a suitable broad location for the longer term provision of site(s) to accommodate culturally appropriate housing needs as part of creating mixed and balanced communities. This is likely to be from year 11 (2033) onwards.

Unmet need

94. Despite the Council's best efforts in seeking to identify land, it is evident that the approximate number of pitches to be delivered on the proposed site allocations (under policy TR4) is not likely to meet the NPPF/PPTS requirement in terms of providing a 5-year supply of 'deliverable' sites against our assessed needs. This is due to the very high identified need of 251 pitches for Annex 1 PPTS definition households that is front-loaded at the start of the plan combined with simply not having enough 'new' sites available^[28] to allocate.

95. This expected shortfall of deliverable pitch provision in the first five years means it is probably not possible to demonstrate a 5-year supply of sites on adoption of the plan as required by the NPPF/PPTS.

96. However, as can be seen from published data in our annual Authority's Monitoring Reports (AMR), there is a demonstrable and proven strong delivery of new pitches through both within existing permanent authorised sites in the borough, as well as on wholly new sites i.e. windfall sites development across the borough.

97. Findings from the initial Pitch Deliverability Assessment (PDA)^[29]worksuggest that up to 82% of the full identified accommodation needs could theoretically be met within existing sites. However, this level of deliverability may be tempered by factors affecting site achievability i.e. ability to accommodate further pitches through a policy-complaint scheme; as well as by the feedback from this consultation.

98. Excluding pitches that were granted upon appeal, there were an average of 25 pitches on non-allocated sites^[30] permitted per year since the adoption of the previous Local Plan (2017) i.e. between 2017/18 – 2024/25. Applying that annual pitch delivery rate over the 15-year plan period would provide in the region of 375 pitches.

99. As such, whilst the council does not intend to write detailed site allocations for each of the existing sites where additional pitches are required and could be delivered, we are confident that these needs could be met through the planning application process and assessment against the detailed development management policies, to ensure high quality developments are achieved. This approach reflects the organic pattern of growth experienced from this type of development.

100. Therefore, where there remains unmet needs and the Council is unlikely to be able to demonstrate a five-year supply of pitches, any proposals for accommodation will be assessed under policies TR1 – Spatial Strategy, TR3 – Safeguarding permitted sites and/or TR7 – Accommodation on non-allocated sites, and any other relevant Development Plan policies.

101. Further, the Council may formally ask neighbouring authorities to help meet the need arising specifically from Annex 1 PPTS definition households in the first five years (where allocations are required) under the legal Duty to Cooperate process^[31].