Gypsy, Traveller and Travelling Showpeople Development Plan Document
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New searchAgree. The spatial policy needs to adhere to National Planning Policy requiring councils to assess and meet the needs of the GTTS community. Agree that the preferred approach is to provide pitches and plots in the most sustainable locations aligned to the Settlement Hierarchy as set out in a to d. b. We welcome that Maidstone Urban area is considered as a location for development but understands that the town is unlikely to be a suitable location for new sites/pitches. However, the most culturally appropriate and easiest way to meet need is likely to be the expansion and/or intensification of existing sites where appropriate and in accordance with proposed DM policies. This is the TWBC approach. Alongside this, the consideration of sites put forward through the call for sites process and maximising the number of pitches provided in accordance with proposed DM policies. c. Garden settlements and Strategic Development Location -TWBC supports the potential to incorporate pitches/plots within these locations. This has been the TWBC approach in its Adopted Local Plan, where provision is provided within its Paddock Wood Strategic policy (site allocation STR/SS 1). MBC will need to demonstrate that it has reliable sources of windfall schemes that come forward. We welcome the approach of intensification and expansion of authorised sites. Has there been any work to show the likely number of pitches that could be accommodated in this way? ii. TWBC agrees with this approach – brownfield first. Has there been any work to show the likely number of pitches that could be accommodated in this way? 3. Greenfield Land in the Countryside: It is acknowledged that G & T provision starts from being inappropriate in the Green Belt. However, if MBC is to optimise its supply and meet its need in full and given that this is where need is likely to arise, this DPD should consider whether there is appropriate Green Belt and/or grey belt land that could be released to provide new sites. This was a comment that TWBC made at the 18b consultation that has not been addressed. In addition, there should be consideration of appropriate development in the National Landscape. Not supportive of a rural exception site policy as such development rural exception sites will come forward through windfall development. However, if a rural exception site policy is to be promoted and there is an identified need this needs to be quantified, and an idea given for where this need arises to guide where exception sites could be located to meet the need arising. 4. Agree that pitches should not be provided on land that does not accord with national policy for flood risk. 5.Agree that all proposals should accord with Development Management policies
The assessment of accommodation needs is a ‘point in time’ exercise. The consultation notes that some of the identified need has been met through the granting of planning permissions between 2023 and now. Since 2023 the Council has granted permission for 75 new GTTS pitches. This takes the net need for pitches for households in the first 5 years down from 251 to 176 pitches. No plots for travelling showpeople have been permitted over the first 5 years, so the need remains for 2 plots. The DPD needs to be clear at points 1 and 2 about the number of pitches and plots required in the first five years taking account of existing permissions. This also needs to be reflected in point 1 for the whole Plan period 2023 to 2040. TWBC notes that several proposed allocations are proposed without specifying the number of pitches, that could be accommodated. This is essential to establish the resultant supply and any residual unmet need – any Unmet need needs to be clearly stated. (Appendix 2 has a map of the location and lists the identified sites for provisional allocation to accommodate need. TWBC notes that none of the proposed allocations are close to the boundary between the two Boroughs).
To ensure that existing sites are safeguarded to meet current and future need.
TWBC supports the approach of there being a site allocation policy for each site, against which proposals will be assessed alongside relevant Development Management policies. We note that some sites have been allocated without an indication of the number of pitches that can be accommodated there. The number of pitches per site should be maximised and clearly stated so expectations are set for all interested parties and so that the unmet need through proposed allocations can be clearly identified. We agree with the approach to achieving high quality accommodation which is sustainable and minimises the impact of new pitches on the environment and local infrastructure. Site specific policies may benefit for including a site wide management plan for the new and/or additional pitches. Policies should state that essential infrastructure such as water or electricity provision should be sufficient to meet capacity. The sites carried forward from the Local Plan Review would provide a total of 22 pitches. The sites put forward as part of the call for sites total 175 pitches with five sites submitted with an unspecified number of pitches. This could therefore provide enough pitches to meet the 5-year net need for 176 pitches but this is not stated. I understand that further analysis of sites is required however a paragragh stating 'potential' to meet needs may be appropriate? Unmet need and how it is met needs to be stated clearly for years 6 – 10 and 11 – 15.
Comments are general as we have no comments to make on specific allocations. TWBC agrees with the approach to achieving high quality accommodation which is sustainable and minimises the impact of new pitches on the environment and local infrastructure. The policy would benefit for including a site wide management plan for the new and/or additional pitches. This has not been incorporated in the site allocation policies. There is no mention of other infrastructure such as water or electricity provision in the allocation policies. The sites carried forward from the Local Plan Review would provide a total of 22 pitches. The sites put forward as part of the call for sites total 175 pitches with five sites submitted with an unspecified number of pitches. This could therefore provide enough pitches to meet the 5-year net need for 176 pitches but this needs to be clearly stated here. Unmet need and how it is met needs to be stated clearly for years 6 – 10 and 11 – 15.
TWBC supports the proposed policy for new public site provision and notes that MBC is committed to the provision of a new public site. However, delivery of a new site is not part of the allocations in this DPD nor is there consideration of the expansion of the existing public sites. It is therefore not clear how MBC proposes to provide for new public sites, for which there is a need. At paragraph 118 the GTTA identifies a need for 10 additional affordable pitches in the first five years, and a further 11 pitches beyond the first five years. To an extent there is also likely to be a hidden affordable pitch need on the two publicly owned sites at Stilebridge and Water Lane. To assist in meeting this need has there been consideration of the expansion of the existing public sites within the parameters of TR6, TR7 and other Development Plan policies? TWBC considers that the potential need for 21 affordable plots needs to be met as part of this DPD in the first 5 years rather than wait for a future review given that this need is only likely to increase.
TWBC previously commented at Regulation 18b that we did not see a necessity for a rural exceptions site policy to meet need as such development would form part of windfall development. This comment still stands and believe that a rural exceptions policy is not required as part of a future DPD, although we appreciate that this is part of Planning Policy Guidance
TWBC is supportive of this approach to ensure that new accommodation on non-allocated sites is of good quality, provides a healthy environment for residents, close to local facilities and respects the natural environment
TWBC supports this approach. Consideration should be given to include the need for good management and maintenance of sites for the benefit of the communities living there. DM Policies should include for the fitting of solar panels and other sustainable energy solutions wherever possible. Porous surface materials should be used for all hard standing.