Gypsy, Traveller and Travelling Showpeople Development Plan Document
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New searchPlease see comment below regarding question 1, which does not have a comments box: We agree with the objectives and vision of improving social cohesion between the settled and the travelling communities and of trying to reduce social tension. However, the development plan as drafted will have the opposite effect. It will risk decreasing social cohesion by housing all of the traveller community in rural countryside locations and all of the settled community in urban locations. Thus, segregate the two communities. It will increase the concentration of traveller sites in the southern half of the Borough in places with the highest proportion of people from the Gypsy and Irish ethnic group, rather than looking to evenly distribute sites throughout the Borough, exacerbating social tensions. It will support the expansion of existing traveller sites, without limiting the total number of pitches. This means there is a likelihood of small family sites, which peacefully co-existed, could expand into large conurbations of mobile homes, which dominate their nearest settled neighbours and create social tensions contrary to the requirements of PPTS. The DPD will look to fulfil the accommodation needs of the traveller community by placing them outside locations where they could more easily access healthcare and schools, and the other social amenities available to the wider community. This is in contrast to the policies which the adjoining Borough of Tonbridge and Malling are consulting upon, as they state that to be approved, a site must be “in a sustainable location and is either located within or adjoining a settlement confines boundary or within good proximity to a range of services including shops, schools and primary health care facilities accessible by public transport, to enable integration into the community” It is noted that PPTS accepts rural locations are acceptable in principle, but that they should be strictly limited in locations away from settlements. Sites should therefore be located within or close to a settlement. Paragraph 8 of PPTS states “Local Plans must be prepared with the objective of contributing to the achievement of sustainable development. To this end, they should be consistent with the policies in the National Planning Policy Framework (NPPF), including the presumption in favour of sustainable development and the application of specific policies in the Framework, and this planning policy for traveller sites”. At present, the DPD does not achieve the Council's stated objectives of protecting the Borough’s natural heritage, enhancing biodiversity, promoting nature, ensuring that all new development is built to the highest standards of sustainable design and construction and has dependable infrastructure for the removal of sewage and wastewater.
The ethos of the policy is to direct development toward the largest settlements first. However, the proposed allocations do not follow this strategy, as they locate all new traveller sites in the least sustainable locations for development, i.e. rural countryside purely based on the available land put forward to date. This is not in accordance with PTTS or the objectives of the NPPF. There is no need to add the wording ‘will be permitted’ as this gives weight to words outside of a Development Plan policy itself. Repetition of section 38(6) of the Planning and Compulsory Purchase Act 2004 is more appropriate. Section 2 and 3 should refer in the text directly to compliance with the Development Plan. Policy 2e(i) requires more clarity on what is ‘appropriate’ in order to comply with the policy. For example, standards set in terms of pitch size, spacing, amenity, soft landscaping, access, highway safety and parking. Although withdrawn, the DCLG Good Practice Guide provides such information that could be used. This is referenced in the DPD but criteria should be part of the policy, not advised. Specification such as a maximum site size of 15 is therefore requested. Individual pitch sizes of 320m2 should be specified, as referred to in the ORS The Gypsy, Traveller and Travelling Showpeople Accommodation Assessment. (GTAA) (2025) at 1.28. Section 5 must interrelate with NPPF 11d. The Council is requested to consider whether pitches could be allocated on any of the larger sites identified for bricks and mortar development. In the same way that self build plots are often identified, so could Gypsy and Traveller Pitches. East Hertfordshire Council have successfully achieved this in their 2018 Local Plan at Gilston, policy GA1, which allocates 15 pitches into a mixed use, 10,000 home allocation. We also do not support the intensification of existing authorised sites for the reasons set out in our response to questions 1 and 3.
We do not agree with the proposed policy for meeting accommodation needs. Many of the allocated sites listed are above the DCLG Good Practice Guide recommended limit of 15 pitches and are all located in rural locations, which the Council itself recognise as being the least sustainable location for such development. As this is a Borough-wide approach it is important to consider the allocation of sites (of which the Council has most control) in a spread across the Borough, in the same way that bricks and mortar development is assessed. This takes in account site designations, access to services and facilities, limiting pressure on local medical and educational services (noting most GRT development is not CIL liable) and also ensuring that sites individually or cumulatively do not dominate the nearest settled community. PPTS 10d states that allocated sites should “relate the number of pitches or plots to the circumstances of the specific size and location of the site and the surrounding population’s size and density”. It is also too simplistic to say that all existing sites and adjoining land in the same ownership should be considered suitable as ‘broad locations for growth’. PPTS 10b requires specific, developable sites to be reviewed and identified. Intensification without very stringent criteria would simply give the green light to overcrowded sites, with poor amenities, outdated and undercapacity sewage and drainage provision, no parking and a lack of adequate circulation space, as their owners look to maximise occupiable space and potential rental income. This would, in turn, give the occupants of such sites very poor living standards, which have been shown to have significant negative impacts on both physical and mental health. This does not align with the Council's objective of putting people first, or the NPPF objectives, seeking for planning to create clean, liveable, healthy places. Furthermore, blanket support for intensification of existing sites will encourage unauthorised development via ‘doubling up’ in advance of retrospective applications for consent, whilst fettering the Council's ability to oppose such development where it does not align with policies TR7 & TR8. Strict clarity on the criteria for any intensification or expansion proposals is therefore critical. As indicated above, a 320m2 minimum pitch size and a maximum 15 pitch site size is requested.
Change of use should be allowed for authorised traveller sites, where this is appropriate and approved as part of the usual planning process. What planning legislation in general and the NPPF in particular encourages is a proactive and positive approach to granting planning permission for alternative use, to make efficient use of land and to meet changing local needs. It would be wrong, therefore, to treat traveller sites in this manner. In point 102 the Council says there are many existing (predominantly small) sites which have conditions limiting occupation to named occupants, and goes on to indicate that these should become unconditionally authorised sites. We do not agree with this approach, as many of these sites will have been granted permission on the basis of individual need when they would not otherwise have been deemed to be suitable. They should therefore be individually reassessed on the basis of TR7 & TR8. At present, they cannot count toward the Borough’s supply as they are not available for all members of the community, and if the site were vacated by the named occupant, the pitch would cease to be part of the Council’s stock of sites. As previously mentioned, if policies TR7 and TR8 are to detail the criteria for accepting sites, additional requirements should add parking for at least 2 cars, circulation space for vehicles, especially important for manoeuvring large mobile homes on and off site, minimum size of pitches (320m2), amenity space for each pitch (TR8(1a)), dependable infrastructure for the sewage disposal and drainage, and consider future flood risk as per the new emerging NPPF. Play space for children should be required within each pitch, or where sites are smaller, safeguarded within the wider site itself. A lack of play space results in children playing in the access driveways which is unsafe. The phrase ‘where appropriate’ is unclear in TR8(1b/c)? TR7(1f) presently accepts moderate landscape harm as acceptable. The assessment of harm should be a planning balance exercise not accepted as policy compliance. This section conflicts with TR8(1h). It should also look to address upgrading the design of existing sites where intensification is to be permitted. Particular attention should be given to the disposal of sewage, as the majority of sites in rural areas will not be connected to main drains and often rely on the use of septic tanks, which are likely to be undersized where expansion is permitted.
POLICY LPR (023) – LAND REAR OF CHART VIEW – SITE B was refused expansion for 5 additional pitches by the Council’s Development Control in Application 23/505684/FULL, for reasons which remain wholly valid and up to date for both this site and the adjacent site POLICY C4S (021) – CHART VIEW (rear of 1 CHART VIEW). Please refer to the attached delegate report, which sets out why these sites are inappropriate for further expansion and should not be allocated. Of particular note: 1) “The proposal would intensify the concentration of mobile homes and associated domestic paraphilia in this part of the countryside which would impose significant harm to the character and visual amenity of the area. Moreover, the scheme having regard to the lack of suitable, adequate, or practical outdoor amenity provision, levels of privacy, would diminish the standard of living conditions enjoyed by future occupiers of the mobile homes”. 2) “In this instance, it is not considered the granting of a temporary permission is appropriate given the circumstances of the site and the fact the proposal would have a significant adverse effect on the character of the valued landscape” 3) The proposal was also rejected on amenity and parking reasons, which would be material for any allocation. The Council Policy team has not presented any assessment to indicate that the proposed allocations overcome the material concerns of the Planning Officers or the Appeal Inspector and that the sites can actually be considered suitable or delivered in a policy-compliant manner. 4) The proposals will add to the imbalance between the settled community (currently seven dwellings at Rabbits Cross) and the Gypsy and Traveller community, contrary to the PPTS and the proposed new DPD policies. As highlighted by the planning inspector in Appeal APP/U2235/C/24/334802, which related to the adjacent site of Hawthorn Lodge. Extract below. 5) Application 25/503131/FULL POLICY LPR (022) – LAND REAR granted approval for 3 additional pitches and not the proposed 2 pitches, noting that community domination and landscape harm had arisen in the planning balance. Further pitch allocation in this location would intensify such impacts. 6) Specifically, it is extremely unclear how the site rear of 1 Chart View could possibly accommodate a further 20 pitches, noting the policy criteria and National requirements in PPTS, given that Site B, which is approximately half its size, was refused permission for 5 pitches on the grounds that it was insufficient in size, and could not provide adequate parking or amenity space. 7) An existing Public Right of Way (PRoW) KH562 is also a significant constraint. This runs directly through both sites proposed for allocation. It would not be appropriate for a PRoW to run directly through 2 private residential sites. No reference is made to the PRoW within the site-specific policy, and it would not be appropriate for the PRoW to be extinguished in order to accommodate these sites. The further allocation of the 2 sites at Chart View goes against Development Control assessments and earlier refusals where conflict with the Development Plan has been clearly identified, specifically surrounding landscape and domination of the nearest settled community. Allocation of sites at Chart View is therefore inappropriate and cannot meet the policy requirements as set out in the DPD. These sites should be removed from the allocation list. POLICY CS4(029) PEACOCK FARM Plot 6 at Peacock Farm was granted permission on 27 November 2025 for 3 additional static units, a facilities block, 3 no associated touring caravans, the provision of 6 no parking spaces and hard and soft landscaping for gypsy and traveller use. This allows for a total of 10 caravans: 5 mobiles and 5 tourers on this site. The plans also include 2 x day rooms, although there is no mention of these in the permission. Given that this site takes up the majority of the site shown in Policy C4S (029), it is hard to envisage how it would be possible to fit an additional 10 units into the remaining space, especially if the site layout and design criteria in TR07 and TR08 are followed, inclusive of a minimum pitch size and overall site size. Significant concern is expressed that the allocation would not meet minimum amenity, play space or parking requirements. Allocations must meet policy-compliant criteria. At Peacock Farm on another site adjacent to the one above, application 25/504652/FULL is outstanding for 5 mobile homes, 5 touring caravans and 4 dayrooms. Other sites with Peacock Farm have the following number of approved pitches: Plot 4 Peacock Farm 4 mobile homes and 2 dayrooms. Plot 3 Peacock Farm 1 mobile home, 1 touring caravan and 1 utility block Plot 2 Peacock Farm 1 mobile home Plot 1 Peacock Farm 2 mobile Homes and 1 utility block There are, therefore 13 approved pitches already at Peacock Farm and 5 pending approval. We contend, therefore that this location should not be allocated any further pitches as the traveller community already far exceeds the surrounding population's size and density.
Policies LPR(023), CS4(021) and CS4(029) should be deleted for the reasons given in the Council/Appeal reports referred above. The further development of these sites would result in landscape harm, domination of the nearest settled community, and would result in inappropriate highway and amenity impacts. CS4(021) and CS4(029) for 20 and 15 pitches, respectively, would have the greatest impact, and the site size identified is not sufficient for the number of pitches proposed for allocation. Site allocation should be on the basis of expanded TR7 & TR8 policies for consistency.
Public sites are welcomed. Policy TR5 should clarify if these are GRT pitches or Travelling Showpeople Plots. It appears a policy for both but the design requirements and needs are different for the different groups. This should be clarified with reference to PPTS Annex 1. TR7 and TR8 should be cross referenced for clarity
The acceptability criteria for rural exception sites should be the same as non-RES sites. Policy TR6 should therefore include the requirements set out in TR7 and TR8 as amended above. It is unclear why 20% BNG is required as a minimum here but not for other policies in the DPD. Consistency should be applied.
See comments above. TR7(1b) needs to reflect PPTS 13. TR7(1f) implies moderate landscape harm is always acceptable, when it should be part of a planning balance. TR7(1g) is unclear. What are exceptional circumstances? This is an extremely high bar. TR7(1g) also implies a sequential test is needed, with sites ‘preferred’ in certain locations. How will this be evidenced/assessed? Overall, the wording is ambiguous and impossible for the Council to assess and control. A more detailed and controllable specification is required.
