The local picture
7.1 South Gloucestershire has well-established gypsy, traveller and travelling showpeople communities. The majority of gypsies and travellers in our area identify themselves as Romany Gypsy and Irish or Scottish Travellers, who are ethnic minorities for the purposes of the Equality Act 2010. Travelling showpeople are self-employed people who operate fairgrounds and circuses. These communities reside on a mix of privately owned and local authority sites within our area.
7.2 There has historically been a persistent level of unmet need for accommodation for gypsies, travellers and travelling showpeople in South Gloucestershire. Recent appeal decisions relating to gypsy and traveller sites raised concerns over the historical under-provision of sites in South Gloucestershire.
7.3 There is a widespread acceptance that gypsies and travellers are amongst the most marginalised groups in the country with disproportionate health and education outcomes. For instance, life expectancies for Romany Gypsies and Irish Travellers are between 10 and 25 years shorter than the general population. A lack of secure accommodation underpins the inequalities that these groups experience.
7.4 Travelling showpeople are also known to experience difficulty in accessing secure accommodation, with its recognised benefits for education and health.
7.5 Through Phase 1 we highlighted that it is important that the council puts in place the policy framework to support the identification of land (through the allocation of sites) to accommodate sufficient gypsy and traveller pitches, in the same way that it has to identify sites for additional housing and employment development. The allocation of sites is consistent with the government’s requirement to make sufficient land available for the gypsy and traveller community and to enable them to continue their traditional and nomadic way of life, while respecting the interests of the settled community.
7.6 This position was trailed in the Phase 1 consultation document, where we set out that:
- there has historically been a level of unmet need in South Gloucestershire
- the refreshed Gypsy and Traveller Accommodation Assessment (GTAA) will set the level of need that the Local Plan will need to provide for
- it is important that these needs are met in a manner that reflects the characteristics of the community and their ‘nomadic habit of life’ through the allocation of appropriate new sites, and there remains a need to seek to protect existing, authorised gypsy and traveller sites until such time that it can be proven there is no longer an outstanding need
7.7 We also set out a desire to investigate the possibility of providing transit provision or temporary stopping places, to provide emergency, temporary accommodation for gypsies and travellers who are passing through our area.
Traveller communities’ accommodation needs
7.8 The council, in its capacity as the local planning authority (LPA) is required by national policy to make its own assessment of travellers* accommodation needs for the purposes of planning. (*The term ‘traveller’ is used by government in national policy to refer to gypsies, travellers and travelling showpeople.)
7.9 Through working with consultants, using a consistent approach and methodology agreed with our West of England partners, we have prepared a refreshed Gypsy and Traveller Accommodation Assessment (GTAA). The refreshed GTAA forms part of the Gypsies, Travellers and Travelling Showpeople background paper which is available on our website.
7.10 As set out at Phase 1, the council considers that:
- it is important that accommodation needs of its gypsy, traveller and travelling showpeople communities are met; and
- the method in which it does so reflects the characteristics of the local traveller communities and their nomadic way of life whilst also providing culturally appropriate accommodation. Doing so will ensure that, alongside meeting the requirements of national planning policy, the council is also meeting its responsibilities in relation to equalities legislation.
7.11 Through meeting the requirements of national planning policy, we will begin to respond to the concerns, included those highlighted in recent planning appeal decisions. In doing so, it is anticipated that the council will also be better placed to resist proposals for development in inappropriate locations.
Defining pitches and plots
There is no official definition of what constitutes a ‘pitch’ for gypsy and traveller use or a ‘plot’ for use by travelling showpeople. We have provided our definitions below:
7.12 With this in mind, based on the refreshed GTAA, there is a need for:
- 132 new pitches for gypsies and travellers in the period 2022 to 2042
- 65 new plots for travelling showpeople in the period 2022 to 2042
7.13 In order to inform the approaches we might take to site provision, we have undertaken some initial analysis to gain an understanding of the split between the need for private provision and social rent provision. This analysis (based on calculations aimed at breaking down the need arising from the council-owned social rent sites in South Gloucestershire) indicates that, of the overall need for 132 pitches, there is a need for 43 pitches to be provided on a social rent basis.
7.14 Since the baseline date of the GTAA (January 2022) a number of permissions have been granted resulting in 8 new private pitches, which has reduced the level of need set out above to 124 new pitches for gypsies and travellers in the period 2022 to 2042. On the basis that all of these pitches have been provided privately, this means a split of 81 private pitches and 43 socially provided pitches.
7.15 At the time of writing no applications for new plots for travelling showpeople have been approved since the GTAA baseline date. Therefore at this stage, the need for plots in the period 2022 to 2042 remains unchanged at 65, however there are currently 2 planning applications awaiting determination.
7.16 Owing to the level of need that the council needs to provide for, and the findings of recent planning appeal decisions, it is considered that a step change is required in the approach to providing for the needs of these communities. To this end, it is important that we seek to deliver this provision through the new Local Plan, while windfall applications for new pitches and plots will continue to be delivered through the development management process.
Identifying and assessing potential sites
7.17 In seeking to meet the needs of our traveller communities, it is important that we investigate all potential sources of land available to us at this stage. With the above in mind, the approach we have taken to date is to investigate the potential:
- for intensification on existing authorised sites
- suitability of land submitted through previous Call for Sites
- suitability of land owned by the council for allocation
- suitability of land owned by traveller communities for allocation
7.18 In order to ensure that the sites identified above are assessed in a consistent manner, we have drafted a site assessment methodology. This is available to view in the gypsies, travellers and travelling showpeople background paper on our website.
Intensification of use
7.19 In line with the approach we have taken previously, in the first instance we are investigating the potential for appropriate intensification of use on existing, authorised sites to accommodate ‘family growth’. Based on previous experience, it is anticipated that a significant number of pitches and plots could be delivered though intensification on existing sites, without the need to alter the sites’ boundaries.
7.20 To this end, the council’s Traveller Unit has undertaken informal engagement with a number of families on existing, authorised sites. To date, potential for intensification of use has been identified on 12 sites.
7.21 While the specific capacity for intensification on these sites will be determined using the site assessment methodology, we initially estimate that there is likely to be capacity for 12 to 15 new pitches on these sites. This work is ongoing, and it seems likely that a significant number of pitches may be identified from existing sites.
7.22 As set out above, intensification of use on existing, authorised sites is an important component of our strategy for meeting the needs of our communities. With this in mind, through this consultation period, we are seeking to engage with our traveller communities, with a view to investigating whether potential exists for intensification on other sites in South Gloucestershire.
Land submitted through previous Call for Sites
7.23 The purpose of the ‘call for sites’ is to provide an opportunity for people to identify sites they think may have the potential for development (for housing and economic purposes) through the new Local Plan. To date, we have invited the submission of sites to be considered through the Housing and Economic Land Availability Assessment (HELAA) process for their suitability for potential allocation through the Local Plan. As part of this exercise, the number of sites submitted specifically for consideration as traveller communities use was very limited.
7.24 Of the 4 sites submitted for traveller communities use, 2 were submitted for consideration for intensification of use on existing authorised sites. One of which (Bridge View, Westerleigh) has since been delivered through the development management process, and the other (Henfield Paddock, Henfield Road, Coalpit Heath) is subject to a planning application currently awaiting determination.
7.25 Of the 2 sites remaining, we consider there is some potential for new pitches and plots at:
- River View, land adjacent to Frome Mill Farm (HELAA ref. SG467)
- land off Oldbury Lane (HELAA ref. SG848).
7.26 It is considered likely that a number of new pitches and plots could be delivered through these sites listed above. The suitability of these sites will be determined using the site assessment methodology. It will also be important to consider the most appropriate use (either gypsy, traveller or travelling showpeople) for these sites in the round alongside the other potentially suitable sites we may identify through the sources described below. Once this has been done, we will be able to determine the potential capacity of each site.
7.27 We are re-opening the Call for Sites as part of this consultation, and we would particularly welcome the submission of sites to be considered for their potential to help meet the needs of our traveller communities.
Potential new sites for allocation – council-owned land
7.28 We are keen to investigate all potential sources of land available to us, and are undertaking a review of the council’s land holdings in order to identify whether any potential exists for new sites to be delivered from this source. In order to do so, we have undertaken an initial, high-level sift, based on general locational considerations and size thresholds, to remove parcels of land that we consider are unlikely to be appropriate for gypsy, traveller or travelling showpeople use.
7.29 The suitability of areas of land identified through this source will be determined using the site assessment methodology. It will also be important to consider the most appropriate use (either gypsy, traveller or travelling showpeople) for these sites in the round alongside the other potentially suitable sites we may identify through the sources described below. Once this has been done, we will be able to determine the potential capacity of each site, and the contribution that land identified from this source can make to meeting our needs will be determined using the site assessment methodology.
7.30 Any sites identified through our review of the council’s land holdings will be considered for their potential suitability for social rent provision, and opportunities to work with prospective delivery partners will be investigated as appropriate.
Potential new sites for allocation – traveller community owned land
7.31 Through engagement with our traveller communities, we will work to understand whether there is land in individuals’ ownership where potential exists for new sites to be delivered (as opposed to intensification on existing sites).
7.32 As set out above, the suitability of areas of land identified through this source and the potential capacity of each site will be determined using the site assessment methodology.
Other potential sources of supply
7.33 As set out above, it is important that we investigate all potential sources of land available to us at this stage. With this in mind, there may be sites that have been submitted as part of the HELAA process which do not form part of the emerging preferred strategy for homes and jobs, and which could potentially be taken forward for gypsy, traveller or travelling showpeople use. This part of our emerging strategy is being considered.
7.34 As set out above, through this consultation we are opening a Call for Sites for land to be considered for its potential for allocation to contribute to meeting our need for pitches and plots.
Contribution from strategic development sites
7.35 Our view is that the options identified above are the most likely to be successful in identifying potential new sites to meet the needs of our traveller communities. However, given the high level of need, we are also keen to explore the potential for provision to be made through the planning and delivery of the strategic allocations proposed through the new Local Plan.
7.36 This approach has previously been contested by representatives of the development sector through previous Local Plans in South Gloucestershire and also in other local planning authority areas. We do however consider that, in view of the level of need locally, and our need to consider all potential sources of land, it is appropriate to further explore this potential avenue.
7.37 To this end, we would welcome any suggestions for other sources of land we could consider as part of our emerging approach to meeting the needs of our communities.
7.38 Over a period of time, the council has developed a protocol, administered by the council’s Traveller Unit, for dealing with unauthorised encampments in South Gloucestershire. This approach is designed to recognise the need for a balance between the rights of gypsies and travellers, the rights of the general public to enjoy private and public land and the rights of landowners. Since this protocol has been in place, there has been a general downward trend in the number of unauthorised encampments.
7.39 As part of the brief for preparing our refreshed GTAA, we asked our consultants to consider this issue. They concluded that due to low numbers of short-term encampments, and that the majority are transient in nature, it was not considered that there is a need for a formal public transit site in South Gloucestershire at this time.
7.40 With this in mind, the GTAA recommends that, in the short-term, the council should continue to use its current approach when dealing with unauthorised encampments, and management-based approaches such as negotiated stopping agreements should continue to be considered. Consideration will be given to whether any of the sites identified are potentially suitable for negotiated stopping.
Safeguarding existing authorised sites
7.41 Through our new Local Plan, we are proposing an approach which is effectively a continuation of the council’s long-held position, set out in Core Strategy Policies CS21 and CS22, to safeguard its existing supply of authorised sites as long as there remains outstanding demonstrable need.
7.42 A number of existing authorised sites are within the Green Belt. Because of this, they are subject to restrictions to personal use only or have time limit conditions. In order to ensure they are safeguarded for use by future traveller families, we are proposing to remove them from the Green Belt. This approach is considered to be appropriate, owing to the need for sites in South Gloucestershire and the contribution these sites could make to future provision. Recent appeal decisions have indicated that this approach is appropriate.
7.43 National planning policy sets out that Green Belt boundaries should only be altered in exceptional circumstances. In the case of sites for traveller communities, the demonstrable level of need for sites is considered to provide the justification for this approach. This approach has been taken in local plan examinations in other local authority areas.
7.44 It is important to note that the allocation of sites for gypsy and traveller use is for the use of the land only. The number of pitches permitted on a site would remain as allowed by the existing planning permission. Any proposal for the intensification of use or change of use of these sites would need to be considered through a new planning application and considered against relevant local and national policies. No further intensification or development on the site could take place unless expressly permitted through the development management process.
7.45 The list of sites proposed for safeguarding can be viewed in the draft policies linked below.
Updated Local Plan policies
7.46 This consultation document contains draft policies that will set out the council’s approach to safeguarding existing authorised sites, and updated criteria which will be used to determine all planning applications for new provision.
7.47 Find out more and submit your comments on the draft policies:
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