Brighton & Hove City Council and the South Downs National Park Authority Gypsy & Traveller Site Assessments 2017 1. Introduction Background 1.1 This document describes the process and outcomes of a joint Gypsy & Traveller site assessment exercise undertaken by Brighton & Hove City Council (BHCC) and the South Downs Nation Park Authority (SDNPA). It has sought to identify potential sites for new traveller accommodation by undertaking a thorough and objective site search process. The study area consists of the geographic area of Brighton & Hove which includes part of the South Downs National Park. Planning functions are split between the two authorities. 1.2 BHCC and the SDNPA have previously undertaken a joint Gypsy, Traveller and Travelling Showpeople Accommodation Needs Assessment, which was published in November 2014. The primary purpose of that report was to provide an evidence base to inform the future development of planning policies through Local Plans. The assessment analysed need for additional traveller pitches as it stood in February 2014, and presented the projection of requirements for the following planning periods: 2013/14-2017/18: five years; 2018/19-2022/23: five years; and 2023/24-2027/28: five years 1.3 This study concluded that the need for new residential pitches in the area over the period to 2027/28, in addition to the 12 permanent pitches recently constructed at Horsdean, was as follows: Brighton & Hove SDNP LPA area of Travelling LPA area Brighton & Hove Showpeople Need Gypsy and (No. of plots) Gypsy and Traveller Need Traveller Need (No. of pitches) (No. of pitches) Current authorised residential/ 0 0 0 permanent provision (pitches) Residential need 2013/14 – 2017/18 15 8 0 (pitches) Residential need 2018/19 – 2022/23 2 2 0 (pitches) Residential need 2 3 0 2023/24 – 2027/28 (pitches) Residential need 2013/14 – 2027/28 19 13 0 (pitches) Table 1: Assessed need for new residential pitches in the area over the period to 2027/28 Purpose of this Assessment 1.4 The two authorities have undertaken a site search exercise to establish what extent of the need for new traveller pitches set out in the table above can be met through site allocations. This has taken the form of an examination of all potential land, a high level sieving exercise to remove sites with no potential and a more detailed examination of those sites that remained, including a detailed landscape assessment where this was identified as an issue on sites that had not been excluded for other reasons. The outcome of the process is a shortlist of one site that may have potential for development as a traveller site through allocation in the Brighton & Hove City Plan Part 2, subject to more detailed on-site examination. No sites were identified within the SDNP. 1.5 The shortlist does not form planning policy and no sites are yet allocated. Any proposals for development of a site would require a planning application to be submitted and the normal planning process to be followed. Policy Context 1.6 The study has used a criteria-led approach to guide the identification and assessment of sites. The criteria have been developed taking account of national and local policy, guidance and identified physical constraints. National policy 1.7 Planning Policy for Traveller Sites1 (PPTS) sets out national policy. It identifies the government’s aims in respect of traveller sites, which includes ensuring that local planning authorities, working collaboratively with their neighbours, develop fair and effective strategies to meet need through the identification of land for sites. It states that local planning authorities should set pitch targets for travellers which address the likely permanent and transit site accommodation needs of travellers in their area, working collaboratively with neighbouring local planning authorities. 1 www.gov.uk/government/uploads/system/uploads/attachment_data/file/457420/Final_planning _and_travellers_policy.pdf 1.8 Local planning authorities should, in producing their Local Plan identify and update annually, a supply of specific deliverable sites sufficient to provide 5 years’ worth of sites against their locally set targets. To be considered deliverable, sites should be available now, offer a suitable location for development, and be achievable with a realistic prospect that development will be delivered on the site within five years. 1.9 Local planning authorities should also identify a supply of specific, developable sites, or broad locations for growth, for years 6 to 10 and, where possible, for years 11-15. To be considered developable, sites should be in a suitable location for traveller site development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged 1.10 PPTS states that the overarching aim of Government is “to ensure fair and equal treatment for travellers, in a way that facilitates the traditional and nomadic way of life of travellers while respecting the interests of the settled community.” (para. 3). 1.11 As a consequence Local planning authorities should ensure that traveller sites are sustainable economically, socially and environmentally. Planning policies should: a) promote peaceful and integrated co-existence between the site and the local community; b) promote, in collaboration with commissioners of health services, access to appropriate health services; c) ensure that children can attend school on a regular basis; d) provide a settled base that reduces both the need for long-distance travelling and possible environmental damage caused by unauthorised encampment; e) provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there or on others as a result of new development; f) avoid placing undue pressure on local infrastructure and services; g) do not locate sites in areas at high risk of flooding, including functional floodplains, given the particular vulnerability of caravans; h) reflect the extent to which traditional lifestyles (whereby some travellers live and work from the same location thereby omitting many travel to work journeys) can contribute to sustainability. 1.12 Within this study area there is a need for residential traveller sites. Such sites provide residents with a permanent base from which they may travel. They may also have residents who have ceased to travel. These sites can be privately rented for affordable pitches, or privately owned. 1.13 Residential sites provide a base to travel from and the amount of facilities on site often varies between public and private sites. Public sites will generally have amenity blocks and sometimes play areas and communal spaces. Private site facilities vary depending on the requirements of the residents. Local Planning Policy 1.14 Policy CP22 of Brighton & Hove City Council (BHCC)’s City Plan Part One relates to Traveller Accommodation. The policy sets out how the council will seek to deliver 18 permanent pitches to meet assessed requirements to 2019 and will review needs to cover the remaining plan period to 2030. A number of considerations to be used in assessing the suitability of new traveller sites are included, and these have been taken into account in drawing up the assessment criteria set out in Table 3. 1.15 Emerging SDNPA planning policy is contained in the Preferred Options consultation document, published in September 2015. Policy SD26 of the document relates to Gypsies and Travellers and Travelling Showpeople. The policy safeguards existing traveller sites, supports the development of new provision to meet proven needs and sets out a number of development considerations, which are reflected in the assessment criteria in Table 3. The South Downs Local Plan will allocate land for Gypsy and Traveller sites where suitable sites are identified. 2 Approach and Methodology 2.1 The process undertaken in order to identify a short-list of potential locations for travellers’ sites is described below. The assessment followed an iterative three stage process. Stage 1 – Site Identification 2.2 The first stage identified all sites to be considered. Table 2 below sets out the types of sites identified at this stage of the process and the data source from which they were identified. Sites Data Source Locations of unauthorised traveller BHCC Traveller Liaison Team encampments, 2011 - 2016 Shortlisted sites from previous site BHCC Cabinet report (15 March 2012) search work setting out the selection process for a location for a permanent traveller site Sites assessed in the Urban Fringe Urban Fringe Assessment (Land Use Assessment that were considered to Consultants, 2014) commissioned by have potential for housing development Brighton & Hove City Council Sites identified through the scoping Public consultation summer 2016 (the consultation on the Brighton & Hove City consultation yielded no additional sites Plan Part 2. for consideration.) Call for Sites exercises SDNPA Local Plan Preferred Options 2016 (none were submitted in the BHCC area) Table 2: Sources of Data 2.3 Some sites were adjacent to each other or in very close proximity. Where considered appropriate, these sites were combined to simplify the assessment process. This led to a total of 90 sites being included on the ‘All Sites List’ taken forward to Stage 2. Appendix 1 lists all the sites identified. Stage 2 – ‘All Sites List’ Screening 2.4 The purpose of Stage 2: ‘All Sites List’ Screening was to consider all the identified sites from stage 1 against a number of absolute constraints. This enables those sites that did not meet basic site requirements or where it was clear that there is no realistic chance of the development of a traveller site occurring during the Plan period to be excluded from further consideration. This prevented unnecessary work and wasted resources being devoted to detailed analysis of sites that would have had no realistic prospect of being developed.