Object

Representation ID: 64545

Received: 09/05/2014

Respondent: Gallagher Estates

Agent: Pegasus Group

Duty to Cooperate:

Concerned that the Authority offers no evidence of when and how, as a District it will demonstrate cooperation on this matter given the strategic nature of it.

The Authority will undoubtedly need to demonstrate this in order for the Plan to progress to adoption.

The Duty to Cooperate is something that is engaged in respect of planning for the gypsy and traveller population whose needs are transient in nature and may well cross administrative boundaries. The very nature of the gypsy lifestyle presumably makes this a matter that needs to be looked at strategically over a wider area.

National Guidance:

[Having regard to the various requirements of national legislation and guidance in terms of meeting the accommodation needs of the general population and gypsies and travellers, and to identify and update annually a supply of specific deliverable sites sufficient to provide five years' worth of housing against their housing requirements] Gallagher Estates have noted the content of the Gypsy and Traveller Accommodation Assessment 2012 (March 2014) Preferred Options and the sites contained therein [and make the following comments]:

* The document has referenced the Gypsy and Traveller Accommodation Assessment 2012 in relation to the need to provide for 31 permanent pitches over a 15 year period, 25 of which need to be provided within the first 5 years of the plan period as a result of historic under provision.

* In terms of the number of pitches on each site, the document indicates that whilst Government advice had been that sites of between 5 and 15 pitches were the most appropriate, this advice has been amended such that the lower end of this scale is now recommended. In effect this therefore means that a larger number of sites, containing fewer pitches, is now required.

* The Council has outlined a range of criteria to which suitable sites should adhere to as closely as possible, and these are, in general terms, consistent with the Government's policy as set out at paragraph 11 of the PPTS.

* However, are also mindful of the need for sites to be 'deliverable' and 'developable', noting particularly that: "in order to be considered 'deliverable', sites should be available now, offer a suitable location for development now, and be achievable with a realistic prospect that housing will be delivered on the site within five years and in particular that development of the site is viable".

* Consider that the document should go further in respect of demonstrating deliverability of sites. Potential barriers have been identified in relation to a number of the Preferred Option sites that could potentially make it unviable for the provision of pitches, within the next five years.

* It is noted that the justification relating to the Preferred Options identified says that there is a risk that one or more of the preferred option sites will not be able to deliver the pitches proposed. It is recognised, as an example, that necessary on and off site infrastructure requirements may render some site unviable and therefore undeliverable.

* It is Gallagher Estates view that if a site does not meet with the Governments advice concerning deliverability, and is therefore not a realistically viable option, then it should not be classified as a Preferred Option. Such an approach would not be justified or effective, rendering any such allocation 'unsound.'

* Accordingly, the Pre Submission Draft version of the Plan necessarily needs to address this issue.