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Waverley Borough Council Committee System - Committee Document

Meeting of the Executive held on 02/10/2007
West Surrey Travellers Group - Response to Draft Options A & B August 2007



APPENDIX I
Waverley Borough Council

Environment AND LEISURE OVERVIEW AND SCRUTINY COMMITTEE
11TH sEPTEMBER 2007
EXECUTIVE – 2ND OCTOBER 2007

Title:
GYPSY & TRAVELLER ACCOMMODATION – AGREEMENT OF OPTION A & B FIGURES AND OTHER DETAILS FOR SUBMISSION TO SEERA
[Wards Affected: All]

Summary and purpose:

This report, which was considered by the Environment and Leisure Overview and Scrutiny Committee at its meeting on 11th September, is to seek Members’ views on the Gypsy and Traveller accommodation needs information which is required by the South East England Regional Agency (SEERA) as part of the Partial Review of the South East Plan. Local authorities have been asked to provide information to SEERA which will help facilitate the allocation of pitches across the South East to meet identified need. In preparing this advice, local authorities are to have regard to current and forecast needs and the existence of any backlog of unmet need. The information will be sent to SEERA in two Options, as outlined later in this report.

This report follows on from an Executive Briefing on 17th May 2007 when information was provided regarding the Gypsy and Traveller Accommodation Assessment (GTAA) and the associated Option A figures for the number of pitches required. This report focuses on the development of both the Option A and Option B figures, and other details required by SEERA
_________________________________________________________________________
Environmental implications:

There are environmental implications arising from the provision of additional sites/pitches. However, these can only be properly assessed at the stage when the Council is considering potential locations for such developments. This is something that will need to be addressed as part of the Council’s Local Development Framework once the partial review of the South East Plan has been completed and the Council knows how many additional pitches are required.

Social / community implications:

There are social/community implications arising from the provision of additional sites/pitches. However, these can only be properly assessed at the stage when the Council is considering potential locations for such developments. This is something that will need to be addressed as part of the Council’s Local Development Framework once the partial review of the South East Plan has been completed and the Council knows how many additional pitches are required.

E-Government implications:

There are no E-Government implications.

Resource and legal implications:

There are resource implications arising both from the on-going work of the West Surrey Group and the work required to address this issue through the Local Development Framework. It is not possible, at this stage, to identify any financial/resource implications in relation to specific sites. These will need to be assessed at the stage when implementation is required.
________________________________________________________________________
Introduction

1. In February 2006 the Government published Circular 01/2006: “Planning for Gypsy and Traveller Caravan Sites”. It states that the Regional Spatial Strategy (RSS) should take a strategic view on the accommodation needs of Gypsies and Travellers and should identify the number of additional pitches required for each local authority. As a result, SEERA has embarked on a partial review of the South East Plan in order to address the issue.

2. The process for the programme for this partial review requires local authorities to submit the necessary information to SEERA by 15th October.

Background

3. Provision of Gypsy and Traveller sites in Waverley is currently met through a number of sites throughout the borough, with a total number of 91 pitches on Gypsy sites and 6 pitches on Travelling Showpeople sites. The table below identifies the current provision for Gypsy sites:

Site ManagementPitchesCaravans
Hill Tops, AlfoldPrivate35
New Acres, AlfoldPrivate3550
Lydia Park, BramleyPrivate2259
Rushett Common, BramleyPrivate13
Burnt Hill, DunsfoldPrivate1010
Borough Farm Road, MilfordPrivate24
Rodborough Common, MilfordPrivate612
RunfoldSCC1020
Bridge View, RunfoldPrivate16
Tongham Road, RunfoldPrivate12

4. The table below identifies the current provision for Travelling Showpeople sites:

Site ManagementPitchesCaravans
Burnt Hill, DunsfoldPrivate510
Old Brickyard, HambledonPrivate11

The Gypsy and Traveller Accommodation Assessment (GTAA)

5. Circular 01/2006 also requires Local Planning Authorities (LPAs) to undertake a Gypsy and Traveller Accommodation Assessment (GTAA) to assess the needs of the Gypsy and Traveller community within their area.

6. In Surrey three groups of Local Authorities have undertaken GTAAs. Waverley,together with Surrey Heath and Guildford Boroughs, commissioned David Couttie Associates (DCA) to undertake a study of the Gypsy and Traveller accommodation needs in these three Boroughs. A methodology for undertaking GTAA’s is set out in the Government guidance: ‘Gypsy and Traveller Accommodation Assessments – Draft Practice Guidance’ 2006. The final report has now been received, which has identified pitch requirements for all three boroughs. Officers consider the methodology used to be sound, and that the final report provides a robust and credible statement of pitch requirements in the Borough.

7. A total of 144 interviews were completed by DCA, including 25 in bricks and mortar accommodation, 92 on permanent authorised sites and 10 on authorised sites and 17 with Showpeople households. Every householder, who lived within any of the three Boroughs that wished to be interviewed, was accommodated. The fieldwork for the study took place between Monday 6th November and Saturday 18th November 2006. The response rate on authorised sites was 55.8% and 47.6% on unauthorised encampments and developments, this represents a reasonable rate of response. A number of topic areas were covered in the survey work, including:
Current accommodation circumstances
How well sites meet the needs of Households
Future accommodation needs
Views on ideal sites
The need of Showperson Households, and
The needs of those in bricks and mortar accommodation

8. A significant level of need emerged from the study for additional new pitches for a number of reasons. There is a low turnover of pitches on current authorised Local Authority sites and a low level of new pitches approved through the planning system each year. There are waiting lists for sites across the study area and there is a backlog of need from households currently living on unauthorised developments or encampments within the study area. Gypsy and Traveller households are leaving the area because of a lack of authorised site provision locally, and 21.8% of households are living in overcrowded accommodation with a backlog of concealed households seeking independent accommodation within the area. New family formation at a rate of 5.9% per year is likely to continue adding pressure to demand.

Options relating to the number of pitches

9. SEERA will allocate the number of pitches required for each Local Authority within the Partial Review of the South East Plan, taking into account the information provided by each Local Planning Authority this autumn and the outcomes of a regional ‘benchmarking’ exercise (to ensure consistency between all the Local Planning Authority information and Gypsy and Traveller Accommodation Assessments). SEERA will follow the advice of the department for Communities and Local Government (CLG), set out in ‘Preparing Regional Spatial Strategy reviews on Gypsies and Travellers by Regional Planning Bodies’.

10. SEERA require 2 ‘options’ (numerical distributions) in order to undertake a sustainability appraisal. It will be SEERA that ultimately determine the preferred option, on which it proposes to consult between May and August 2008. The two options considered in this report are:-

Option A – a distribution (of pitches) which seeks to meet identified needs where they arise as identified through the Gypsy and Traveller Accommodation Assessments (GTAA’s) and the existence of unauthorised encampments.

Option B – a distribution which seeks to protect and enhance the natural environment, including its biodiversity and landscape character whilst making best use of previously developed land and existing or planned infrastructure provision; and facilitates access to employment opportunities and local services to support social inclusion.

Option A Figures

11. Option A draws on the needs identified through the GTAA and the existence of unauthorised encampments. The report produced by DCA has outlined a need for 86 households to be accommodated on new permanent site pitches between 2006-2011 to deal with the backlog of demand existing within the study area and to meet emerging demand from new family formation. Within this figure of 86, it has been identified that the requirement for Waverley is a total of 37 pitches (see table 1 below). A need for 27 households on Showpeople sites has also been identified, with a breakdown of 2 in Waverley, 15 in Guildford and 10 in Surrey Heath.

Table 1 - Pitch requirement by District 2006 – 2011
DistrictPitch Requirement
Waverley37
Guildford30
Surrey Heath19
Total86

Option B Figures

12. A second numerical distribution, Option B, is also required. This seeks to protect and enhance the natural environment, including its biodiversity and landscape character, whilst making the best use of previously developed land and existing or planned infrastructure provision, and facilitating access to employment opportunities and local services to support social inclusion.

13. Officers from the three West Surrey authorities have worked together to utilise the methodology developed by the East Surrey grouping of authorities to prepare Option B. The final version is presented in Table 2 below. Table 3 provides a breakdown of the environmental constraints affecting each borough. Particular care was given to critical appraisal of the methodology as Option B developed, to ensure an appropriate balance of consistency with the East Surrey methodology and refinement of the approach, to strengthen the Councils ability to defend the options should these be tested at examination during later stages of this South East Plan Partial Review.

14. All three local authorities in the West Surrey grouping face significant environmental and policy constraints on land within their boroughs, affecting the capacity of each to accommodate Gypsy and Traveller pitch allocations. The government guidance focuses on a checklist of absolute environmental - rather than policy - constraints, allowing only those which physically prohibit development to be acknowledged: for instance, Special Protection Areas (and buffer zone), Flood Risk Areas (Zones 3a & 3b), Special Areas of Conservation (SAC), Historic Parks and Gardens, Scheduled Ancient Monuments, Areas of Archaeological Importance, Sites of Special Scientific Interest and Best and Most Versatile Agricultural Land.

15. Strategic policy designations, such as Green Belt, could not be factored into the methodology, although Green Belt is shown in Table 3 for information purposes; national planning guidance recognises any consideration of Green Belt sites will be as part of a sequential approach focusing first on development on previously developed land. Local designations are similarly precluded: Areas of Great Landscape Value, Conservation Areas, Strategic Gaps (such as the Blackwater Valley), Areas of High Archaeological Potential, safeguarded open spaces and Countryside beyond the Green Belt. Following these guidelines, and taking into consideration all relevant constraints affecting Waverley Borough, Option B shows a total of 37 Gypsy and Traveller pitches required within Waverley Borough 2006-2011.

16. Option B was also considered at the West Surrey Stakeholder Group meeting on 16th July. The Group comprises representatives from the three local authorities, together with representatives from Surrey County Council, the police, parish councils and the travelling community. The Group discussed and agreed Option B. The joint submission to SEERA regarding Option B will include comments on the factors taken into account in arriving at the Option B distribution. 17. Copies of the draft Options A & B plus extracts from the GTAA have been sent to targeted additional stakeholders for comment. The consultation period finished at the end of August. Attached as Annexe 1 is a schedule of responses to this consultation, together with officer comments compiled on behalf of the three authorities.

Table 2 – Option B numerical distribution of pitch numbers
Waverley
Guildford
Surrey Heath
Option A distribution
37
30
19
Percentage of land not covered by environmental constraints* (includes urban areas)
30%

2
20%

1
60%

3
Total area of the borough
34516 ha
3
27020 ha
2
9507 ha
0
Amount of previously developed land (PDL) based on 2001 population
115,665

2
129,000

2
80,309

1
Infrastructure based on no. of dwellings per annum in draft South East Plan
230 pa

2
322 pa

3
187 pa

1
Existing distribution of pitches
48%
(90 pitches – 85 authorised)
3
32%
(60 pitches – 56 authorised)
2
20%
(30 pitches – 30 authorised)
1
Total ‘score’
12
10
6
% of pitch provision
43%
36%
21%
Option B distribution
37
31
18

* Special Protection Areas (SPA), Special Area of Conservation (SAC), Sites of Special Scientific Interest (SSSI’s), National Nature Reserves (NNR’s), Areas of Outstanding Natural Beauty (AONB), Flood Zones 3a & 3b, and best and most versatile agricultural land (Grades 1, 2 and 3 of the Agricultural Land Classification).

Table 3 - Breakdown of environmental constraints affecting each borough
Waverley
Guildford
Surrey Heath
Total area of the borough:

Natural environmental constraints (% of total district area unless otherwise stated):*

SPA
SAC
SSSI’s
NNR’s
AONB
Flood Plain
Agricultural Land Grade 1,2 & 3 (Defra)

Green Belt (for information only)


Total area of the borough covered by natural environmental constraints (excluding Green Belt):*

Area of the borough not covered by natural environmental constraints (approx).
34516 ha







1% (345 ha)
No data
8% (2761 ha)
No data
53% (18293 ha)
5% (1726 ha)
45% (15,541 ha)



61% (21055 ha)


70%
(24161 ha)



10355 ha
27020 ha







7% (1891 ha)
No data
9% (2432 ha)
No data
37% (9997 ha)
3% (811 ha)
42% (11,382 ha)



89%
(24048 ha)


80%
(21616 ha)




5404 ha
9507 ha







23% (2164 ha)
16% (1533 ha)
23% (2172 ha)
No data
No data
7% (622 ha)
8% (754 ha)



No data



40%
(3803 ha)




5704 ha

Projected Need 2011 – 2016

18. Options A and B above show the number of pitches required within the borough for the period 2006-2011 (working from the 2006 baseline of the GTAA). The South East Plan Partial Review is committed to cover the period 2006-2016. SEERA therefore requires additional data for the period to 2016.

19. Following a the guidance set out in the CLG methodology, which involves the application of a 3% compound rate, the Gypsy and Traveller need for 2006-2011 has been projected forward, year-on-year, to address the period 2011-2016. Tables 4 and 5 show the resulting compound figures for Options A and B, respectively. The need for the next five-year plan period (2006-2011) is considerably larger than for the period 2011-2016, in part because no new provision has been planned in the three boroughs since 1994.

20. The GTAA will need to be repeated in five years time (2011), to provide robust data for future Waverley Local Development Framework preparation.


Table 4 – Projected Option A Distribution (Compound Figures) 2011-2016
Period
Waverley
Guildford
Surrey Heath
2006 – 2011
37
30
19
2011 – 2012
38
31
19.5
2012 – 2013
39
32
20
2013 – 2014
40
33
20.5
2014 – 2015
41
34
21
2015 – 2016
42
35
21.5
Total increase 2011 – 2016
5
5
2.5
Total increase 2006 - 2016
42
35
21.5

Table 5 - Projected Option B Distribution (Compound Figures) 2011-2016
Period
Waverley
Guildford
Surrey Heath
2006 – 2011
37
31
18
2011 – 2012
38
32
18.5
2012 – 2013
39
33
19
2013 – 2014
40
34
19.5
2014 – 2015
41
35
20
2015 – 2016
42
36
20.5
Total increase 2011 – 2016
5
6
2.5
Total increase 2006 - 2016
42
36
20.5

Travelling Showpeople

2006-2009 Data
21. SEERA has recently clarified its requirements regarding the submission of data relating to Travelling Showpeople. The GTAA has identified that there is a need for 2 Travelling Showpeople pitches in Waverley borough during the period 2006-2009, alongside a further 15 pitches in Guildford and 10 in Surrey Heath (total 27 pitches). This information will also need to be presented to SEERA although separate Options A & B are not required for the Travelling Showpeople data as for the Gypsy and Traveller data. It is understood that Surrey Heath has not accepted the GTAA findings in relation to the number of pitches required for Travelling Showpeople in its area.

Projected Need 2009-2016

22. Although the GTAA identifies needs regarding Travelling Showpeople to 2009, it is not considered that there is sufficient evidence on which to base an assessment of future needs. It is considered that SEERA will need to work with the Travellling Showmen’s Guild to establish a growth figure to be applied across the South East.


Other Information Required by SEERA

23. The statement of information which each Local Authority must submit to SEERA encompasses a range of information, including the GTAA study itself and final Options A and B:

Specific data on existing Gypsy and Traveller Caravan Sites including location, ownership, type and size [this information has already been submitted, in time for SEERA’s deadline of 30 April 2007]; Individual caravan pitch requirements for each Local Authority, including Travelling Showpeople requirements; Two spatial options (Options A and B) for the distribution of pitches between County, GTAA or other appropriate groupings of authorities [including Travelling Showpeople]; Qualitative assessment of the demand for and type of transit sites – broadly allocate transit sites where there is a clear need; Advice on implementation and delivery issues – costs and potential funding sources, site location criteria, public and private site split, Local Development Document timetable, type of facility required, management of pitches, the implications of site size on an area; The relevant GTAAs and any other evidence used to inform the advice submitted; An explanation of how key stakeholders have been involved in the GTAA and subsequent processes leading up to the submission of advice. This will be a factual timetable setting out the programme of stakeholder involvement to date.

24. With regard to point 4 above, the GTAA does not provide evidence for additional transit provision locally.

25. Joint working continues amongst officers of the West Surrey Group of authorities to collate this information, much of which is factual and will be taken through the respective committee processes of each authority. It may not, however, be possible to provide all of the information sought at this time. For example, the information required in point 5 above, relating to implementation and delivery issues. The reasons for this are varied; Annexe 2 explains these in summary form, taking into account points from the discussion of the Stakeholder Group on 16th July. Care will be taken to explain in the covering letter to SEERA that the Group would wish to help provide information on these points but that for reasons set out it is not possible to do so at this early stage.

26. SEERA has invited comments on the benchmarking of the various GTAAs. It is considered that the response on behalf of the three authorities should point out that the benchmarking work to date has found that the West Surrey GTAA is robust and, if anything, slightly over-estimates the requirement in West Surrey, compared to the formula used in the benchmarking exercise. (This suggests a need for 75 pitches compared to the 86 identified in the GTAA). In other areas the equivalent benchmarking indicates that some GTAAs may have under-estimated the need.

27. SEERA has also invited comments on “any other distribution of pitches”. Although the officers are not proposing to put forward specific alternatives to Options A & B, it is considered that attention should be drawn to the benchmarking that shows that the West Surrey GTAA is robust (see above). In addition, it is considered that SEERA should be reminded that the current methodology reinforces the existing distributions and places no requirement on those authorities that are currently failing to do so. SEERA should also be reminded that when the Council considered the draft South East Plan in June last year, part of its response was to point out that Waverley is home to about a third of Surrey’s gypsies and that the Council did not believe that it should be the focus for the provision of additional sites to meet regional needs.

Submission of Information to SEERA

28. Options A and B, the information on Travelling Showpeople and other relevant details, will be considered by the Executive on 2nd October, in order for the final response to SEERA to be put together to meet the deadline of 15th October.

29. Once the information has been submitted, SEERA will check the data for consistency (‘benchmarking’) and will consider the distribution of pitches throughout the region and consult on the options from 15 May to 7 August 2008. SEERA aim to submit the South East Plan Partial Review to the Government Office of the South East (GOSE) in December 2008 and adopt the document in 2009.

30. Running parallel with this work, West Surrey Group officers are also participating in regular county-wide meetings, organised by the Surrey Traveller Co-ordinator. These provide a forum to secure greater consistency of approach across the county and highlight actions the West Surrey Group might need to pursue.

Conclusion

31. Members will note the timetable and tasks that continue to be progressed to complete preparation of the information for SEERA. The three boroughs of Waverley, Guildford and Surrey Heath will continue to work together to finalise the submission statement for both Gypsy and Travellers and Travelling Showpeople need in West Surrey.

Environment and Leisure Overview and Scrutiny Committee

32. The Environment and Leisure Overview and Scrutiny Committee had the following observations to make:

Recommendation

That the Executive:

Background Papers (DP&D)

The West Surrey Gypsy and Traveller Accommodation Assessment 2006
Presentation to West Surrey Stakeholders Group, 16 July 2007

CONTACT OFFICER:

Name: Graham Parrott Telephone: 01483 523472
E-mail: gparrott@waverley.gov.uk






comms\executive\2007-08\084v.2 gypsies 021007.doc
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ANNEXE 2
(5) Advice on Additional Implementation and Delivery Issues

SEERA request six separate pieces of information under this heading:

(5.1) Advice on the cost and type of facilities required
Suggested response:
Further guidance is required from SEERA in order to reply helpfully to the question.
Irrespective of the cost of land, building a site will depend on the infrastructure available;
There is a need for investment to update existing facilities in addition to construction of new sites.
New sites should have the benefit of energy efficiency measures and similar, in the same way as affordable housing developments for the settled community. (5.2) Estimated implementation costs for proposed level of provision and potential sources of funding
Suggested response:
Implementation costs cannot be estimated at this early stage in the process;
Government funding will be crucial to the achievement and delivery of sites to accommodate the needs identified;
Past difficulties must be acknowledged by the Government – it is understood that even 75% government funding has not been taken up by local authorities in the past because of an inability to fund the 25% shortfall. SEERA needs to raise this at a higher level;
Use of Section 106 contributions for the provision of new Gypsy and Traveller pitches will be difficult to achieve given the needs test specified in Circular 5/05 (Planning Obligations).

(5.3) Responsibilities for delivery and management of pitches (by type) including the special role of landlords
Suggested response:
The main responsibility for delivery will lie with each borough, in particular the Planning, Housing and Environmental Services. Delivery will also be dependant to a certain extent on the Gypsies and Travellers putting forward suitable private sites and securing planning permission. Each of the districts is at a different stage in preparing its LDF, which will be crucial in translating the identified need into delivery through the identification of sites where necessary.

(5.4) Anticipated timing of preparation of relevant LDD documents setting out site allocations for Gypsy and Traveller caravan pitches

Stage
Waverley
Guildford
Surrey Heath
Early Stakeholder involvement and community
To be reviewed
Nov 2006 – May 2007
To be reviewed
Consultation on Issues and Options
To be reviewed
Nov 2007 – Jan 2008
Preferred Options
Public Consultation (6 Weeks)
To be reviewed
Jan – Feb 2009
Independent Examination
To be reviewed
May 2010
Adoption by Council
To be reviewed
Feb 2011

(5.5) Advice on the strategic site location criteria which the Regional Spatial Strategy should include to inform the preparation of relevant Local Development Documents
Suggested response:
The requirements of this question are unclear;
South East Plan does not include criteria, only explains that this Partial Review will take place;
There is reference in national guidance in both Circular 01/2006 and the draft circular on Travelling Showpeople and in CLG’s guidance to regional planning bodies on preparing regional reviews of Gypsy and Traveller accommodation to five basic planning principles which might bear upon deliberations about pitch allocations. These are: Sustainability; Equity and Choice; Social Inclusion; Environmental protection; Need for flexibility of provision.
Option B takes these constraints into account.

(5.6) Anticipated split between public and private provision of pitches
Suggested response:
Exact details are not known at this early stage of the process;
Waverley – anticipate further private sites in the future. There is likely to be capacity within existing sites to accommodate a proportion of the 2006-2011 needs for Waverley borough.
Guildford – a significant proportion of pitches within Guildford are likely to be private;
Surrey Heath – as an approximate indication Surrey Heath consider that a large proportion of the pitches provided will be socially rented;

(5.7) The implications of the diversity of the Gypsy and Traveller population in an area for the appropriate size and number of caravan sites
Suggested response:
This has not been identified as an issue in the West Surrey Area.