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TORFAEN GYPSY AND TRAVELLER STUDY Identification of Permanent Gypsy and Traveller Sites: General Approach Report October 2009 Client: Torfaen County Borough Council Report By: Philip Costa MRTPI Our Ref: WPC/29/015 Date: October 2009

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Page 1: TORFAEN GYPSY AND TRAVELLER STUDY · Torfaen Gypsy and Traveller Study Identification of Permanent Gypsy and Traveller Sites - General Approach Report inform the development of policy

TORFAEN GYPSY AND TRAVELLER STUDY

Identification of Permanent Gypsy and Traveller Sites: General Approach Report October 2009

Client: Torfaen County Borough Council

Report By: Philip Costa MRTPI

Our Ref: WPC/29/015 Date: October 2009

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Torfaen Gypsy and Traveller Study Identification of Permanent Gypsy and Traveller Sites - General Approach Report

CDN Planning (Wales) Ltd Suite SF1, Ethos Kings Road SA1 Swansea Waterfront Swansea SA1 8AS t. 01792 830238 f. 01792 863895 e. [email protected] w. www.cdnplanning.com

Report Title: Torfaen Gypsy and Traveller Study: Identification of Permanent

Gypsy and Traveller Site(s) - General Approach Report Client: Torfaen County Borough Council File Location: F:\Jobs - Folders\2009\2009-015 - Torfaen

CBC\Correspondence\Stage 4 - Report\Torafen Gypsy-Traveller Study - General Approach - Oct09.doc

Draft Report Issued: July 2009 Final Report Issued: October 2009 Prepared By: WPC Checked By: KD © The contents of this document must not be copied or reproduced in whole or in part without the written consent of CDN Planning Ltd. All plans are reproduced from the Ordinance Survey Map with the permission of the Controller HMSO, Crown Copyright Reserved, Licence No. 100020449

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Torfaen Gypsy and Traveller Study Identification of Permanent Gypsy and Traveller Sites - General Approach Report

CONTENTS 1 Introduction and Experience Page 3

2 Government Guidance Page 5

3 Consultation Page 12

4 Existing Provision Page 19

5 Identified Need Page 22

6 Proposed Site Selection Methodology Page 29

7 Criteria-Based Policy Page 43

8 Conclusions Page 48

Appendix A Proposed Scoring Matrix Page 50

Appendix B Suggested Site Identification / Assessment Template Page 58

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1 INTRODUCTION AND EXPERIENCE 1.1 In February 2009 Torfaen County Borough Council commissioned CDN Planning to

identify and assess a number of potential site options for new suitable Gypsy and

Traveller sites to meet the accommodation needs within the County Borough. The

main purpose of this report is to outline the general approach and methodology

proposed for the identification of suitable potential sites for Gypsy and Traveller

accommodation in a Site Options Report; which is anticipated in mid 2011 following

the completion of the Council’s own study on the future of their Shepherds Hill Gypsy

& Traveller Site in Pontypool.

1.2 This General Approach Report will broadly quantify the need for additional gypsy and

traveller pitches within the County Borough, following a review of the only Council-

owned site at Shepherds Hill and other sites within Torfaen.

1.3 A need for a transit site has also been identified; however this will need to be

assessed further in consultation with neighbouring authorities. The future Site

Options Report will identify a number of sites that might be suitable to meet transit

need. Alternatively, it might be feasible to provide a level of visitor/transit pitches

within existing and new permanent Gypsy and Traveller sites.

1.3 In order to identify suitable potential sites for Gypsy and Traveller pitches, CDN

Planning has used a three-tier site identification and assessment that has been

applied and developed over a number of years in assessing and identifying suitable

sites in areas of South Wales and England.

1.4 In 2003-04 CDN Planning applied its three-tier approach to site selection and

assessment when identifying site options for a new permanent Gypsy and Traveller

site for Colchester Borough Council. The methodology used was called before a

scrutiny committee and after a thorough investigation it was concluded to be a fair,

robust and sound planning-based methodology.

1.5 Subsequently the approach has been expanded to meet the requirements of

Government guidance relating to Gypsy and Traveller site identification and design,

including Welsh Assembly Government (WAG) Circular 30/2007 “Planning for Gypsy

and Traveller Caravan Sites” and WAG’s “Good Practice Guide in Designing Gypsy

Traveller Sites in Wales” (July 2009). Of relevance is also the Department for

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Communities and Local Government’s “Designing Gypsy and Traveller Sites - Good

Practice Guide” (2008).

1.7 The methodology also takes account of guidance relating to sustainable development

provided in the Code for Sustainable Homes and its predecessor BRE EcoHomes.

Access requirements are set out in adopted and emerging local policy and guidance,

including Manual for Streets and TAN18: Transport.

1.8 Building on CDN Planning’s experience in Colchester and the requirements of the

above guidance, a revised three-tier approach was used to assist Derby City Council

in undertaking a review of its short-list of site options for a new permanent Gypsy and

Traveller site. Using the methodology as outlined in Section 6 of this report, CDN

Planning identified a list of top performing sites. Ultimately a site within a built-up

residential area was selected, near to where the local Gypsy and Traveller community

had settled on an unauthorised encampment. Due to the relatively small size of the

site, the Project Team identified the essential facilities required (summarised in

Section 2.5 of this report) to ensure a high standard of design, allow for a high quality

of life within the site, and produce a scheme with a long lifespan and manageable

maintenance costs.

1.9 In 2008 CDN Planning was approached to undertake a study on behalf of Vale Royal

Borough Council to identify a number of site options for new Gypsy and Traveller

accommodation. Through the RSS process, a need for 7 to 10 pitches was identified.

CDN Planning used its three-tiered approach to identify approximately 15 site options

whereby three were taken out to public consultation.

1.10 CDN Planning has also used its site assessment methodology to help defend

Pembrokeshire Coast National Park Authority’s decision to refuse planning

permission for a new Gypsy and Traveller site at a planning inquiry.

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2 GOVERNMENT GUIDANCE

2.1 Policy Context 2.1.1 The Welsh Assembly Government’s Circular 30/2007 “Planning for Gypsy and

Traveller Caravan Sites” contains Government’s most recent advice on identifying

new sites for Gypsy and Traveller accommodation. The Circular provides updated

guidance on the planning aspects of finding sustainable sites for Gypsies and

Travellers and how local authorities and Gypsies and Travellers can work together to

achieve this aim. WAG Circular 30/2007 supersedes advice contained in Circular

2/94 “Gypsy Sites and Planning”.

2.1.2 For the purposes of this study, the definition of Gypsies and Travellers outlined in

WAG Circular 30/2007 is used, which identifies Gypsy and Travellers as:

“… persons of nomadic habit of life whatever their race or origin, including such

persons who on grounds only of their own or their family’s or dependants’ educational

or health needs or old age have ceased to travel temporarily or permanently, but

excluding members of an organised group of travelling show people or circus people

travelling together as such.”

2.1.3 For the purpose of this study, the only accommodation needs of Gypsies and

Travellers will be addressed and not those of New Aged Travellers or Travelling

Showpeople. Many Gypsies and Travellers pursue an active itinerant lifestyle and

are generally self-employed, sometimes occupied in scrap-metal dealing, laying

tarmac, seasonal agricultural work, casual labouring, and other employment.

However, these traditional patterns are changing whereby the community has

become increasingly settled.

2.1.4 It is often generalised that Gypsies and Travellers are a uniform, cohesive

community, however the reality is they are a diverse group of communities which

share some features but have their own histories and traditions. There is often

fragmentation between different families and between cultural groups. The main

cultural groups include Romany Gypsies, Irish Travellers, and New Travellers. Only

Romany Gypsies and Irish Travellers are recognised in law as distinct ethnic groups

and are legally protected from discrimination under the Race Relations Acts.

2.1.5 Pat Niner of the Centre for Urban and Regional Studies at the University of

Birmingham carried out research on behalf of the Welsh Assembly Government to

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inform the development of policy as it relates to the accommodation needs of Gypsies

and Travellers in Wales. (“Accommodation Needs of Gypsy-Travellers in Wales”,

2006). The report provides updated information on the following:

- the number, size and condition of existing permanent and temporary Gypsy and

Traveller sites in Wales;

- the extent and location of unauthorised encampments;

- whether the number of places on existing authorised sites is sufficient to meet the

present and likely future levels of demand for accommodation;

- the need for new site provision - permanent, transit and stopping places - with the

estimated costs of providing such facilities;

- the obstacles to new site development and how they can be overcome;

- the contribution of the planning system to the provision of Gypsy and Traveller

sites/accommodation; and

- good practice in site provision, management and design.

2.1.6 WAG Circular 30/2007 and the Pat Niner report have been the key guidance

documents that have informed the methodology outlined in this document for the

identification and assessment of potential sites for new Gypsy and Traveller

accommodation in the County Borough.

2.1.7 WAG Circular 30/2007 also highlights the need to involve the Gypsy and Traveller

community directly to ascertain their accommodation needs, along with their

representative bodies and local support groups and other relevant stakeholders. This

consultation should include encouraging Gypsies and Travellers to put forward

candidate sites as part of the LDP preparation process.

2.1.8 The Council has undertaken on-going consultation with the Gypsy and Traveller

community in order to assess the current need for additional pitches within the

County Borough. This on-going assessment, along with new consultations

undertaken by the study team will help to determine the unmet need for Gypsy and

Traveller accommodation in the County Borough and identify site-specific needs of

the community. Section 5 of this report details the anticipated need for additional

Gypsy and Traveller pitches over the Local Development Plan period.

2.1.9 One of the key intentions of WAG Circular 30/2007 is to create and support

sustainable, respectful, and inclusive communities where Gypsies and Travellers

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have fair access to suitable accommodation, education, health, and welfare provision.

The Circular states “local planning authorities should first consider locations in or near

existing settlements with access to local services.” WAG Circular 30/2007 also

requires that all potential sites must have their social, environmental and economic

impacts assessed in accordance with the requirements of Sustainability Appraisal, as

outlined in Section 3 of the LDP Manual (WAG 2006).

2.1.10 As part of the Local Development Plan process, it is necessary to formulate a criteria-

based policy to guide the identification of potentially suitable sites for Gypsy and

Traveller accommodation and assist Officers with the determination of future

proposals. A proposed policy is included in Section 7 of this report and is based on

the key principles of the three-tiered site selection and assessment methodology

outlined in Section 6.

2.2 Site Location 2.2.1 Potential sites for Gypsy and Traveller use should not be considered in areas

deemed to be inappropriate for residential use, either private or social. WAG

guidance on site design states that a Gypsy and Traveller site “should receive the

same considerations as other forms of accommodation and should not be located in

areas which will have a detrimental effect on the general health and well being of the

residents.” Sites should have adequate access to services such as health and

education and shopping facilities.

2.2.2 It is necessary to identify a range of locations for potential sites, including sites in

built-up areas, areas on the outskirts of built-up areas, rural or semi-rural locations,

and previously developed (brownfield) or derelict land. All suitable sites should be

considered appropriate in principle provided there is no specific planning or other

constraints limiting the development of these sites.

2.2.3 Sites within Torfaen’s Green Wedges would generally be inappropriate and all

alternatives should be fully explored before Green Belt or Green Wedge locations are

considered.

2.2.4 Potential sites should not be located near refuse sites or facilities, general (B2 use)

industrial locations and other hazardous locations such as motorway flyovers. Table

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1 below outlines the considerations contained in the Welsh Assembly’s “Designing

Gypsy and Traveller Sites - Good Practice Guide”.

TABLE 1: Site Considerations

Accessibility A site should have good access to a public road which is safe and direct.

The Site Land should be flat and suitable for development as planned. A site survey must be undertaken which will identify possible problems such as water logging, risk of flooding, landfill contamination etc. It is acknowledged that a shortfall of suitable land may increase the probability of a new site being situated on land with previous occurrences of flooding. Where such a piece of land is being considered for a new site, as with other potential risks, residents and potential residents should be made aware of these risks.

Local Services A site should be located within reasonable distance from school, shops, medical services and other community facilities. Certainly a site should not be more than 3 miles from any of these in less rural areas. If a site is located or going to be located in a rural area this will in many situations not be achievable.

Environment The location of a site should always be in acceptable surroundings or where the surroundings can be made pleasant at a reasonable cost. Sensitive landscaping and boundary definition should be able to provide seclusion for the residents from the elements without making them feel imprisoned in the site.

On site services Water, electricity, sewage, drainage and refuse disposal should be provided on all sites.

2.5 Site and Size Requirements 2.5.1 WAG Circular 30/2007 does not recommend standards for site size, it asserts:

“It is not considered appropriate to set a national maximum size for a site, but sites

should be considered in their context and in relation to the local infrastructure and

population size and density to ensure they do not dominate local settled

communities.”

2.5.2 However, WAG’s “Designing Gypsy and Traveller Sites - Good Practice Guide”

states:

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“The ideal size of a site should generally be no more than 12 pitches. Consultation

with the Gypsy and Travelling community has shown that there is a preference for

smaller sites, around 10-12 pitches.”

2.5.3 WAG Circular 30/2007 states: “Sites should respect the scale of and not to be so

large as to dominate the nearest settled community serving them.” It is therefore

sensible and reasonable to follow this guidance whereby the concentration of sites

should be avoided. Any impacts on the amenity of existing local residents and

services must be minimised.

2.5.4 Having considered the size of each settlement in the County Borough, and based on

experience working with other Authorities, there is a general consensus that smaller,

family sites work best. This size of site tends to ‘work better’ by allowing for better

maintenance, management, and control. Due to family expansion and visiting

relatives/friends and other site needs, it may be necessary to expand sizes. It is

recommended that sites should be no more than 15 to 20 pitches in size; however

proposals for a larger number of pitches should be considered on their merits

regardless of site size.

2.5.5 It may be necessary to allow for some flexibility in the number of pitches to account

for local circumstances. Sites should presume to be no bigger than between 15-20

pitches to allow for family growth for example or whereby larger sites are necessary

where there is a clear and demonstrable reason to act against such a presumption.

In all cases engagement with all stakeholders is necessary.

2.5.6 In assessing the suitability of potential sites for permanent Gypsy and Traveller

accommodation, and important consideration is determining an ideal or preferred site

size. Based on the guidance set out in WAG Circular 30/2007 and other good

practice guidance on designing Gypsy and Traveller sites, it is assumed that a site of

at least 1 hectare will be required, allowing each pitch to be at least 500 square

metres in size based on a development size of up to 10-15 pitches and allowing for

road and other infrastructure. This is consistent with WAG design guidance for Gypsy

and Traveller caravan sites.

2.5.7 A pitch size of at least 500 square metres would comfortably accommodate the

following on-pitch facilities:

- Hard standing for 1 touring/mobile caravan and 1 static caravan

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- 2 car parking spaces

- 1 amenity block

- Hard standing for storage shed and drying

- Garden/amenity area

2.5.8 Larger sites of between 1 hectare and 1.5 hectare, for example, would be able to

accommodate a wider range of appropriate on-site facilities and uses, including:

- Secure children’s play area

- Communal facilities (such as shared day room, laundry facilities, visitor parking

spaces, lorry/work vehicle parking, etc)

- Area for dog kennels (if deemed suitable to the locality)

- Stables and/or grazing area (if deemed suitable to the locality)

- Scope for business/employment uses (if deemed suitable to the locality)

2.5.9 Sites less than 1 hectare in size are assessed against the minimum requirements for

on-site facilities set out in Government guidance. Smaller sites and pitches will

create an opportunity for providing a range of pitch sizes, maximising the best use of

available land within the County Borough.

2.5.10 Although not essential requirements, the amenities outlined above are often stated in

Guidance as desired provisions on permanent Gypsy and Traveller sites. They are

also identified in an in-depth research report by Pat Niner to the Welsh Assembly

Government.

Figure 1 Minimum Size Requirement for a Double Pitch

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2.5.11 Figure 1 above illustrates a pitch of approximately 325 square metres, reflecting the

minimum size requirement for a double pitch taking account of all minimum

separation distance requirements between caravans and pitch boundaries as

stipulated in guidance and safety regulations for caravan development. Each pitch

could accommodate a basic number of on-pitch amenities, including space for 2

vehicles and an amenity block. A single pitch or transit pitch could be halved in size

as space for only a single mobile caravan would be required.

2.5.12 Whilst the figure bellow illustrates the minimum design and safety requirements

outlined in Government guidance, it is desirable to provide Gypsies/Travellers with

additional private amenity space. For the purposes of this Study, when assessing

the raw capacity of each potential site, it is proposed that a maximum pitch size of

500 square metres for permanent Gypsy and Traveller pitches and 250 square

metres for transit Gypsy and Traveller pitches be applied, taking account of the

necessary space requirements for internal road(s), shared/communal areas, and

parking and circulation space.

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3 CONSULTATION 3.1 Context 3.1.1 This study builds on the findings of interviews undertaken in June/July 2007 by

Torfaen County Borough Council of those living on the Shepherds Hill site. The

Council interviewed representatives from 21 out of 27 plots on the Shepherds Hill,

representing a sample size of 78%.

3.1.2 Consultation events were undertaken with the local Gypsy/Traveller community on

the Shepherds Hill Site on the 24th and 30th March 2009 to determine what local

services/amenities and on-site facilities were deemed to be essential, desirable or

not necessary.

3.1.3 The study team undertook new interviews/workshops of those living on that site and

spoke to occupiers from 16 out of 27 plots, gaining a sample size of approximately

60%. The objective of these new interviews was to test the robustness of the

June/July 2007 interviews and also to identify any new issues that may not have

been identified during those interviews.

3.1.4 The format of the March 2009 consultation was informal whereby consultants invited

local residents to participate in discussions - often this resulted in several members

of the community converging in a single caravan. Workshops were grouped as

follows:

- Session 1: Plots 8, 17, 23

- Session 2: Plots 4, 9, 13, 15, 16, 21

- Session 3: Plots 11, 12, 26

- Individual Sessions: Plots 5, 6, 18, 20

3.1.5 Given the nature of the interviews, which were undertaken in a group setting as

informal workshops rather than formal questionnaires, it is difficult to draw out

scientific conclusions from these surveys. The purpose of these workshops was to

discuss issues relating to Gypsy and Traveller accommodation, which would help

quantify the need for additional Gypsy and Traveller pitches in the County Borough

as well as inform the site selection process.

3.1.6 The informal structure of the March 2009 consultation allowed respondents to

discuss freely the issues that currently face the Gypsy and Traveller community in

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terms of on-site requirements, accommodation needs and access to services and

facilities. The study team met with residents at the Shepherds Hill site and used a

set of questions and key considerations to guide discussions, which are listed in

Table 2 below.

TABLE 2: Consultation Considerations

A. What makes a good site?

Considerations: - Ideal site size / total number of pitches - Ideal pitch size - single pitch, double pitch - Proximity to services and facilities - how important, which ones - Provision of on-site facilities - how important, which ones - Areas to avoid within the County Borough - Preference for traditional caravan park or bricks and mortar development - Importance of integration with settled community

B. What are the accommodation needs of the local Gypsy and Traveller community? Where are they needed?

Considerations: - Total need for additional pitches - Location and number of sites - Expansion of existing sites or provision of new sites - Future of Shepherds Hill site

C. How many transit pitches/sites are need? Where should they be located?

Considerations: - Dedicated transit site or provision within permanent sites? - Ideal locations for transit sites - known Traveller routes, key roads, etc

D. Management – who and how?

Considerations: - Private ownership/management? - Council ownership/management?

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3.2 Findings 3.2.1 Site Size / Pitch Size

Generally the findings of the 2007 interviews and the 2009 workshops determined

that there was, on average, an identified need of between 25 and 30 additional

pitches.

Individual pitches should ideally accommodate up to two caravans, including one

static caravan or mobile home. Sites should also provide sufficient space for an area

for children to play, parking for up to two vehicles, and space for a shed or other

amenity/garden space.

Those consulted also expressed a desire to have plots separated by fencing or other

boundary treatment to distinguish plots and provide greater security.

3.2.2 Preferred Areas

When asked to consider what areas of the County Borough new sites should be

located, an overwhelming majority of respondents expressed a preference to remain

close to the existing Shepherds Hill site (Pontypool area). Other areas identified as

potential search areas included Cwmbran due to existing family connections living in

bricks and mortar.

A wide consensus amongst those interviewed was a desire to avoid any sites in

Blaenavon. Blaenavon’s poor relationship to existing Gypsy and Traveller sites and

lack of adequate services and facilities desired by the respondents was identified as

reasons for this view held by a most of the respondents.

Although the local Gypsy and Traveller community has expressed this preference, it

is important to examine the County Borough holistically and not discount any

potentially suitable sites if there are no planning or other barriers to development. To

deviate from such an approach would be contrary to the advice contained in WAG

Circular 30/2007.

Generally the participants of the 2009 workshops were content with living on a

traditional caravan park and retaining the traditional Gypsy and Traveller lifestyle.

The 2007 interviews indicated 40% of respondents would like to live in bricks and

mortar.

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3.2.3 Integration with the Settled Community

The project team also sought the views of the local Gypsy and Traveller community

on the importance of integrating their community with the nearest settled community.

The vast majority of respondents indicated a preference to have some kind of

integration with the local settled community although they expressed a preference to

be located ‘near them’ but not ‘among them’.

Respondents also highlighted the relative cohesion currently experienced between

the residents of the Shepherds Hill site and nearby Pontypool. The majority of

children on the site attend local schools and colleges and make use of nearby

facilities and services. There has been a general acceptance of the Gypsies and

Travellers living in this area with little hostility between both communities.

3.2.4 On-Site Requirements

In assessing the importance of on-site facilities, participants were asked to identify

the importance of the site requirements listed in Table 3 below. Similarly,

participants were asked to identify if access to range of services was essential,

desirable or not important. The findings are summarised in Table 3, which also

reflects national research from similar studies:

TABLE 3: Key On-Site Requirements

Site Requirement Permanent Transit (up to 6 moths)

Temporary (up to 28 days)

Land area sufficient for required number of pitches and vehicular/pedestrian circulation

Utilities - water and electricity supply Good drainage Refuse collection and recycling Good access to local facilities Boundary fencing, hard standing, toilet & washing facilities, entry control

Amenity block (1 per pitch) with day room Children’s Play Area * Visitor pitches/parking Scope for business/employment uses Temporary toilet block Access to known Gypsy/Traveller routes

Essential Desirable Not Necessary

* Respondents indicated a preference for the provision of play space within pitches/plots and not a communal play area

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3.2.5 Access to Local Services and Facilities

Respondents of both the 2007 interviews and the 2009 workshops determined

access to local amenities and facilities was important. Unsurprisingly, during the

workshops all respondents identified having access to play areas, medical facilities,

schools and public transport as essential. This result reflects national guidance in

WAG Circular 30/2007 and the findings contained within the Pat Niner report.

3.2.6 Distance to Local Services and Facilities

Respondents were also asked to consider what they felt was an acceptable walking

distance to local services and facilities. The general consensus among respondents

was that key local services and facilities, including GP, schools, shops, public

transport, play areas and other recreational facilities should be within a 5 to 15 minute

walk.

3.2.7 Access to Traveller Routes

When asked about the importance of having access to key traveller routes, few of

those who responded indicated this as desirable with the majority indicated access to

such routes was not important. This reflects the very settled nature of the Gypsy and

Traveller community in Torfaen.

Few occupiers living at the Shepherds Hill site travel more than once a year and the

duration of those trips are often no more than a week. Access to key roads however

was important given the need for suitable vehicular access for trailers, caravans and

trucks.

3.2.8 Site Management

Respondents generally felt that issues related to who should be responsible for site

management were secondary to ensuring there is an adequate provision of on-site

facilities/utilities and ensuring these are managed more efficiently. The lack of

individual meters for electricity, gas and water on each plot was identified as a key

concern.

In terms of site ownership and site management, a majority of respondents indicated

a preference for this to be a Council responsibility and not private. Several

respondents indicated a desire to be afforded the opportunity to purchase their own

plot/pitch on Council-run sites.

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A significant majority of respondents expressed a preference for any site manager to

be a Council employee and not a member of the Gypsy and Traveller community.

Several members of the Shepherds Hill community questioned the neutrality of

having “one of their own” acting as a site manager.

A number of those interviewed also expressed a preference for privately owned

family sites. Those expressing a preference for small family sites identified the

benefits in terms of site management, site maintenance and site security.

3.2.9 Transit Provision

Currently there is little transit provision within the County Borough for Gypsies and

Travellers visiting the area on a temporary basis. There is 1 transit pitch on the

Shepherds Hill site, providing space for up to 2/3 caravans. These plots however

have no on-site services and are of a limited size. However, both the Mountain View

and Rose Cottage sites have space to accommodate visiting family members.

Respondents indicated a desire to have larger pitches in order to accommodate

visiting relatives. Currently only a limited number of pitches on the Shepherds Hill site

are large enough to accommodate visitors. The vast majority of plots are of an

inadequate size to allow for this - many failing to meet the minimum fire safety

requirements for caravan development.

Although respondents did not question the need for additional transit pitches within

the County Borough, a majority of respondents during the 2009 workshops felt it was

not a good idea to combine residential and transit pitches on the same site. Overall

there was a preference for provision within pitches for visitor spaces rather than

dedicated transit pitches within permanent residential sites, unless these pitches

could be restricted to the extended family of those already living on the transit site.

The 2007 interviews reflect this whereby 60% of respondents felt residential and

transit pitches should be kept separate.

3.2.10 The Future of Shepherds Hill

Respondents of the 2009 workshops expressed concerns over the future of the

Shepherds Hill site. There was a general acknowledgement that the site had become

overcrowded and required upgrading, particularly in improving pedestrian safety,

providing additional private amenity space, and utility management. There are also

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growing concerns over the ground stability of the site, although a number of

respondents indicated they would be happy to live with the risk if it meant not being

uprooted from the area.

Current occupiers of the site, particularly older members of the community, expressed

a reluctance to consider moving to a new site having spent 15 years or more on the

site. Younger respondents did express a willingness to relocate, however they would

want to remain within the surrounding area.

If a replacement site for Shepherds Hill is to be considered, those interviewed

expressed a need to locate such a site within the immediate surrounding area in

order to avoid any disruption to children attending schools. A nearby site would also

avoid the fragmentation of the relatively tight knit community that currently resides on

the site.

A number of workshop participants also expressed a need to extend the existing site

further; the Council is going to examine this in its study of the site.

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4 EXISTING PROVISION 4.1 The current provision of Gypsy and Traveller sites in Torfaen is concentrated in the

Pontypool area of the County Borough. Based on September 2009 figures provided

by Torfaen County Borough Council and a caravan count dated 12 August 2009,

there is a total of 37 permanent households/pitches on public and private sites across

the County Borough.

4.2 The August 2009 count indicates a total of 49 caravans or movable dwellings were

counted on all sites across Torfaen. This figure remains unchanged from the Bi-

annual Caravan Count undertaken by the Welsh Assembly Government in July 2006,

demonstrating a low vacancy rate within the County Borough.

4.2 Shepherds Hill, Lower Race, Pontypool (27 pitches)

Shepherds Hill is a Torfaen County Borough Council owned site, opened in 1975,

with 27 pitches (17 single pitches and 10 double pitches (1 of which is for transit

use)) with a capacity for 37 caravans. There are currently 26 households residing on

the site with a total of 40 and 34 caravans counted on site in January and July 2008

respectively. This site is usually full and has a waiting list. One transit pitch is

currently occupied at the site, although the pitch is often subdivided to accommodate

3 transit caravans.

According to the 2006 Niner Report, each pitch has an amenity block, but facilities

needed refurbishment and upgrading, which was estimated to cost approximately

£140,000 over the next 5 years and over £500,000 over the next 30 years. However,

in 2008 the Council spent £160,000 (including £75,000 WAG Gypsy Traveller

Refurbishment Grant) on the refurbishment of the amenity blocks. A Community

building is expected to be installed in 2010. The Council also hope to obtain a WAG

Refurbishment Grant to install individual electricity and gas meters to each pitch and

associated electricity infrastructure and street lighting works.

The site was subject to coal mining subsidence in 2005; a subsequent desktop

assessment found the risks from further subsidence to be low, but recommended a

cautious approach and grouting the voids under the site. The costs of grouting the

voids could cost up to £1 million and would require the residents to be temporally

relocated to a serviced site for up to 6 months. The Council intends to examine the

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issue of subsidence in its study of the site as well as the potential for extending the

site area; the results of which are expected in early 2011.

Although the Council has provided a site capacity figure of up to 37 caravans, it is the

view of the study team that the Shepherds Hill site is currently saturated and cannot

safely accommodate further caravans on areas recognised as pitches/plots without

serious violations to fire safety regulations.

4.3 Mountain View, Upper Race, Pontypool

A licensed (Caravan Site Licence - April 1993) authorised (Established Use

Certificate - June 1992) private, family run, site with no number of pitches specified.

There were 15 and 12 caravans/mobile homes counted in January and July 2008

respectively. A revised count in August 2009 identified 16 caravans/mobile homes

on the site with a total of 7 families/households residing on this site. From the August

2009 caravan count, it was established that there is capacity for an additional 3

pitches on site, which should accommodate family growth for the foreseeable future.

On-site facilities are very poor and access to local amenities/facilities by foot is

relatively poor.

4.4 Rose Cottage, Upper Race, Pontypool

The Rose Cottage site is an unauthorised but tolerated private site with 8 and 5

caravans counted in January and July 2008 respectively. The revised August 2009

count indicated a total of 6 caravans on the site and a total of 3 families/households

residing on this site. However, This, almost weekly, variance is explained by the fact

that there are normally 3 resident households on the site, with increases due to

members of the extending family staying for short periods as transit households. On-

site facilities are minimal and access by foot to local amenities/facilities is relatively

poor.

4.5 The Caravan, Land at Lower Race, Pontypool One household is currently located on unauthorised but tolerated privately owned

sites on land at Lower Race.

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4.6 Current Planning Applications

In addition to the current unauthorised pitches, the owner of the Rose Cottage site is

proposing to create an additional 10 pitches, which may require a planning

permission for a material change of use or a certificate of lawful use if the use can be

established. However, any building/operational works will require planning

permission. If approved, the additional pitches on the Rose Cottage site will help

reduce the anticipated need for additional Gypsy and Traveller pitches. The Council

is likely to include this land as a formal allocation for a Gypsy and Traveller site in the

Deposit Local Development Plan.

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5 IDENTIFIED NEED 5.1 Context 5.1.1 The thrust of this document is to identify a general approach and methodology for the

identification and assessment of potential sites to meet Gypsy and Traveller

accommodation needs within the County Borough. This section will quantify the

need based on new consultation undertaken over the past six months and historical

evidence of authorised and unauthorised encampments within the Torfaen, along

with an assessment of the likely demand result from population growth and aging

population of the local Gypsy and Traveller community.

5.1.2 This report ‘tests’ the findings of the Niner report and provides new empirical

evidence to quantify the likely need over the Local Development Plan period for

additional Gypsy and Traveller sites within the County Borough.

5.1.3 In assessing the existing supply of Gypsy and Traveller pitches and projecting the

likely need for additional pitches within the County Borough, the study has drawn

from information provided by the local authority, the knowledge of key stakeholders,

surveys undertaken by the local authority in June/July 2007, new interviews

undertaken by consultants in March 2009, and assumptions based on the

professional experience of the study team.

5.1.5 The approach adopted in quantifying the need for additional Gypsy and Traveller

pitches in Torfaen is based on guidance published by the Department for

Communities and Local Government, “Gypsy and Traveller Accommodation Needs

Assessments” (2007). No equivalent has been published by the Welsh Assembly

Government.

5.1.4 In estimating the need for likely demand for additional Gypsy and Traveller pitches

over the first five years of the Local Development Plan Period (2006-2011), the

following indicators have been taken into account:

- Household growth

- Need from overcrowding on the Shepherds Hill site

- Need from unauthorised developments

- Movements between sites and housing

- Need from potentially closing the Shepherds Hill site

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- Need from households on unauthorised developments

5.1.5 In considering the existing supply of Gypsy and Traveller accommodation within the

County Borough, the following factors have been considered:

- Pitch vacancies on socially rented sites

- Unused pitches within the County Borough

- Known and/or planned developments of sites and/or pitches

5.1.6 Further accommodation requirements within the five years of the LDP period are

based on estimated family or household growth. This follows commonly accepted

assumptions as to the growth of the Gypsy and Traveller population. Household

growth rates of 4% a year was suggested as appropriate in Pat Niner’s

“Accommodation Needs of Gypsy-Travellers in Wales” (2006). Similarly, long-term

demand for additional pitches over the full Local Development Plan period up to 2021

is estimated using these household growth projections.

5.2 Anticipated Need 5.2.1 Table 4 below summarises the estimated need for permanent residential pitches

during the first five years of the Local Development Plan up to 2011. It is anticipated

that a total of 15 pitches are required over this period to meet the current shortfall of

pitches and accommodate family growth.

5.2.2 The figures in Table 4 are also provided and indication of the likely additional

demand over the remaining 10 years of the LDP period up to 2021. A further need of

up to 31 pitches is anticipated between 2011 and 2021. The number of pitches

identified for long-term need only accounts for the likely household growth of 4% per

annum. These estimates do not factor in additional demand resulting from

unauthorised encampments and migration from other areas of the country.

5.2.3 The formula used to identify anticipated Gypsy and Traveller accommodation needs

follows the recommended guidance contained in the Department for Communities

and Local Government document, “Gypsy and Traveller Accommodation Needs

Assessments” (2007).

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TABLE 4: Estimated Need for Residential Pitches Over LDP Period (2006-2021)

A. Current Residential Supply (based on 1 pitch per household) Pitches Currently supply of occupied local authority residential site pitches 26

Current supply of occupied authorised privately owned site pitches 10

Current supply of occupied tolerated privately owned site pitches 1

Total Existing Households 37 (1) Number of unused local authority pitches, and vacancies on privately owned sites 0

Number of existing pitches expected to become vacant in the near future (local authority or privately owned) 0

Number of households in site accommodation expressing a desire to live in housing 5

New local authority pitches already planned in Year 1 of the LDP 0

Existing applications for private site development/extension likely to gain planning permission during Year 1 of the LDP 10

Total Pitches Available 15 (2) Available over 5 years (assumption) 75

Total Pitch Provision Available (1) + (2) 52 (3)

B. Current Residential Demand Pitches Households seeking permanent site accommodation in the area (based on waiting lists and results of survey/interviews) 1

Households on unauthorised encampments 0

Households on unauthorised developments for which planning permission is not expected 0

Households currently overcrowded (where insufficient space on the pitch for a further caravan) 5

New households expected to arrive from elsewhere (based on waiting lists, survey and caravan counts/trends) 2

New family formations expected to arise from within existing households (based on waiting lists, survey) 11

Households in bricks and mortar but with a need for site accommodation (based on waiting lists, survey) 0

Current Demand 19 (4) Current Shortfall (4) – (3) 4

Family formation for period between year 1 and year 5 of the LDP (52 Households @ 4% year on year growth for 5 years) 11

Medium Term Demand: Total Pitch Need (2006-2011) 15 Pitches Total Number of Sites Required 1

Projected family formation for period between year 6 and year 10 of the LDP (63 Households @ 4% year on year growth for 5 years) 14

Projected family formation for period between year 11 and year 15 of the LDP (74 Households @ 4% year on year growth for 5 years) 17

Longer Term Demand: Total Pitch Need (2011-2021) 31 Pitches Total Number of Sites Required 2

TOTAL NEED OVER LDP PERIOD (2006-2021) 46 Pitches Total Sites Required 3

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5.2.4 Bricks and Mortar Housing

No detailed data currently exists that provides an accurate number of Gypsies and

Travellers living in bricks and mortar across the County Borough. It is known

however that a significant Gypsy and Traveller community resides in conventional

housing in Cwmbran and Pontypool and have integrated with the existing settled

community, many of whom no longer follow a traditional Gypsy and Traveller lifestyle.

What is not known is what proportion of that population living in conventional housing

would want to return to traditional Gypsy and Traveller sites. The Council does not

maintain a waiting list of those wishing a pitch at the Shepherds Hill site.

Survey data suggests that very few households plan to move from an authorised

local authority pitch. Out of 20 respondents in the Council’s 2007 survey of

Shepherds Hill residents, 8 indicated they would live in bricks and mortar. Out of 16

respondents in the 2009 workshops undertaken by the study team, only 2 indicated

they would live in bricks and mortar. An average was therefore used of the two

figures.

5.2.5 Overcrowding

Some of the existing pitches on the Council’s Shepherds Hill site and other

authorised sites fall well below accepted norms for adequate pitch size. There is

however scope for further caravans on privately owned authorised sites, provided

this conforms to accepted design guidance for caravan development.

Existing plots on the Shepherds Hill do not conform to accepted design guidance for

caravan development. Some caravans are sited below the minimum separation

distance recommended for fire safety. As result, there is little scope for the provision

of additional caravans on the Shepherds Hill site, unless the site is extended.

In the Council’s 2007 survey of Shepherds Hill residents, 4 indicated a need for a

larger pitch within the next five years. As such it is reasonable to assume that at

least 5 pitches are required due to overcrowding.

5.2.6 Households Seeking Permanent Site Accommodation in the Area

Torfaen County Borough Council does not currently maintain a waiting list of Gypsies

and Travellers wanting a space on authorised local authority sites. During the March

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2009 workshops however the study team was made aware of 1 household currently

making use of the transit pitch at the Shepherds Hill site who expressed an interest in

securing a permanent residential pitch within the Borough. This has therefore been

factored into the accommodation need calculations.

5.2.7 New Pitch Demand from Outside the County Borough

During the workshops undertaken by the study team in March 2009, two individuals

expressed a desire to move to Torfaen in order to be closer to parents and other

extended family. One respondent was located in Cardiff on a Council-run site and

the other in Brynmawr. Based on these findings, it is assumed that up to 2 new

households are expected to arrive from elsewhere. This figure could in reality be

much higher.

5.2.8 New Family Formations from Existing Households

It is difficult to predict future family formations from existing households. There are

currently 11 young people between the ages of 16 and 25 living with parents. It is

reasonable therefore to assume that in the next five years there is a demand for 11

pitches from new family formation.

Based on the outcomes of the 2009 workshops, it can also be assumed that a large

number of young adults live with parents due to a lack of additional pitches within the

County Borough. The Council’s 2007 interviews identified 10 respondents who

indicated at least one member of their family/household would require a pitch within

the next five years.

From the above figures, it is reasonable to assume that up to 11 new pitches are

required to accommodate the existing demand for Gypsy and Traveller

accommodation.

5.3 Implications of Shepherds Hill Closure / Redevelopment 5.3.1 Torfaen County Borough Council has yet to decide the future of the Shepherds Hill

site. A comprehensive plan is necessary to address the current issues at the

Council’s Shepherd Hill Site in terms of overcrowding, poor design and on-going

concerns over subsidence.

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5.3.2 Section 4 of this report has provided a review of the Shepherds Hill site. The Council

currently has two options in dealing with future of the site. These include:

- Refurbish the site in terms of enhancing existing facilities, addressing the

subsistence issues and overcrowding issues; and finally; or

- Close the site and relocate it to another area within the County Borough.

5.3.3 The closure of the Shepherds Hill site would inevitably increase the identified need

by up to 26 pitches, excluding the transit pitch.

5.3.4 The subsidence issue on the Shepherds Hill site will need to be addressed from a

legal point of view whereby the Council must act on a known safety risk to the

occupiers of the site. The cost of such remediation work is high and it could be more

financially viable to relocate the site elsewhere; noting that the occupants of the site

are likely to need to be relocated for several months whilst grouting takes place. A

more detailed cost analysis will need to be undertaken as part of the Council’s study

on the future of the site.

5.3.5 It is clear that the Shepherds Hill site as it currently stands is unacceptable. The

layout of the site in terms of access and positioning of caravans does not conform to

fire safety guidance for caravan development, nor does it meet the guidance

contained within WAG’s “Designing Gypsy and Traveller Sites - Good Practice

Guide”.. If the Council decide to address the ground stability issues on the site, the

redevelopment of the site will need to reflect good practice guidance. A reduction in

the number of pitches on the site of between 5 and 10 pitches could address existing

concerns.

5.4 Transit Need

5.4.1 According to information provided by Officers, since 2003, there have been between

1 and 16 unauthorised Gypsy and Traveller encampments annually in Torfaen, which

is summarised in Table 5 below. Figures provided by Torfaen County Borough

Council also indicate an average of 4 unauthorised encampments annually over the

past 3 years.

TABLE 5: Unauthorised Encampments in Torfaen since 2003

Year 2003 2004 2005 2006 2007 2008 2009 No. of 3 1 8 16* 2 5 5

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Encampments

* - The high figure for 2006 was actually 2 encampments that moved to 7 locations within the Borough and 2 other separate encampments; so 4 would be a more realistic figure for comparison purposes.

5.4.2 There is no pattern in their location and occupants are often connected to the existing

Gypsy and Traveller sites in the area, where there is lack of capacity and the nomadic

Gypsy and Traveller community. Similarly, there is no pattern to the length of stay as

occupants can stay a few days to several weeks in one place or move around the

County Borough. Information provided by Officers shows that non-visitor

encampments usually contain 1 to 4 caravans.

5.4.3 The provision of transit pitches can be accommodated in three ways:

- Within existing or new residential sites;

- New dedicated transit site(s); and/or

- Provision of space within residential pitches for visitors.

5.4.4 As indicated in Section 3 of this study, through various consultations with the local

Gypsy and Traveller community, many oppose the idea of combining transit pitches

with residential pitches on the same site. Respondents were more favourable to the

option of having dedicated transit sites and providing additional space within

residential pitches to accommodate visiting family.

5.4.5 Transit need is often a regional consideration. Therefore it is recommended that

further discussions with neighbouring authorities be undertaken with regards to the

provision of regional transit site(s).

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6 PROPOSED SITE SELECTION METHODOLOGY 6.1 CDN Planning will assess potential sites using a criteria-based three-tier approach

where consideration is given to a wide range of environmental, economic and social

factors in order to determine the suitability and sustainability of the site. The

approach is summarised briefly in Table 6 below with each element of the

methodology then discussed in further detail.

TABLE 6: Summary of Three-Tier Site Identification/Assessment Approach

Tier 1: Location, Policy & Environmental Constraints Relationship to Settlements Sites should ideally be within an agreed acceptable distance

of a neighbourhood/district centre via safe walking/cycle route.Policy Constraints Sites should avoid any adverse impact on local/national

designations (such as conservation areas) Environmental Constraints Sites should avoid any hazardous areas (such as flood zones,

contaminated land) Tier 2: Access & Infrastructure Physical Infrastructure The capacity of local infrastructure to accommodate the

maximum number of pitches on a site. Transport Infrastructure Access to site options should be in line with adopted highway

guidance and standards. Access to public transport should be within an agreed distance and frequency.

Social Infrastructure Sites should be within an agreed acceptable distance of at least 5 local amenities/services, including schools, shops, medical facilities, recreational facilities via safe walking/cycle route. Capacity of existing infrastructure is also considered

Other Considerations The relationship of a site with existing Gypsy and Traveller sites (if any) is considered.

Tier 3: Design & Deliverability Design & Impact The use of a site for Gypsy and Traveller accommodation is

assessed in terms of its impact on the character/appearance of the surrounding area, along with the impact on the residential amenity of nearby properties.

Deliverability The ease of acquisition is considered along with indicative costing of bringing the sites forward for development (detailed site layouts and costing are prepared for top-performing sites).

6.2 Identifying Search Areas 6.2.1 To facilitate the process of identifying sites, it is necessary to narrow down the

potential search areas in order to more efficiently and effectively identify suitable and

sustainable sites that meet the criteria set out in the three-tier approach.

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6.2.2 Using GIS mapping, search buffer zones were used to determine areas of the County

Borough that have access to three primary services (a doctor, a school and a food

shop) within at least 1000m, as the crow flies. These are not actually walking

distances, which could in some instances exceed 1000m. Actual walking distances

to local services and amenities is assessed in Tier 2. Figures 2, 3 and 4 below

highlight in blue the search zones with the urban areas of the County Borough edged

red.

6.2.3 Having identified search areas, aerial photographs will examined to pinpoint

potentially suitable sites for Gypsy and Traveller pitches. Consideration will be given

to the relationship to the nearest settlement, site enclosure, existing landscaping and

existing land uses. Sites will then be assessed against policy and environmental

constraints, avoiding areas where known hazards exist (such as flood zones and land

known to be contaminated) and avoiding land which lies within a nationally or locally

recognised designation (such as conservation areas).

Croesyceiliog Pontnewydd

Fairwater

CWMBRAN Llanyrafon

Henllys

Llantarnam

Ponthir

Figure 2 Search areas for Cwmbran

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BLAENAVON

Figure 2 Search areas for Blaenavon

Abersychan

Trefethin

PONTYPOOL

New Inn Pontymoile

Panteg/ Sebastopol

Figure 3 Search areas for Pontypool

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6.2.4 Site visits will then be undertaken to assess potential sites in greater detail against

site-specific criteria. Using professional judgement and previous experience

undertaking similar site searches, areas where one would expect to find potential

sites will be examined - those on the edge of the settlement in particular and away

from any built-up residential, commercial or industrial areas. Access to a main

distributor road may also be a key factor in identifying potential sites. A future Site

Options Report will outline the full findings of these investigations.

6.2.5 Following an on-site investigations, potential sites will immediately be eliminated from

consideration if they fail to meet basic site topography suitability or were deemed to

relate poorly to the surrounding area (i.e. proximity to dangerous installations, poor

access, etc.). The study team will then make use of a matrix to score each potential

site against the criteria set out in the three-tiered methodology, a template of which

can be found in Appendix A of this report. The methodology is summarised further in

Sections 6.3, 6.4 and 6.5 below.

6.2.6 From the pool of potential sites, a short-list of suitable preferred site options will be

subject to wider public consultation. It will be necessary to ensure the information

contained in the matrices is presented in a more user-friendly format, as outlined in

the template found in Appendix B of this report.

6.3 Tier 1: Location 6.3.1 The main objective of Tier 1 is to assess the relationship of a potential site with the

nearest settlement. Historically, Gypsy and Traveller sites are often located on the

outskirts of settlements away from a range of services and amenities. However,

locations within settlements where conventional residential development would be

acceptable should not be ruled out if it met the requirements set out in the criteria-

based approach set out below.

6.3.2 Government guidance stresses the importance of providing the Gypsy and Traveller

community with access to a range of community services and facilities. Therefore,

potential sites should ideally be located no more than 1200m from a district or

neighbourhood centre where a range of local services and facilities can be expected

via a safe walking route or where such a route can be provided if one currently does

not exist.

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6.3.3 If no suitable potential sites have been identified within the initial 1000m search area,

sites beyond 1200m are considered up to a maximum of 2000m.

6.3.4 Potential sites for Gypsy and Traveller development should ideally be located in

suitable areas with adequate access to services such as health and education and

shopping facilities. A range of site options should be considered including those in

built-up areas, areas on the outskirts of built-up areas, rural or semi-rural locations

and previously developed (brownfield) or derelict land.

6.3.4 Policy Constraints / Valued Areas

It is important to ensure that the quality and character of the countryside is protected

and where possible enhanced. Proper regard must therefore be given to areas of the

County Borough that have been designated for their landscape, wildlife or historical

qualities and restrain any development that may compromise these designations.

However, nationally and locally recognised designations for landscape and nature

conservation should not be used in themselves to remove potential sites from

consideration or refuse planning permission for Gypsy and Traveller sites.

It is therefore not reasonable to rule out development in a locally recognised

designation area if there is no harmful impact. As with any form of development,

potential sites and planning applications for new Gypsy and Traveller sites should

only be permitted where it can be demonstrated that the objectives of the designation

will not be compromised by the development.

In undertaking this study, potential sites identified for new Gypsy and Traveller

development should avoid adverse impacts on local and national designations,

including development plan allocations (existing or emerging), environmental and

conservation designations, and any other locally or nationally recognised

designations. Potential sites within the Special Landscape Area, where all forms of

development is restricted, should only be taken forward when all other suitable

options have been fully explored.

6.3.5 Environmental Constraints

A Gypsy and Traveller site should not be located in areas where conventional bricks

and mortar housing would be considered unsuitable. To position a Gypsy and

Traveller site in the vicinity of a hazardous installation or in areas of contaminated

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land or water with poor drainage without potential for alleviation would be

unreasonable. Sites should therefore not be located where there is a significant level

of contamination, pollution, flood risk, poor ground stability or poor drainage.

Generally, sites in close proximity to any hazardous installations, motorways, dual

carriageways, railway lines and rivers will also be avoided. Mitigation measures can

be considered if it can address potential concerns where potential sites meet the

minimum scores for other suitability and sustainability criteria.

6.3.6 Hazardous Areas As with conventional residential development, caravan sites should not be located

within defined safety zones established around installations or operations considered

as dangerous to life and health. These may include pipelines, installations handling

or storing hazardous materials, industrial or defence premises, and mineral extraction

areas.

6.3.7 Water Contamination

Similarly, caravan sites will not be permitted on sites considered to present health

risks through prior contamination of land or water. Where significant contamination

issues arise, detailed investigation and risk assessment would be required. This

especially applies to the re-use of brownfield sites, which may be appropriate where

acceptable remedial measures could overcome any hazards.

6.3.8 Flood Risk

There is generally a presumption against most forms of development in areas where

a high risk of flooding exists, either from the development itself or from surrounding

watercourses, for up to the 1 in 1000 year event including the forecast effects of

climate change. New development must also not increase the risk of flooding in

surrounding areas.

The approach of limiting Gypsy and Traveller pitches in areas of flood risk reflects

Government advice contained in TAN 15 Development & Flood Risk. Given their

vulnerability, caravan sites should not be located in areas of high risk of flooding.

Generally, TAN 15 affirms that caravan development should be refused in Zone C2

where there is a high risk of flooding.

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In areas of flood risk where a potential site has been deemed suitable for

development, a risk assessment will be needed to identify the extent of potential

flood risk and recommend any possible mitigation measures prior to development of

any new Gypsy and Traveller site. The Environment Agency (EA) will be consulted

on all proposed sites within and adjacent to a floodplain. The EA will then advise on

the acceptability of the proposal in light of all known information and comment on any

proposed mitigation measures.

6.3.9 Ground Stability

To position Gypsy and Traveller pitches on unstable land without the potential for

alleviation would be unreasonable. Often where there is poor drainage or risk of

flooding, ground instability occurs. Similarly, where mineral extraction or other

activities have taken place, a site’s stability can be compromised. Therefore,

potential sites will only be identified in areas that are physically capable of

accommodating the new development.

6.3.10 Poor Drainage

To position Gypsy and Traveller pitches on land with poor drainage without the

potential for alleviation would be unreasonable. Gypsy and Traveller pitches should

not be located in areas of poor drainage. Where these problems exist, a flood risk

assessment will be prepared prior to development of any new site which will identify

risks of flood as well as recommend sustainable drainage systems for the site. A

sustainable drainage system will help to maintain, where possible, practical and

sustainable, the natural catchment areas.

6.3.11 Planning History

Once a potential site has been identified, a full planning history search is undertaken;

however a live consent will not necessarily preclude a site from further consideration.

The proposed use of the site for Gypsy and Traveller development will need to be

assessed against the approved use/development and potential impacts.

All suitable sites should be considered appropriate in principle provided there is no

specific planning or other constraints limiting development of these sites. A planning

history search will be undertaken for each potential site to identify any possible

barriers to development.

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6.4 Tier 2: Access and Infrastructure 6.4.1 The second tier of assessment examines issues relating to basic physical

infrastructure, highway and access issues, and access to social infrastructure. The

objective of this phase in the identification process is to ensure a potential site:

- has access to basic infrastructure, such as water and electricity, on the site;

- meets the minimum requirements of the highway authority in terms of safe

access and minimal impacts to the existing highway network;

- has access to frequent public transport within a reasonable walk or cycle

distance;

- has access to a range of local services and amenities within a reasonable walk or

cycle distance; and

- will not result in any undue stresses on existing local physical and/or social

infrastructure

6.4.2 Physical Infrastructure To locate a Gypsy and Traveller site in an area without access to basic infrastructure

would be against statutory duties placed on utilities companies, for example, the

statutory duties on a water utility company to provide water for domestic purposes.

As with all forms of development the availability of water, electricity and sewage

disposal are necessary features of any viable Gypsy and Traveller site. Once a final

short-list of suitable potential sites (preferred options) has been identified, detailed

consultations with utility companies will be undertaken to assist with detailed

evaluation of all potential sites that come forward for consideration. As with

traditional residential development, the developer, owner or manager of the site will

undertake the implementation and associated costs of providing essential

infrastructure to Gypsy and Traveller pitches.

Sustainable technologies for the provision of heat and domestic hot water through

the use of, for example, Biomass installations (wood chip / wood pellet systems)

should be promoted where appropriate. Given the Gypsy and Traveller community’s

self-reliance, having on-site energy solutions might be attractive to them.

The capacity of local infrastructure (water, electricity, etc) should be able to

accommodate the maximum number of pitches on a site. An assumption at this

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stage, if the development is located close to an existing settlement, that capacity

exists to accommodate between 10 and 15 Gypsy and Traveller pitches. Detailed

assessments on capacity issues would be undertaken once a preferred site option is

selected.

6.4.3 Transport Infrastructure

Providing safe highway access in line with adopted guidance is essential for the

operation of a potential site, for road safety, and for ease of travel. Adequate space,

grades and visibility are essential factors in the provision of safe and effective sites.

It is desirable that all potential sites meet the following requirements:

- Access to potential sites should avoid routes through built-up areas or is available

by distributor roads without the need to use more local roads within industrial

areas, recognised commercial areas or housing areas.

- The potential site must be serviced by an independent vehicular access point that

adheres to the Highway Authority’s guidance and standards in terms of safe entry

and egress.

- Safe pedestrian and/or cycle access/route should be provided to the nearest

village, town or neighbourhood centre providing a range of services and

amenities (or in an area where one such route can be provided).

Potential sites are also assessed against their distance to public transport via safe

walking or cycle route and the frequency of services from the nearest bus stop or

transport node. Ideally, sites should be within at least 800m via safe walking route of

a public transport node, such as a bus stop, where service is provided at least hourly.

This reflects guidance provided by the Institute of Highways & Transportation (IHT)

Guidelines for Providing Journeys on Foot.

6.4.4 Social Infrastructure In promoting sustainable development, new Gypsy and Traveller sites will ideally be

situated within walking distance of local services and amenities and near to frequent

public transport to access jobs, shopping, leisure facilities and services. This reflects

WAG Circular 30/2007 guidance that Gypsy and Traveller sites must be located near

to a range of services and amenities.

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Distances from potential sites to social infrastructure reflect the Institute for Highway

and Transport’s (IHT) Guidelines for Providing Journeys on Foot. These are similar

standards applied when assessing Local Development Plan candidate housing sites

for conventional residential development. These standards for achieving sustainable

communities are summarised in Table 7 below:

TABLE 7: Acceptable Walking Distances (Institute of Highway and Transport)

Walking Distances Local Facilities * District Facilities ** Other Desirable 200m 500m 400m Acceptable 400m 1000m 800m Preferred Maximum 800m 2000m 1200m

* includes food shops, public transport, primary schools, crèches, local play areas ** includes employment, secondary school, health facility, community/recreation facilities

Similarly, acceptable distances by cycle route to local services and amenities should

conform to IHT’s Guidelines for Providing Journeys by Bicycle i.e. 1000m (desirable),

4000m (acceptable), and 8000m (preferred maximum).

6.4.5 Access to Key Local Services

Through various consultation exercises with the local Gypsy and Traveller community

and discussion with Officers, and through other similar studies across England and

Wales, it has been determined that new permanent sites for Gypsy and Traveller

accommodation should be located near to four key local services. These include:

Potential sites should be within 800m of these services and amenities via safe

walking route. Consideration can be given to the provision of a play area within the

site if no existing play area is within the preferred maximum distance.

6.4.6 Access to Other Local Services

In addition to the above key local services, consideration is given to access to other

local amenities and services including post office, bank, place of worship and public

house within at least 800m of a site via safe walking route. This reflects IHT’s

guidance for acceptable walking distances for local services.

6.4.7 Access to District Services

Consideration is also given to the site’s relationship to district services and amenities,

including secondary schools, dentists, leisure/recreation centres, community centres

and other recreation. Ideally these should be no more than 2000m from the site via a

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safe walking route, reflecting IHT’s guidance for acceptable walking distances for

district services.

Cycle access from potential sites to the above local and district services is also

assessed. Access to a range of services and amenities should be no more than

8000m of potential sites via a safe cycle route. This reflects IHT’s guidance for

acceptable cycle distances.

6.4.8 Other Considerations The relationship of a site with existing Gypsy and Traveller sites (if any) is considered

along with what impacts this might have on local physical and social infrastructure,

including existing services and amenities. Although it is desirable to avoid the

‘ghettoisation’ of Gypsy and Traveller sites within a particular area in the County

Borough, consideration must be given to preferred Gypsy and Traveller settlement

areas and established local connections through employment and family ties.

6.5 Tier 3: Design and Deliverability 6.5.1 Design and Impact

A screening assessment for each site option is undertaken, including a brief site

appraisal examining, for example:

- Overall impact of a Gypsy and Traveller development on the locality

- Microclimate - if the site’s topography or location mean that it is likely to have an

expose or sheltered microclimate

- Topography and Aspect

- Level and Quality of Existing Vegetation - trees, hedgerows, etc and the impact a

Gypsy and Traveller development might have on these

- Any other relevant issues

The use of a site for Gypsy and Traveller pitches must be assessed in terms of its

potential impact on the surrounding area. The development of Gypsy and Traveller

sites should not result in a significant adverse impact on the character and

appearance of the locality - this includes the surrounding countryside, landscape and

nearest settlement/dwelling. As with any other forms of development, this outcome

would not be acceptable. Therefore, Gypsy and Traveller sites should respect the

character and appearance of the nearest settlement or surrounding area.

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Government guidance expresses the need to consider the needs and interests of the

settled community along with those of the Gypsy and Traveller community. The

identification of new sites and the granting of future planning permission for sites

should therefore avoid any detrimental impact on the amenity of local residents and

adjoining land users, including business parks and commercial land uses. Amenity

would include local services, facilities, infrastructure, and other aspects that enhance

the value of a particular area.

In assessing the impacts resulting from a Gypsy and Traveller development, the

following are considered:

- Nature of any likely impacts on local or national designations (level of impact is

likely to be high, medium or low)

- Nature of any likely impacts on the residential amenity of nearby properties (level

of impact is likely to be high, medium or low)

- Nature of any likely impacts on the surrounding landscape or character of the

locality (level of impact is like to be high, medium, or low)

As stated in Tier 1 above, sites should not be located where there is a significant

level of contamination, pollution or nuisance, which can be caused by neighbouring

uses including air quality, noise, odour, etc. An assessment is undertaken in Tier 3

to identify any potential environmental health issues relating to poor air quality, noise

issues or light nuisance.

6.5.2 Notional Costing

An indicative cost for each site option will be reflected in a score value, which will be

calculated by taking the considerations listed in Table 8.

The scores below represent the level of difficulty associated with securing the site

and the likely cost associated with site specific issues. The scores are added to

provide a notional cost of taking a suitable site forward for Gypsy and Traveller use.

The figure is not a real-world cost, but an indicative theoretical cost of delivering the

site.

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TABLE 8: Notional Costing Cost of Securing Site/Land Value: - Land already in the ownership of the Gypsy and Traveller community with have no

value (0) - Land in the Council’s ownership or in the ownership of another public body, where that

body is willing to release the site for Gypsy and Traveller use, with have a nominal land value (+1)

- Land in the ownership of another public body or a landowner unwilling to sell the site for Gypsy and Traveller use with have a market land value (+2) and may require compulsory purchase

Cost of Road Layout: - Where existing road layout/infrastructure can be used, the cost will be none (0) - Where minimal road layout/infrastructure are required, the cost will be nominal (+1) - Where significant road layout/infrastructure works must be undertaken, the cost will be

high (+2) Cost of Utility Connection: - Where an existing connection exists, the cost will be none (0) - Where a connection can be made within 100m of the site, the cost will be nominal (+1) - Where a connection is only possible beyond 100m, the cost will be high (+2) Cost of Landscaping: - Where there is sufficient landscaping already present for adequate screening, the cost

will be none (0) - Where minimal additional landscaping must be implemented for adequate screening, the

cost will be nominal (+1) - Where significant additional landscaping is required for adequate screening, the cost will

be high (+2) Cost of Mitigation - Where there is no need for mitigation due to land contamination, flooding, poor drainage,

poor ground stability, the cost will be none (0) - Where there is a need for mitigation for one of (land contamination, flooding, poor

drainage, poor ground stability) the cost will be nominal (+1) - Where there is a need to mitigate more than one of (land contamination, flooding, poor

drainage, poor ground stability) the cost will be high (+2)

For the purposes of this study it will be assumed that Torfaen County Borough

Council will cover all costs associated with basic infrastructure provision (road, utility,

mitigation, landscaping) through its own funds or more likely through grant funding.

This assumption will be applied to any potential sites that are likely to be delivered

and/or managed by the Council. Where potential sites are owned by the Gypsy and

Traveller community, these costs might be shared – particularly the provision of basic

infrastructure such as roads, landscaping and utility connection.

6.5.3 Deliverability

A site’s ease of acquisition is considered along with provision of an initial assessment

of what barriers to development/deliverability might be encountered for each potential

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site. For example, sites that are in Council ownership and available for purchase will

be easier to acquire for Gypsy and Traveller use than those sites in private

ownership where compulsory purchase is likely.

Detailed costing for each site option can only be provided once a layout of the

proposed development is prepared for each site option.

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7 CRITERIA-BASED POLICY (Advice for the Deposit LDP) 7.1 General 7.1.2 Torfaen County Borough Council is committed to meet the identified accommodation

needs of the Gypsy and Traveller community who normally reside in or travel to the

County Borough. The Council will support the development of permanent Gypsy and

Traveller caravan sites in suitable and sustainable locations in accordance with the

criteria set out in this policy.

7.1.3 The provision of sites to meet the on-going accommodation needs of the Gypsy and

Traveller community who normally reside in or travel to the County Borough will be

encouraged. Meeting this need will be achieved by supporting the development of

permanent Gypsy and Traveller caravan sites in suitable and sustainable locations in

accordance to the criteria set out in this policy.

7.2 Meeting the Identified Need 7.2.1 A need has been identified within Torfaen County Borough Council to provide

additional Gypsy and Traveller accommodation. This identified need of up to 46

pitches must be met over the Local Development Plan period (2006-2021). An

assessment of the anticipate needs of the Gypsy and Traveller community in Torfaen

has identified an immediate need of 15 pitches over the first five years of the LDP. A

study has been undertaken to identify suitable potential sites whereby a criteria-

based approach has been used to assess site suitability and sustainability.

7.2.2 A need for a transit site has also been identified. Given the nature of transitory

Gypsies and Travellers, such need should be discussed and addressed at a regional

level. Torfaen County Borough Council will work with all neighbouring Local

Authorities to identify and provide for its transit need over the plan period.

7.2.3 When assessing potential new sites for Gypsy and Traveller accommodation, the

Council will give preference to those sites located in or near to existing settlements

with access to a range of local services such as shops, doctors and schools, and a

range of amenities including play areas and other recreation facilities.

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7.2.4 Consideration will be given to sustainability issues such as co-existence in the local

community and the provision of a settled base which reduces the need for long

distance travelling.

7.2.5 All sites considered as options for new Gypsy and Traveller sites as part of the Local

Development Plan must have their social, environmental and economic impacts

assessed through the Sustainability Appraisal process.

7.2.6 Consideration will be given to the potential impact of proposed Gypsy and Traveller

sites might have in enhancing the existing built and natural environment, particularly

on previously developed land, in terms of design, layout and landscaping.

7.3 Identifying Sites - The Approach

The Council will use WAG national policy and a criteria-based approach which

considers environmental, economic and social indicators to identify the most suitable

sites for Gypsy and Traveller pitches. Sites under consideration will only be granted

planning permission if they can meet the objectives set out in this policy.

7.4 General Development Control Policy

New proposals for Gypsy and Traveller development will generally be permitted in

appropriate locations outside or within settlement boundaries where no planning

policy or other barrier to development exists. Proposals must satisfy the following

general criteria:

- No significant barriers to development exist in terms of flooding, poor drainage,

poor ground stability or proximity to other hazardous land or installation where

conventional housing would not be suitable;

- Unacceptable impacts on the character and appearance of the surrounding

landscape will be minimised through the sensitive and appropriate design of the

scheme;

- The proposal will not result in an unacceptable loss of amenity of neighbouring

land uses; and

- Mixed-use proposals will only be considered if appropriate to the locality and

whereby such uses will not result in an unacceptable loss of amenity.

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7.5 Amplification 7.5.1 Site Suitability

Sites for Gypsy and Traveller pitches may be located outside and/or within settlement

boundaries if the site can meet the requirements set out in this Policy and national

guidance. Proposals for Gypsy and Traveller pitches will only be permitted where

they conform to the following criteria:

- The site is not liable to flooding or where the development may likely give rise to

flooding elsewhere, unless it is demonstrated that these effects can be overcome

by appropriate alleviation and mitigation measures secured by planning

conditions or Section 106 agreements.

- The site access is deemed safe/adequate by the highway authority and where a

safe pedestrian route exists to a local neighbourhood centre or where such a

route can be made available.

- The site is not located in the vicinity of any dangerous roads, railway lines, water

bodies or power lines; however, these locations will be considered in the same

way as for conventional residential development if they are suggested and no risk

to health and safety is present.

- The provision of necessary infrastructure such as water, sewage disposal and

electricity is readily available.

- No ground stability issues are present, unless it can be demonstrated that the

land is physically capable of accommodating development and that the risk of

damage to the proposed development or adjoining land or buildings can be

overcome by appropriate alleviation and mitigation measures secured by

planning conditions or Section 106 agreements.

- No drainage issues are present, unless it can be demonstrated that these issues

can be addressed through an appropriate drainage system secured through

planning conditions or Section 106 agreements and where practical the

development should be served by sustainable drainage systems.

- The site is not located in the vicinity of a hazardous installation or in areas of

contaminated land or water unless it can be demonstrated secure by planning

conditions or Section 106 agreements.

- The site is not located in the vicinity of mineral resources so as to safeguard any

future demand.

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7.5.2 Sustainability of Site Location

New Gypsy and Traveller sites will ideally be located in sustainable locations within or

adjoining settlements with access to a range of services. To encourage sustainable

forms of development within the County Borough, sites for Gypsy and Traveller

pitches will ideally be located:

- within 1200 metres via a safe walking and/or cycle route of a town centre or

neighbourhood centre; and/or

- within at least 800m via a safe walking and/or cycle route of a transport node

providing at least an hourly service to the nearest town centre or neighbourhood

centre.

The Council will encourage, where appropriate, the use of brownfield sites for use as

new Gypsy and Traveller sites.

7.5.3 Rural Areas, Semi-Rural Areas, National/Locally Recognised Designations

As with any form of development, planning permission for new Gypsy and Traveller

sites should only be granted where it can be demonstrated that no unacceptable

impacts on the surrounding landscape, character of a locality or residential amenity

will result. Proposals for new Gypsy and Traveller sites will only be deemed

appropriate where it can be demonstrated that the criteria below can be satisfied:

- In rural areas or within nationally recognised designations such as Sites of

Special Scientific Interest, Special Landscape Areas and Conservation areas, it

can be demonstrated that the objectives of the designation will not be

compromised. Sites located within these areas should not be used as reason in

themselves to refuse planning permission.

- In areas on the edge of built up areas or in rural or semi-rural areas of the County

Borough, proposals for new Gypsy and Traveller sites will not result in undue

reliance on private vehicles to access local services and amenities.

- Proposed new Gypsy and Traveller sites must respect the scale of and not

dominate the nearest settled community and minimise any impact on local

physical and social infrastructure.

- Regard must be given in the design and layout of proposed Gypsy and Traveller

areas in such areas where there is the potential to minimise harmful impacts

through sensitive design and landscaping.

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7.5.4 Mixed-use Proposals

Through the Local Development Plan process, the Council should identify sites that

would be suitable for mixed-uses. Planning applications for mixed-uses within Gypsy

and Traveller sites will only be considered appropriate where it can be demonstrated

that the criteria below can be satisfied:

- A proposed mixed-use scheme must be appropriate to the locality;

- Such uses would not result in any unacceptable loss of amenity to neighbouring

land uses;

- Where Gypsies and Travellers wish to operate businesses from the same site

where their caravans are located, such uses would not result in any adverse

impacts on the safety and amenity of occupants and their children and

neighbouring residents

7.5.5 Transit Sites

Where appropriate, a small number of transit or temporary pitches may be provided

within permanent Gypsy and Traveller sites for family members (immediate or

extended).

Torfaen County Borough Council would support cooperation with neighbouring Local

Authorities to investigate the provision of further transit sites within the South East

Wales Region.

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8 CONCLUSIONS 8.1 Within the context of national guidance for identifying new Gypsy and Traveller

accommodation, this report has highlighted a robust evidence base for the provision

of new permanent and transit Gypsy and Traveller pitches within Torfaen County

Borough.

8.2 There have been low numbers of unauthorised Gypsy and Traveller sites in Torfaen

over recent years; which are mainly a result of the lack of visitor accommodation at

the Council’s Shepherds Hill site. However, much of this need can be met by

increasing the number of double pitches on the Shepherds Hill site or its

replacement. Also, given the size of the ‘non-visitor’ encampments, there is a need

for approximately 2 transit pitches for up to 6 caravans in Torfaen.

8.3 In addition, as transit need is often a regional consideration, it is recommended that

further discussions with neighbouring authorities be undertaken with regards to the

provision of a network of regional transit site(s).

8.4 The study has identified a total need of up to 15 pitches over the first five years of the

Local Development Plan period up to 2011. Based on best practice and guidance

outlined in the Welsh Assembly Government’s Circular “Planning for Gypsy and

Traveller Caravan Sites”, this could result in a need for at least one site. Smaller

sites brought forward through the planning process or allocated in the emerging

Deposit Local Development Plan (LDP) could accommodate this demand.

8.5 It is anticipated that a total of 46 permanent residential pitches will be required over

the LDP’s 15-year period, based on anticipated current need and family formation

and growth. However, this forecast will need monitoring as household growth is

difficult to predict in such a small population and the figure does not take account of

pitch turnover or vacancies that may occur in the future. It is also recognised that

now the Council has taken the management of the Shepherds Hill site more accurate

data for the forecasting process will be kept.

8.6 Meeting this identified need will however be dependent on the future of the Council’s

only permanent residential Gypsy and Traveller site at Shepherds Hill. The Council

will shortly undertake a study to determine the future of the site and address

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concerns over ground stability and overcrowding and if this would result in the need

to identify a new site within the Borough.

8.7 Finally, this General Approach Report has outlined a proposed three-tiered

methodology for the identification and assessment of potential sites to meet the

identified need. This robust and proven approach has been used to identify new

Gypsy and Traveller sites in England and Wales and has been developed using

Government’s most recent guidance as it relates to the Gypsy and Traveller

accommodation.

8.8 The proposed methodology will be the foundation of the final stage of the study

whereby a number of sustainable and suitable sites will be identified to meet the

identified accommodation need in the future Site Options Report.

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APPENDIX AProposed Scoring Matrix

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TIER 1 – LOCATION Sites must score the minimum score outlined below to move to Tier 2

Issue Score Min Notes 1. The Site 1a. Is Site located within the Search Zone?

Yes No

+1 0 YES (+1)

Sites must be located in the pre-assessment site zone whereby search areas were identified with the following criteria: Sites must be within 1000m (as the crow flies) of a school, general practitioner/medical centre and food store.

1b. Site Location and Size Specify Site Location Total Site Area -

1c. Current Land Use Use Brownfield or Greenfield? - Preference would be given to Brownfield sites in sustainable locations

(to be determined through other tests) 1d. Raw Capacity of the Site Guidelines:

Double Permanent Pitch = 500 sq m Single/Transit Pitch = 250 sq m

-

1e. The identified capacity meets the required need for a:

Permanent Gypsy/Traveller Site Transit Gypsy/Traveller Site Temporary Gypsy/Traveller Site

Yes No

+1 0 YES (+1)

Identify a raw capacity for the site and assess whether or not this would satisfy the required need for additional pitches within the County Borough. WAG Circular 30/2007 does not stipulate an ideal site size; however WAG’s “Designing Gypsy and Traveller Sites Good Practice Guide” states sites should accommodate no more than 15 to 20 pitches.

2. Relationship to Settlements 2a. Site is located within a safe walking (or where one can be made available) of a Local Centre

Within 200m Within 400m Within 800m Within 1200m

+4 +3 +2 +1

+1

A Local Centre is defined as a neighbourhood centre, district centre, village centre, or town centre offering a range of services and amenities. This conforms to IHT Guidelines for Providing Journeys on Foot.

2b. Site is located within a safe cycle route (or where one can be made available) of a Local Centre

Within 1000m Within 4000m Within 8000m

+3 +2 +1

+1

A Local Centre is defined as a neighbourhood centre, district centre, village centre, or town centre offering a range of services and amenities. This conforms to IHT Guidelines for Providing Journeys by Bicycle.

2c. How does the site relate to the existing settlement?

Within Existing Settlement Boundary Rounding off Settlement Edge of Settlement Out of Settlement

+4 +3 +2 +1

+1

Out of settlement locations will only be awarded a point if the site relates well to existing services and amenities.

3. Policy Constraints 3a. Green Wedge.

Yes No

0 +1 NO (+1)

A presumption against Gypsy/Traveller development in the Green Wedge is made. However, in line with WAG Circular 30/2007, sites within the Green Wedge can be considered although should only be taken forward when all other options are full exhausted.

3b. Valued Areas (The list is not exhaustive and can include any existing or future designations)

Internationally or Nationally Recognised Designations: - Special Areas of Conservation (SAC) - Special Protection Areas (SPA) - Sites of Special Scientific Interest (SSSI) - Scheduled Ancient Monuments - Landscapes, Parks and Gardens of

Special Historical Interest - Landscapes of Outstanding Historical

Interest - World Heritage Sites

YES = 0 NO = +1

NO (+1)

Ideally potential sites should be located outside the designations outlined. Where sites are located nearby or adjoining these designations, mitigation might address any potential harmful impacts and as such will be considered further. Proposals will only be considered further if it can be demonstrated that issues or concerns can be addressed through sensitive design or appropriate mitigation secured by planning conditions or S106.

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- Regionally Important Geological/Geomorphological sites

- Other International/National Designation Locally Recognised Designations: - Conservation Areas - Special Landscape Area - Important Countryside Frontages - Listed Buildings (curtilage or setting of) - Archaeological Sites - Tree Preservation Orders - Protected Mineral Workings, Waste

Safeguarding Areas, Sustainable Transport Protection Zones

- County Wildlife Sites - Biodiversity Action Plan areas - Ancient Woodland - Other Local Designations

3c. Impact on the above can be minimised through mitigation or sensitive design.

Yes No

+1 0 YES (+1)

4. Environmental Constraints 4a. Hazardous Areas / Significant Constraint to Development.

Flood Zone / Floodplain / River Poor Ground Stability Poor Drainage Topography Contaminated Land Hazardous Installations Poor Highway Safety Motorway flyovers, Dual Carriageway Railway

YES = 0 NO = +1 NO (+1)

4b. Above can be addressed through mitigation or sensitive design of the site.

Yes No

+1 0 YES (+1)

Potential sites should not be located in areas deemed unsuitable for conventional bricks and mortar residential housing use, either private or social. Sites should not be considered if they are near refuse sites or facilities, industrial locations and other hazardous locations such as those indicated. Proposals will only be considered further if it can be demonstrated that issues or concerns over health and safety can be addressed through sensitive design or appropriate mitigation secured by planning conditions or S106.

5. Planning History 5a. Does the site or part of the site have any valid planning permissions?

Application Number Application Type Decision Details

YES/NO -

Impact should be assessed and implications of any existing or pending planning application. A live planning consent does not remove a site from further consideration.

5b. Is the principle of a Gypsy/Traveller development on this site acceptable?

Yes No

+1 0 YES (+1)

TOTAL TIER 1 SCORE MIN 9 DOES THE SITE ADVANCE TO TIER 2? YES / NO

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TIER 2 – ACCESS AND INFRASTRUCTURE Sites must score the minimum score identified to proceed to Tier 3

Issue Score Min Notes 1. Physical Infrastructure 1a. Basic infrastructure (water, electricity) is available on site or within a reasonable distance away from the site to enable a practical connection.

Yes No

+1 0 +1

1b. Basic infrastructure has the capacity to serve the maximum site capacity.

Yes No

+1 0 +1

1c. If No, mitigation measures that can be taken to address issues.

Yes No

+1 0 +1

Details of local infrastructure must be provided, including any capacity issues, how far the nearest connection is, and feasibility of connection. It would be based on the recommendation of utility providers as to whether or not a connection is practical. A similar approach to residential development where no connection to basic infrastructure is available on the site will be used.

2. Transport Infrastructure 2a. The site can be serviced by independent vehicular access point, which adheres to the Highway Authority’s guidance and standards.

Yes No

+1 0 +1

2b. Access avoids routes through built-up areas or is available by distributor roads without the need to use more local roads within industrial areas, recognised commercial areas or housing areas.

Yes No

+1 0 +1

2c. Existing highway network is capable of accommodating proposed traffic movements.

Yes No

+1 0 +1

2d. The site has a safe pedestrian and/or cycle access/route to the nearest local area centre (or could one be provided).

Yes No

+1 0 +1

2e. The site has good, reasonably direct access to key routes out of the nearest town/city.

Yes No

+1 0 - This consideration would only be applied to potential sites under

consideration as a new transit site for the County Borough.

2f. Access to a transport node is provided via a safe walking route:

Within 200m of the site Within 400m of the site Within 800m of the site

+3 +2 +1

+1 This can be either a bus stop or rail stop or community share service. This reflects guidance within the Institute of Highways & Transportation Guidelines for Providing Journeys on Foot.

2g. The nearest public transport node provides:

Half-hourly public transport service Hourly public transport service

+2 +1 +1

3. Social Infrastructure 3a. Access to key* local facilities is provided (actual walking distance): * these are services and amenities that are deemed to be essential for the Gypsy/Traveller community as determined from similar study’s elsewhere and through consultation with the Gypsy/Traveller community.

Within 200m of the site Within 400m of the site Within 800m of the site

+3 +2 +1

+1

The site must be within the specified distance of at least 3 the following key Local Amenities: - Food Shop - a supermarket or village shop where a range of

products are available for purchase; a restaurant or take-away will not qualify as a food shop

- Doctor’s Surgery - Primary School - Children’s Play Area - will only classify as such if it is a clearly

defined and designated publicly available play area (or alternatively points can be awarded if such a play area can be provided within the site)

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Reflects WAG Circular 30/2007 guidance that Gypsy/Traveller sites must be located near to a range of services and amenities. Also reflects IHT guidance for acceptable walking distances.

3b. Access to at least 1 other local facilities is provided by safe walking route: (actual walking distance) Within 200m of the site

Within 400m of the site Within 800m of the site

+3 +2 +1

-

The site should be within the specified distance of at least 1 of the following Local Amenities: - Bank/Cash Point - or a post office providing a cash service. - Postal Facility - can be a post office or a postal subsidiary within for

example a supermarket - Pharmacy - Public House - Place of Worship Reflects WAG Circular 30/2007 guidance that Gypsy/Traveller sites must be located near to a range of services and amenities. Also reflects IHT guidance for acceptable walking distances.

3c. Access to district services/amenities is provided by safe walking route: (actual walking distance):

Within 500m of the site Within 1000m of the site Within 2000m of the site

+3 +2 +1

-

The site should be within the specified distance of at least 1 of the following Local Amenities: - Secondary School, College or other higher education - Medical Centre, Hospital, Dentist - Leisure/Recreation Centre - must be open for public use although

an entry fee may be charged (i.e. not a subscription). - Community Centre - Outdoor open access public area - can be a public park, village

green or any other type of outdoor amenity area with unrestricted public access.

Reflects WAG Circular 30/2007 guidance that Gypsy/Traveller sites must be located near to a range of services and amenities. Also reflects IHT guidance for acceptable walking distances.

3d. Access to local amenities/services is provide by safe cycle route:

Within 1000m Within 4000m Within 8000m

+3 +2 +1

+1 Reflects IHT guidance for acceptable cycle distances.

4. Other Considerations 4a. Is the site located within 1000m of other Gypsy/Traveller pitches/sites?

Yes No

0 +1 +1 Other pitches can be authorised or unauthorised or potential future

allocations. 4b. If Yes, what is the total number of pitches? Number of Pitches N/A Identify total number of unauthorised/authorised pitches within 1000m

of a proposed site, including any proposed allocations. 4c. Would there be any harmful impact to local physical/social infrastructure should additional pitches be permitted?

Yes No

0 +1 +1

Provide explanation of what infrastructure impacts might result from allowing additional pitches, e.g. impact on physical infrastructure such as sewage/water capacity and impact on social infrastructure such as capacity of schools.

TOTAL TIER 2 SCORE MIN 10 DOES THE SITE ADVANCE TO TIER 3? YES / NO

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TIER 3 – DELIVERABLITY, DESIGN AND IMPACT Sites achieving the highest Tier 3 scores will be identified as suitable site options or alternative options for consideration.

Issue Score Desired Notes 1. Design and Impact 1a. Site Analysis Considerations:

Overall Impact Microclimate, Topography, Aspect, Level and Quality of Existing Vegetation (trees, hedgerows, etc), Emergency Response Times, Relationship to Services/Amenities, Other Issues

The overall suitability of the site for Gypsy/Traveller use - either for permanent, transit or temporary use - should be assessed and should reflect guidance in WAG Circular 07/2007 and WAG’s “Designing Gypsy and Traveller Sites Good Practice Guide”. Sites should have a natural/logical boundary, or where one is proposed it must be sensitive to the character/appearance of its surroundings. Sites should not be visually intrusive. Adequate response times should be available from Emergency Services.

Policy/Environmental Designations

High Medium Low

0 +1 +2

LOW (+2)

Residential Amenity High Medium Low

0 +1 +2

LOW (+2)

1b. Level and Nature of Impact on:

Landscape Impact High Medium Low

0 +1 +2

LOW (+2)

The development of potential sites for Gypsy/Traveller pitches will only be permitted in areas where there would be no impact on policy designations (adopted or emerging), nationally/locally recognised environmental designations, residential amenity, the surrounding landscape and the character/appearance of the locality, including Conservation Areas. An assessment is undertaken on the level and nature of any impacts.

1c. Where Medium/High in any of the above, mitigation measures address concerns.

Yes No

+1 0 YES (+1) Where appropriate, consideration may be given to possible mitigation

that could address potential harmful impacts.

Air Quality Issues Yes No

0 +1 NO (+1)

Potential Light Nuisance Yes No

0 +1 NO (+1)

1d. Environmental Health

Potential Noise Issues Yes No

0 +1 NO (+1)

Gypsy/Traveller sites are more susceptible to air quality, light and noise issues. Consideration must be given to the impact of these issues on the health and well-being of occupiers of a potential site. Should issues exist, mitigation measures can be considered.

1e. Other appropriate uses be accommodated within the site.

Yes No

+1 0 YES (+1) Must be appropriate to the location and can include: visitor pitches,

shared amenity block, play area, work vehicle parking, stables, etc.

Permanent Gypsy/Traveller Use Yes No

+1 0 YES (+1) 1f. On balance, would the potential site be

suitable for:

Transit Gypsy/Traveller Site Yes No

+1 0 YES (+1)

Having considered all the criteria in the three tiers, would the potential site be suitable for Gypsy/Traveller use?

2. Deliverability 2a. Ease of Acquisition Site Ownership*

Available for Purchase? Is the use of Compulsory Purchase likely?

0-3 YES/NO YES/NO

- YES (+1) NO (+1)

A - Land Value** B - Utility Connection C - Road Infrastructure D - Landscaping E - Mitigation

0-2 0-2 0-2 0-2 0-2

N/A

2b. Notional Cost

Total Notional/Indicative Cost (A+B+C+D+E) X N/A

* Site Ownership: ** Land Value: - Council: +3 - Gypsy/Traveller: None (0) - Gypsy/Traveller: +2 - Council/Public: Nominal (+1) - Other Public Body: +1 - Private: Market (+2) - Private: 0 When Assessing Cost: - Existing works/conditions can be used: 0 - Minimal infrastructure/mitigation works are required: +1 - Significant infrastructure/mitigation works required: +2

TOTAL TIER 3 SCORE and COST MIN 11 FINAL RECOMMENDATION SITE OPTION / ALTERNATE / REJECTED

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ypsy and Traveller Study of Permanent Gypsy and Traveller Sites - General Approach Report

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Torfaen GIdentification

CDN PLANNIN

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APPENDIX BSuggested Site Identification / Assessment Template

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SUGGESTED SITE IDENTIFICATION/ASSESSMENT TEMPLATE

Site Appraisal Site Number Reference number provided for each site Site Name / Address If applicable Location Nearest Settlement to the Site and Site Plan Site Size The area of the site in hectares Current Land Use Is the site Greenfield or previously developed land (Brownfield)? Raw Capacity of the Site

The number of pitches that are proposed on the potential site (where there is current Gypsy and Traveller use on a site, the number of existing pitches is also given)

Site Description & Context

A description of the character and appearance of the site and that of the surrounding area

Tier 1: Location and Constraints Relationship to Settlements

Is the site located within a safe walking (or where one can be made available) of a Local Centre? (ideally within 1200m)

Is the site located within a safe cycle route (or where one can be made available) of a Local Centre? (ideally within 8000m)

Key Social Infrastructure

Is the site located within 1000 or 2000 metres of a primary school, a doctor’s surgery, and a food shop? (as the crow flies)

Policy Constraints Is the site within the Green Belt? Is the site within or in close proximity to any valued area(s)

including internationally/nationally/locally recognised designations?

If so, can any of the above be addressed through mitigation or through sensitive design?

Environmental Constraints

Is the site within or in close proximity to a hazardous area(s) or any significant constraint to development?

If so, can this be addressed through mitigation or through sensitive design?

Planning History Any relevant planning history for the site or part of the site Is the principle of a Gypsy and Traveller development on the site

acceptable? Tier 1 Conclusion Summary of Findings

Does the site warrant further consideration? Tier 2: Access & Infrastructure Transport Infrastructure

Can the site be services by independent vehicular access point, which adheres to the Highway Authority guidance/standards?

Does access to the site avoid routes through built-up areas or is available by distributor roads without the need to use more local roads within industrial areas, recognised commercial areas or housing areas?

Is the existing highway network capable of accommodating the proposed traffic movements?

Does the site have a safe pedestrian and/or cycle access/route to the nearest local centre? (If not, could one be provided?)

Is access to a transport node provided via a safe walking route? (ideally within 400m or at least 800m)

What level of service does the nearest transport node provide?

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(ideally access to at least an hourly service) Site Infrastructure Are utilities (water, electricity, drainage) available on site or

within a reasonable distance away from the site to enable a practical connection?

Does the basic infrastructure have the capacity to serve the maximum site capacity? (If no, are there measures that can be taken to address this?)

Social/Local Infrastructure

Is there access to key local service/amenity? Is there access to at least 1 other local service/amenity? Is there access to at least 1 district service/amenity?

Other Considerations Is the site located within 1000m of other Gypsy and Traveller pitches/sites? If yes, how many pitches?

If yes, would there be any harmful impact to local physical/social infrastructure should additional pitches be permitted?

Can the site accommodate Travelling Showpeople needs in terms of access to key routes, additional on-site storage, etc?

Tier 2 Conclusion Summary of Findings Does the site warrant further consideration?

Tier 3: Impact, Design and Deliverability Design and Impact Site Analysis / Overall Impact / Overall Suitability

Level and nature of impact on Policy/Environmental Designations, Residential Amenity, Landscape Impact

Environmental Health considerations - air quality, light nuisance, noise issues

On balance, would the Potential Site be suitable for: o Permanent Gypsy and Traveller Use? o Transit Gypsy and Traveller Use? o Travelling Showpeople Use?

Deliverability Time of potential delivery (short, medium, long-term) Land ownership Ease of Acquisition Notional Cost - cost of security site (including land value), cost

of demolition/clearing, cost of road layout, cost of utility connection, cost of landscaping, cost of mitigation, total cost (notional, not a real world figure)

Tier 3 Conclusion Summary of Findings Recommendation Site Option, Alternate Option, Rejected Option Note: Maximum walking/cycle distance indicated above is based on IHT guidance - actual walking/cycle distance to reflect IHT guidance or other adopted/approved guidance.

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