brentwood.gov.uk

I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.
(2) Paragraph 7.79 states that there is a need for 59 new pitches by 2018 and that planning permission has been granted for 17. This means that provision for another 42 pitches is required by 2018. The only provision identified (paragraph 7.80) is sites for 6 pitches as shown in figure 7.5 and 20 pitches to be allocated within "Dunton Hills Garden Village". Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.
(3) Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. A pitch can accommodate two caravans or chalets to cater for an extended family so 20 pitches could easily amount to about 100 individual travellers. The total need by 2033 is identified as 84 pitches with 23 on identified locations elsewhere. This implies that the total size of the traveller site at Dunton Hills Garden Village could be extended to 50 or even 60 pitches by 2033. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide - says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation.
(4) PPTS section 13 © states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable
(5) PPTS secion 13 (g) states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.
(6) PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.
(7) PPTS Annex 1 section 1 defines "gypsies and travellers" to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.