brentwood.gov.uk

Support inclusion of policy
Policy should safeguard all existing sites esp whilst there is a need for more sites.
Support the fact need is expressed as a minimum fig as there are issues/ concerns with the ORS 2014 assessment, in particular the use of a low 2% for household formation (not tested against any other assessments yet accounts for more than half of need identified in Brentwood). If ORS assumptions are wrong this could have significant implications for future site provision.

Policy should be committed to careful monitoring of ORS assumptions in particular ability of London authorities to deliver enough sites and how soon. ORS fail to accept importance of in migration in past from inner London and dismiss it as source of need in future. There is no consideration of European Roma.

It is unclear why policy refers to a 5 year supply for 2013-2018. By the time policy is adopted the 5 year supply is more likely to be 2017-2022 is 59 plus 8 ie 67 pitches.

Until and unless the Gov provides an explanation as to what the new definition in PPTS means then no revisions should be made to any need assessment. The 2016 update survey by ORS should not be relied on unless and until it is explained to those interviewed what is meant by travelling and a nomadic way of life and what policy now seeks. For instance many GTs do not regard a visit to a horse fair as travelling as to them travelling is what they did before they settled down ie living a roadside existence and many will quite properly say they do not want to go back to that lifestyle. I have had complaints over the way ORS turned up unannounced to update need assessment and sneak in questions about status. One client was pressured into answering just as she was dashing off on school run. This is not acceptable.

Policy should however stress need to front load provision as there is a large immediate need.

Criteria (a) is wholly unacceptable and unrealistic and will continue to be relied on to thwart provision. Inappropriate development will by definition give rise to unacceptable harm when judged against PPTS/NPPF as made clear in para 7.81. This policy seems set to fail from the outset.

criteria (b) is also unreasonable as few sites are well related to services until/ unless land is found in and close to settlements.

criteria (e) will be used to object to most new sites as in the past.

Support the allocation of three sites in fig 7.5-but why only these? This is not enough to meet the immediate need. It is far from clear how they were chosen and not others. It is far from clear if you propose to inset from the Green Belt and if not why not? How will they be made permanent if not inset from the GB? They will still fail criteria (a) and national policy test.

Dunton Hills can not be relied on to meet immediate need for 59 pitches to 2018 of which only17 have been granted. It is not clear how quickly Dunton Hills can be delivered and how.

Policy must identify suitable sites for the immediate need and a 5 year supply ie 2016-2021 minimum.

Para 7.82-Given the large number of appeals for sites in this district and fact most have only been established on appeal, I do not know how the Council can possibly claim to have good track record of positively considering appropriate windfall sites. There is no obvious consistency in recent decisions and whilst it is welcomed that some have (finally) been made permanent it is far from clear why others have not. There remain far too many sites with temporary/ unauthorised pitches. It is not clear why plots at Lizvale Farm is not listed in Fig 7.5 or the rest of Orchard view given Hope Farm is supported. I am not clear what has happened to Cottage Gardens Beads Hall Lane or whether the Council has, in the alternative, agreed to a replacement house on this site. But if the owner still wants a caravan site this should be included in Fig 7.5 along with the unauthorised pitches at Blackmore and Hunters Green.

Para 7.83 Policy fails to allocate enough to meet the immediate need and fails to indicate broad locations for further provision.

Policy as drafted fails to do what is required. It is not NPPF/PPTS compliant. It will not address the immediate need for sites with no certainty future need will be met either.

More sites need to be put forward to meet the immediate need especially if there is to be reliance on Green belt sites.

Sites need to be inset from the Green Belt so that they stand any chance of being granted permission

Criteria for windfall sites need to be positive and fair. If sites can not be found in settlements then it is wholly unfair to include criteria (a) as this is a contradiction in terms .

There is no consideration of transit sites or how provision will be made. 2014 GTAA identified need for just two transit sites in Essex-bound to be woefully inadequate. Given the revised legal definition of GTs in PPTS Annex 1 far more transit provision must be found and delivered if GTs are to be able to maintain a travelling way of life. Brentwood is exceptionally well placed for Travellers coming to SE for work. Provision should be made along main transport corroders.

It is not clear how provision will be made for non travelling Gypsy Travellers ie those who fail the legal definition in Annex 1 PPTS either because they do not have a driving licence or are to young to legally tow a caravan, are too old to travel, are too infirm to travel, or are unable to travel for work due to caring responsibilities or for other reasons, yet may still retain a cultural preference to live in caravans with their own families and community and whose needs have to be addressed by Equalities Act 2010 .