The following comments have been prepared in partnership with the Brentwood Gypsy Support Group, but are independent.

We welcome the recognition of continuing growth in need during the plan period, but the East of England Plan figures are almost certainly an underestimate of need. The reasons include the points recognised in their report by the Regional Strategy Panel, migration into the area, and the difficulty in assessing the need from housed Travellers, but also because numbers Gypsies and Travellers tend to not self identify because of prejudice, and because some lead are nomadic.

Based on the Brentwood Gypsy Support Group's knowledge of the local Gypsy community, there is an existing need from Travellers on unauthorised development or on temporary permissions for 36 pitches. Together with the existing 10 authorised pitches that suggests a current base need for 46 pitches.

If we then apply the 3% compound annual growth that underpinned the regional strategy and that the Council has used in their calculation it suggests a requirement for a further 30 pitches in the 17 years between 2013 and 2030, a total of 76. 30 pitches from household growth feels of the right scale, based on the needs of the children of the local Gypsy and Traveller community.

We would also advocate an additional allowance for needs from Travellers moving into the area, or from housing. A further 10 pitches would be a small addition, given Brentwood's proximity to London, and the huge difficulties there are in making additional provision within London. In total this would suggest a target for 86 pitches by 2030, a net increase in 76 permanent pitches.

This estimate will be tested by the Essex wide needs assessment being carried out by ORS. But based on our detailed knowledge of the local community, we would question an assessment which suggested a need much less than this.

Recognising that such projections are likely to under-count need, and to avoid the policy being used as a ceiling, we propose the 1st sentence of Policy DM28 should read: Provision should be made within the Borough to meet the need for at least 86 permanent Gypsy and Traveller pitches to 2030.

The provision needs to be front-loaded. If we assume the plan is adopted in 2015, at that point it would require a 5 year supply of deliverable sites ie covering needs to 2020. If we add in half the 10 pitches for housed Travellers / people moving into the area, at adoption in 2015 it would require the base requirement of 46 plus 11 plus 5 pitches, a total of at least 62.

We broadly welcome the criteria for judging planning applications. Compared with those promoted by some councils, they represent a reasonable list.

We would recommend that the sites identified in sections A, B, C and D of the Brentwood Support Group's submission should be allocated for Traveller needs. Roman road Triangle should be 5, not 4 pitches. Together they would provide 36 permanent pitches. The need for provision to be front-loaded gives added importance to existing sites. Unlike pitches provided within new development, they are deliverable now.

We welcome in principle the proposed 14 pitches at West Horndon, but would question a single site of that size. Generally smaller extended family sites work better, and are preferred by the Traveller community, so we would advocate perhaps 3 smaller sites of 5 pitches each.

To accommodate more of the needs we would want to see small Traveller sites incorporated as part of other major developments. Based on an initial appraisal we have identified three of the housing sites in the plan as large enough to include and suitable for Traveller needs. We suggest that those three, Housing sites 13 Council Depot, Warley, 20 Sow & Grow Nursery, Pilgrims Hatch, and 21, Ingatestone Garden Centre should each include a 5 pitch site.

The plan needs to be clear about these requirements. We suggest that the descriptions of these three developments and the West Hordon strategic allocation under Policy DM23 are amended to make this clear. A possible form of words would be: 13 Council Depot, the Drive Warley (081) - (137 dwellings [or an amended figure reflecting the inclusion of the Traveller site], and a 5 pitch Gypsy and Traveller site) etc.

Together these proposals would accommodate 66 pitches, leaving an additional minimum 10 to be identified. This should be done through this development plan process. Given the very strong policy presumption against Traveller sites in Green Belt, it would not be appropriate to leave a balance of sites to come forward through planning applications.

The Traveller community in Brentwood all own their own sites, and would want most of the new provision provided on a private basis. They also recognise that some families cannot afford sites and need to rent. We suggest that the 6 small sites we envisage as part of developments (West Horndon and housing sites 13, 20 & 21) should include 2 or 3 small public sites. This approach is consistent with Government policy, see the 5th bullet under paragraph 4 of Planning policy for traveller sites.

The following comments have been prepared in partnership with the Brentwood Gypsy Support Group, but are independent.

We welcome the recognition of continuing growth in need during the plan period, but the East of England Plan figures are almost certainly an underestimate of need. The reasons include the points recognised in their report by the Regional Strategy Panel, migration into the area, and the difficulty in assessing the need from housed Travellers, but also because numbers Gypsies and Travellers tend to not self identify because of prejudice, and because some lead are nomadic.

Based on the Brentwood Gypsy Support Group's knowledge of the local Gypsy community, there is an existing need from Travellers on unauthorised development or on temporary permissions for 36 pitches. Together with the existing 10 authorised pitches that suggests a current base need for 46 pitches.

If we then apply the 3% compound annual growth that underpinned the regional strategy and that the Council has used in their calculation it suggests a requirement for a further 30 pitches in the 17 years between 2013 and 2030, a total of 76. 30 pitches from household growth feels of the right scale, based on the needs of the children of the local Gypsy and Traveller community.

We would also advocate an additional allowance for needs from Travellers moving into the area, or from housing. A further 10 pitches would be a small addition, given Brentwood's proximity to London, and the huge difficulties there are in making additional provision within London. In total this would suggest a target for 86 pitches by 2030, a net increase in 76 permanent pitches.

This estimate will be tested by the Essex wide needs assessment being carried out by ORS. But based on our detailed knowledge of the local community, we would question an assessment which suggested a need much less than this.

Recognising that such projections are likely to under-count need, and to avoid the policy being used as a ceiling, we propose the 1st sentence of Policy DM28 should read: Provision should be made within the Borough to meet the need for at least 86 permanent Gypsy and Traveller pitches to 2030.

The provision needs to be front-loaded. If we assume the plan is adopted in 2015, at that point it would require a 5 year supply of deliverable sites ie covering needs to 2020. If we add in half the 10 pitches for housed Travellers / people moving into the area, at adoption in 2015 it would require the base requirement of 46 plus 11 plus 5 pitches, a total of at least 62.

We broadly welcome the criteria for judging planning applications. Compared with those promoted by some councils, they represent a reasonable list.

We would recommend that the sites identified in sections A, B, C and D of the Brentwood Support Group's submission should be allocated for Traveller needs. Roman road Triangle should be 5, not 4 pitches. Together they would provide 36 permanent pitches. The need for provision to be front-loaded gives added importance to existing sites. Unlike pitches provided within new development, they are deliverable now.

We welcome in principle the proposed 14 pitches at West Horndon, but would question a single site of that size. Generally smaller extended family sites work better, and are preferred by the Traveller community, so we would advocate perhaps 3 smaller sites of 5 pitches each.

To accommodate more of the needs we would want to see small Traveller sites incorporated as part of other major developments. Based on an initial appraisal we have identified three of the housing sites in the plan as large enough to include and suitable for Traveller needs. We suggest that those three, Housing sites 13 Council Depot, Warley, 20 Sow & Grow Nursery, Pilgrims Hatch, and 21, Ingatestone Garden Centre should each include a 5 pitch site.

The plan needs to be clear about these requirements. We suggest that the descriptions of these three developments and the West Hordon strategic allocation under Policy DM23 are amended to make this clear. A possible form of words would be: 13 Council Depot, the Drive Warley (081) - (137 dwellings [or an amended figure reflecting the inclusion of the Traveller site], and a 5 pitch Gypsy and Traveller site) etc.

Together these proposals would accommodate 66 pitches, leaving an additional minimum 10 to be identified. This should be done through this development plan process. Given the very strong policy presumption against Traveller sites in Green Belt, it would not be appropriate to leave a balance of sites to come forward through planning applications.

The Traveller community in Brentwood all own their own sites, and would want most of the new provision provided on a private basis. They also recognise that some families cannot afford sites and need to rent. We suggest that the 6 small sites we envisage as part of developments (West Horndon and housing sites 13, 20 & 21) should include 2 or 3 small public sites. This approach is consistent with Government policy, see the 5th bullet under paragraph 4 of Planning policy for traveller sites.

The following comments have been prepared in partnership with the Brentwood Gypsy Support Group, but are independent.

We welcome the recognition of continuing growth in need during the plan period, but the East of England Plan figures are almost certainly an underestimate of need. The reasons include the points recognised in their report by the Regional Strategy Panel, migration into the area, and the difficulty in assessing the need from housed Travellers, but also because numbers Gypsies and Travellers tend to not self identify because of prejudice, and because some lead are nomadic.

Based on the Brentwood Gypsy Support Group's knowledge of the local Gypsy community, there is an existing need from Travellers on unauthorised development or on temporary permissions for 36 pitches. Together with the existing 10 authorised pitches that suggests a current base need for 46 pitches.

If we then apply the 3% compound annual growth that underpinned the regional strategy and that the Council has used in their calculation it suggests a requirement for a further 30 pitches in the 17 years between 2013 and 2030, a total of 76. 30 pitches from household growth feels of the right scale, based on the needs of the children of the local Gypsy and Traveller community.

We would also advocate an additional allowance for needs from Travellers moving into the area, or from housing. A further 10 pitches would be a small addition, given Brentwood's proximity to London, and the huge difficulties there are in making additional provision within London. In total this would suggest a target for 86 pitches by 2030, a net increase in 76 permanent pitches.

This estimate will be tested by the Essex wide needs assessment being carried out by ORS. But based on our detailed knowledge of the local community, we would question an assessment which suggested a need much less than this.

Recognising that such projections are likely to under-count need, and to avoid the policy being used as a ceiling, we propose the 1st sentence of Policy DM28 should read: Provision should be made within the Borough to meet the need for at least 86 permanent Gypsy and Traveller pitches to 2030.

The provision needs to be front-loaded. If we assume the plan is adopted in 2015, at that point it would require a 5 year supply of deliverable sites ie covering needs to 2020. If we add in half the 10 pitches for housed Travellers / people moving into the area, at adoption in 2015 it would require the base requirement of 46 plus 11 plus 5 pitches, a total of at least 62.

We broadly welcome the criteria for judging planning applications. Compared with those promoted by some councils, they represent a reasonable list.

We would recommend that the sites identified in sections A, B, C and D of the Brentwood Support Group's submission should be allocated for Traveller needs. Roman road Triangle should be 5, not 4 pitches. Together they would provide 36 permanent pitches. The need for provision to be front-loaded gives added importance to existing sites. Unlike pitches provided within new development, they are deliverable now.

We welcome in principle the proposed 14 pitches at West Horndon, but would question a single site of that size. Generally smaller extended family sites work better, and are preferred by the Traveller community, so we would advocate perhaps 3 smaller sites of 5 pitches each.

To accommodate more of the needs we would want to see small Traveller sites incorporated as part of other major developments. Based on an initial appraisal we have identified three of the housing sites in the plan as large enough to include and suitable for Traveller needs. We suggest that those three, Housing sites 13 Council Depot, Warley, 20 Sow & Grow Nursery, Pilgrims Hatch, and 21, Ingatestone Garden Centre should each include a 5 pitch site.

The plan needs to be clear about these requirements. We suggest that the descriptions of these three developments and the West Hordon strategic allocation under Policy DM23 are amended to make this clear. A possible form of words would be: 13 Council Depot, the Drive Warley (081) - (137 dwellings [or an amended figure reflecting the inclusion of the Traveller site], and a 5 pitch Gypsy and Traveller site) etc.

Together these proposals would accommodate 66 pitches, leaving an additional minimum 10 to be identified. This should be done through this development plan process. Given the very strong policy presumption against Traveller sites in Green Belt, it would not be appropriate to leave a balance of sites to come forward through planning applications.

The Traveller community in Brentwood all own their own sites, and would want most of the new provision provided on a private basis. They also recognise that some families cannot afford sites and need to rent. We suggest that the 6 small sites we envisage as part of developments (West Horndon and housing sites 13, 20 & 21) should include 2 or 3 small public sites. This approach is consistent with Government policy, see the 5th bullet under paragraph 4 of Planning policy for traveller sites.

The following comments have been prepared in partnership with the Brentwood Gypsy Support Group, but are independent.

We welcome the recognition of continuing growth in need during the plan period, but the East of England Plan figures are almost certainly an underestimate of need. The reasons include the points recognised in their report by the Regional Strategy Panel, migration into the area, and the difficulty in assessing the need from housed Travellers, but also because numbers Gypsies and Travellers tend to not self identify because of prejudice, and because some lead are nomadic.

Based on the Brentwood Gypsy Support Group's knowledge of the local Gypsy community, there is an existing need from Travellers on unauthorised development or on temporary permissions for 36 pitches. Together with the existing 10 authorised pitches that suggests a current base need for 46 pitches.

If we then apply the 3% compound annual growth that underpinned the regional strategy and that the Council has used in their calculation it suggests a requirement for a further 30 pitches in the 17 years between 2013 and 2030, a total of 76. 30 pitches from household growth feels of the right scale, based on the needs of the children of the local Gypsy and Traveller community.

We would also advocate an additional allowance for needs from Travellers moving into the area, or from housing. A further 10 pitches would be a small addition, given Brentwood's proximity to London, and the huge difficulties there are in making additional provision within London. In total this would suggest a target for 86 pitches by 2030, a net increase in 76 permanent pitches.

This estimate will be tested by the Essex wide needs assessment being carried out by ORS. But based on our detailed knowledge of the local community, we would question an assessment which suggested a need much less than this.

Recognising that such projections are likely to under-count need, and to avoid the policy being used as a ceiling, we propose the 1st sentence of Policy DM28 should read: Provision should be made within the Borough to meet the need for at least 86 permanent Gypsy and Traveller pitches to 2030.

The provision needs to be front-loaded. If we assume the plan is adopted in 2015, at that point it would require a 5 year supply of deliverable sites ie covering needs to 2020. If we add in half the 10 pitches for housed Travellers / people moving into the area, at adoption in 2015 it would require the base requirement of 46 plus 11 plus 5 pitches, a total of at least 62.

We broadly welcome the criteria for judging planning applications. Compared with those promoted by some councils, they represent a reasonable list.

We would recommend that the sites identified in sections A, B, C and D of the Brentwood Support Group's submission should be allocated for Traveller needs. Roman road Triangle should be 5, not 4 pitches. Together they would provide 36 permanent pitches. The need for provision to be front-loaded gives added importance to existing sites. Unlike pitches provided within new development, they are deliverable now.

We welcome in principle the proposed 14 pitches at West Horndon, but would question a single site of that size. Generally smaller extended family sites work better, and are preferred by the Traveller community, so we would advocate perhaps 3 smaller sites of 5 pitches each.

To accommodate more of the needs we would want to see small Traveller sites incorporated as part of other major developments. Based on an initial appraisal we have identified three of the housing sites in the plan as large enough to include and suitable for Traveller needs. We suggest that those three, Housing sites 13 Council Depot, Warley, 20 Sow & Grow Nursery, Pilgrims Hatch, and 21, Ingatestone Garden Centre should each include a 5 pitch site.

The plan needs to be clear about these requirements. We suggest that the descriptions of these three developments and the West Hordon strategic allocation under Policy DM23 are amended to make this clear. A possible form of words would be: 13 Council Depot, the Drive Warley (081) - (137 dwellings [or an amended figure reflecting the inclusion of the Traveller site], and a 5 pitch Gypsy and Traveller site) etc.

Together these proposals would accommodate 66 pitches, leaving an additional minimum 10 to be identified. This should be done through this development plan process. Given the very strong policy presumption against Traveller sites in Green Belt, it would not be appropriate to leave a balance of sites to come forward through planning applications.

The Traveller community in Brentwood all own their own sites, and would want most of the new provision provided on a private basis. They also recognise that some families cannot afford sites and need to rent. We suggest that the 6 small sites we envisage as part of developments (West Horndon and housing sites 13, 20 & 21) should include 2 or 3 small public sites. This approach is consistent with Government policy, see the 5th bullet under paragraph 4 of Planning policy for traveller sites.