4.2 Local evidence, identified from the bi-annual Gypsy counts and planning history suggests that travellers in Ashford tend to reside on small private sites which accommodate their immediate and extended family.

4.3 Over half the demand for new pitches identified in the GTAA is generated through new family formation. This can often be where children currently resident on sites reach an age where they are likely to need their own accommodation at some point in the plan period. Such accommodation is initially likely to be sought on existing family sites with the creation of an additional pitch.

4.4 There are also some sites with additional pitches in the borough which may have a temporary permission or have been 'tolerated' over time and these have not been formally identified by the GTAA as part of the permanent pitch supply.

4.5 During June and July 2019, Gypsy and Traveller sites across the borough were visited to try to build up an understanding of where there may be extra site capacity and how this was linked to the future need of each site. A number of sites indicated that they had capacity for additional pitches

4.6 Whilst some of these sites may not be suitable for expansion or permanent pitch provision due to environmental or other factors, some of these may be well-related to services and facilities and which would not negatively impact on local character and landscapes are considered to be one of the most deliverable options for future pitch supply.

4.7 The impact of new traveller accommodation on existing communities and how well proposals can be integrated is also an important consideration in the determination of applications for site enlargement. We will include all factors in the full SA assessment process so that we can assess their suitability and ensure we allocate the most sustainable sites/pitches as set out in chapter 3.

4.8 This consultation is also an opportunity for travellers and other residents to suggest specific sites for enlargement or regularisation.

 

4.9 In addition to the options around existing sites, the Council also needs to consider the availability of new sites/pitches across the borough in order to meet the needs identified in the GTAA and to take into account the borough distribution issues outlined in Chapter 3.

4.10 New sites will be assessed in the same way as those for extension which will include a range of considerations such as impacts on the environment and landscape, impact on the residential amenity, access to services and impact on the nearest settled community.

4.11 This consultation is an opportunity for Gypsies, Traveller and other residents to suggest specific new sites to be considered for allocation in the next stage of this document.

4.12 Policy HOU16 of the adopted Local Plan 2030 allows for windfall (currently unidentified) pitches to be delivered, subject to a set of detailed criteria relating to site size, location, living environment, access to local services, on-site services, constraints such as landscape and biodiversity designations, and their scale in relation to the nearest settlement, in accordance with the PPTS guidance.

4.13 The supporting text of the policy states that the policy will be applied until adoption of this specific plan, which will allocate pitches to meet the identified need.

4.14 However, this windfall approach has already delivered a number of pitches (7 since April 2018) against the identified need. It is expected that following allocation of pitches in this plan that the need for windfall delivery of pitches will be less frequent, but there may be circumstances over the plan period where currently unidentified sites/pitches may still come forward to meet a particular household need that cannot be met on one of the allocated sites.

4.15 It is suggested that this policy could be retained following adoption of this Plan, and that the Council can continue to monitor windfall pitch delivery as part of the borough supply. This could be used as a 'buffer' in our supply, to counteract any non-delivery of site allocations (Option 1a). More information on using a supply 'buffer' can be found at Question 3 of this document.

4.16 The second option (1b) is that windfall supply could be determined as a specific amount of future delivery, as it is for general market housing. In these instances, NPPF advises that the estimated amount of future windfall is based on historic evidence of previous windfall delivery. However, as there has been no traveller site allocations in place to meet the needs for many years, the windfall evidence cannot be calculated in this way. We could calculate the estimated windfall as a certain percentage of the historic delivery, or we could calculate all pitches permitted by the Council under HOU16 and discount those granted on appeal. If this option for calculating some of the windfall delivery as supply is supported, we are inviting views on these potential calculation methods (Option 1b below). Option 1c below can be selected if you do not think that any windfall allowance should be counted towards the supply of pitches.

4.17 As this Plan can delete, amend or supersede the adopted windfall policy (HOU16), we are also seeking views on Policy HOU16 and its purpose in Question 2 below. Do you think the assessment criteria in HOU16 is still effective and appropriate or that the policy should be amended or deleted?

4.18 It is also of note that Policy HOU16 also allows sites and plots to meet the needs of Travelling Showpeople, and if the policy is not retained this plan would be need to address this as a separate policy issue. Jump back to Travelling Showpeople section here.

 

4.19 The council provides and manages 16 public pitches to rent at its Chilmington site and this is an important resource, both in terms of contributing to the borough's pitch provision for those than cannot buy pitches privately as well as providing alternative options to help deal with unauthorised encampments.

4.20 The Council will ensure the long term retention of this site for Gypsy and Traveller use by maintaining ownership, but is exploring options to transfer management of the site to a third party. This has been identified as the most practical and achievable way of retaining the supply for those who are unable to secure their own private site.

4.21 The site provides an ongoing supply, and when residents move in and out of the site it is known as pitch 'turnover'. Evidence of pitch voids show that this turnover of pitches is an average of 2 each year over a 10 year period. It is therefore a potential supply option against the need requirements identified in the GTAA and as there are 16 pitches there could potentially be 32 pitches becoming available at some point over the remaining 10 year plan period to 2030.

4.22 However, there is no firm evidence to suggest that vacated pitches on Chilmington will definitely become available within 5-years or the plan period, or that they will be vacated by travellers leaving the borough to move elsewhere, therefore no longer having an accommodation 'need' in Ashford. If moving within the borough, the overall need would not be reduced by turnover. A West Oxfordshire appeal decision found the authority 'unsound' for including turnover in supply figures if there was no evidence of outward migration.

4.23 There are a number of options to be explored which we would like your views on. Option 1 would be to count all the estimated turnover as 'supply' over the plan period. As stated above, this position is considered to be a high-risk strategy if there is no evidence that the occupants are leaving the borough when they leave the site.

4.24 Option 2 is to count a reduced amount, for example 50%, of the turnover - this would result in a supply of 16 pitches to 2030. This would potentially account for those that have not left the borough but have moved within it but still carries a degree of risk as it is estimated, and cannot be evidenced that this 50% calculation of those moving out of the borough would be reality. Option 3 requests views on a different calculation method.

4.25 Option 4 would be to monitor the pitch occupation and turnover at Chilmington and record only those pitches in the supply that are known to have become vacant due to the occupant leaving the borough. This would enable a factual position to be recorded on whether it can be counted towards pitch supply.

4.26 However, this would mean that the supply could not be counted towards the identified pitch target now in the plan, but it could provide a future 'buffer' of additional pitches over the need, to meet any unidentified needs which may arise in the borough during the plan period. This unidentified supply is known as 'windfall' and will provide additional pitches which reduces risk of not having a 5 -year supply in the event of allocated sites not coming forward.

4.27 It is accepted that it may not be the most reasonable option to accommodate all the identified pitch need on new or existing private sites as historically the council has had difficulty in identifying new private sites, and few have come forward from the community itself. This can be for a number of reasons, including financial barriers to land ownership such as the lack of availability of financial products for such purchases or lack of certainty in the planning process.

4.28 In order to meet the pitch requirement without relying solely on privately owned sites, the council is exploring the possibility of delivering an additional public site to meet the needs of those who are unable to purchase private land and need to rent a pitch - See Question 1. It is suggested that this could be delivered by the Council in the same way as Chilmington or through the private sector in close cooperation with the Council - see Question 2. The size of the site will depend on submissions but please provide views through Question 3.

4.29 A public site would need to be located in a sustainable location, with good access to services. At present, there are very limited site options available. The council are therefore requesting land submissions and suggestions for sites which can be assessed in greater detail. It is acknowledged that the management of the current public Chilmington site draws on significant council resources, and proposals for new public sites would need to demonstrate appropriate design and layout and how they can be delivered in a way that promotes peaceful and integrated co-existence between the occupants and the settled community.

 

4.30 It is important to ensure that those sites that benefit from permission for Gypsy and Traveller use currently and that will be allocated through this plan are retained for that purpose since any loss of sites to other uses would require that the council find alternative sites to continue to meet the overall need. The adopted Local Plan 2030 Policy HOU17 currently safeguards these sites and pitches, as set out below:

4.31 This policy has been considered at examination and found sound so Option 1 is that this policy is retained in the Ashford Local Plan 2030 as drafted to ensure that the existing supply is retained which reduces risk of an increase in need.

4.32 However, if the policy is not supported, it could also be amended or deleted through adoption of this plan. The Council has no evidence that the policy is not effective but views are sought below on this in Options 2 and 3.