Gypsy and Traveller Accommodation Local Plan

Chapter 3 - Site and Pitch Assessments

Sustainability Appraisal

3.1 Where Local Plan documents are prepared that have the potential to have significant social, economic or environmental effects, a process known as a Sustainability Appraisal (SA) is undertaken. SA is a statutory requirement of the Planning and Compulsory Purchase Act 2004 and is designed to test a policy document for soundness through the use of social, economic and environmental criteria and promote sustainable development by integrating sustainability considerations into the preparation and adoption of plans.

3.2 The SA process has also been tailored to incorporate the requirements of the European Strategic Environmental Assessment (SEA). The SEA is a process to ensure that plans and policies with land use implications also consider an assessment of the current state of the environment, any significant effects on it and potential mitigation. The overall aims of the combined SA/SEA process are to:

  • Allow the public and stakeholders to input into its production through consulting on the SA process at different stages
  • Make the plan as sustainable as possible by integrating sustainable development into all stages of the plan making process
  • Provide a high level of environmental protection and balance in the plans preparation
  • Provide an environmental, social and economic audit at appropriate levels

Scoping Report

3.3 The Scoping Report is the first stage of SA/SEA preparation and includes borough data and facts and figures such as population, demographics, and specific data relating to Gypsies and Travellers and the boroughs land and environmental designations. This evidence collation led to the creation of a Sustainability Appraisal Framework (SA Framework) which will be used to assess the policies and the sites proposed for inclusion in the plan throughout its evolution.

Site Assessment Criteria

3.4 The published SA Framework within the Scoping Report contains a set of specific site assessment criteria and associated 'scoring' which will be used to assess the sites and pitches for suitability for allocation in the next version of the plan.

3.5 There are 12 overall objectives set out in the SA Framework which cover a broad range of issues and questions that can be used to assess whether a site or pitch is the most sustainable and suitable location for Gypsy and Traveller accommodation to be provided. The Scoping Report can be viewed here as a supporting document to this consultation but the proposed site assessment criteria under each objective is summarised below under each objective title.

1 - Biodiversity

3.6 Many existing and potential traveller sites are located within the rural areas of the borough, and therefore have potential to impact on protected biodiversity and ecological important sites. The SA Scoping Report outlines a number of set criteria that will be assessed to check effects of a site on internationally and nationally designated habitats, wildlife sites and nature reserves, ancient woodlands and other habitat networks such as ponds, hedges and trees, Biodversity Opportunity Area's (BOAs) and Green corridor. Those sites which impact on and harm these environmentally important sites will score more negatively.

2 - Landscape

3.7 The borough contains two Areas of Outstanding Natural Beauty (AONB) which have a higher level of protection than other landscapes. It is directed that these should be protected and enhanced where possible. Sites within them or the setting of them will score more negatively than those outside of the landscape designation. There are also other assessments to be made in relation to local landscape character, settlement character and whether sites/pitches will negatively impact on this or views to/from these features.

3 - Cultural Heritage and Archaeology

3.8 The borough contains a number of heritage assets including Conservation Areas, Listed Buildings, Archaeological sites, Registered Parks and Gardens and Scheduled Monuments. Sites will be assessed to determine if they help improve access to, and understanding of, historical and cultural assets and/or preserve, and where possible, enhance the character and setting of these historic/cultural assets. Historic England suggested this approach at Issues and Options stage.

4 - Water

3.9 The PPTS highlights the particular vulnerability of caravans in relation to flood risk which makes this topic of particular relevance to these assessments. During the Issues and Options consultation, KCC flood team highlighted a number of issues in relation to surface water flooding and ensuring that the EA flood map is considered. They also suggest due consideration is given to possible surface water flood rates. These issues will be assessed as part of site scoring and sites within designated flood zones or which create drainage issues will be scored negatively.

5 - Housing

3.10 Ashford is one of five local authorities with the highest proportion of people who identified as Gypsy or Irish Traveller. The GTAA 2018 data states that the 531 Gypsy or Irish Traveller individuals resided in 167 households. As part of the 167 households, 120 households live in bricks and mortar accommodation and 47 households living in a caravan or other mobile or temporary structure.

3.11 The GTAA identifies a clear need to provide accommodation for this ethnicity group so sites / pitches which contribute to this need will score positively.

6 - Access to Services and Social Inclusion, 7 - Health and Wellbeing and 8 - Sustainable Travel

3.12 These objectives have been grouped together due to these linkages between the subjects.

3.13 The health status of Gypsies and Traveller is known to be much poorer than that of the general population[1] . Poor access to, and uptake of, health services is a major factor and the PPTS seeks to enable provision of suitable accommodation from which Traveller can access health and welfare infrastructure.

3.14 The PPTS seeks to ensure that children can attend school on a regular basis and to enable provision of suitable accommodation from which Traveller can access education infrastructure. The skills / qualifications attained by Traveller in the borough is consistent with the trend at the national level in that a high proportion of the population (aged 16 and above) have no qualifications.

3.15 There are many complex and interwoven factors that may influence the educational attainment of Traveller pupils. The highest proportion of Gypsy or Irish Traveller in the borough falls within the 0-14 age category at 39%. Schools and local authorities can make a big difference to their life chances through:

  • clear high expectations of all pupils, regardless of their background
  • an inclusive culture that welcomes all communities
  • strong engagement from parents[2]

3.17 The Traveller Movement charity supports this view and also report that Gypsies and Traveller have the lowest life expectancy of any ethnic group in the UK and experience higher infant mortality rates than the settled community. Poor living environment, low education attainment, economic exclusion and community isolation also have a negative impact on Gypsies' and Traveller' physical and mental health[3] .

3.18 This reinforces the need to provide sites to allow for a settled base, nearby to existing settlements with these types of local services.

3.19 Therefore sites/pitches which are located in isolated locations or areas of deprivation will be scored negatively, and sites which are closer to settlements with services such as GPs and Schools will school more favourably.

3.20 In addition, sites which have poor vehicle access points, or that do not have good access to footpaths, bus stops and other sustainable travel options in order for residents to access local services and employment will score less favourably.

9 - Infrastructure Delivery and Availability

3.21 The PPTS Policy C states that 'When assessing the suitability of sites in rural or semi-rural settings, local planning authorities should ensure that the scale of such sites does not dominate the nearest settled community'. One aspect of this is to consider the local service provision and infrastructure and whether these would be placed under undue pressure from the identification of a site/pitch in the area. For example, due to the health and education issues mentioned above, whether a local GP surgery or local school has capacity for new residents is an important consideration.

3.22 In addition, there are a number of other site infrastructure needs such as water, drainage, sewerage and electricity connections, which will need to be provided on new sites and these issues will be addressed as part of the overall assessment when determining suitable future site allocations.

10 - Land Use and Geology

3.23 Sites or pitches that are on previously developed land (Brownfield land) or those that would re-use a redevelop and existing site or building will score more favourably than greenfield sites that have not been previously developed.

11 - Minerals, Waste and Soil

3.24 The borough contains a number of land classifications which include sites reserved for minerals, regionally important geological sites and high quality farming land such as Grade 1&2 agricultural land. Sites/pitches which are located in these important classifications will be scored negatively.

12 - Sustainable Economic Growth, Employment and Skills

3.25 Within the Ashford borough, there are higher rates of economically active Gypsy or Irish Traveller respondents than nationally, at 51.7%. Within the economically inactive population, the largest proportion were 'looking after home or family' of 33%, followed by 27% as 'Long-term sick or disabled'.

3.26 The PPTS makes it clear that providing sites that meet the needs of the traditional live/work lifestyle of travellers, for example, by providing enough storage or employment space alongside the residential space, will score more positively as these sites will be supporting the local economy.


1. The health of Gypsies and Travellers in the UK, A Race Equality Foundation Briefing Paper, Matthews, Z. 2008 [back]

Borough pitch distribution and Family Needs

 3.27 The Gypsy and Traveller population of Ashford has historically settled to the west and north of Ashford. This is due to the settlement pattern of travellers within Kent itself, where there are higher populations within the neighbouring authorities to the north and North West of Swale and Maidstone and lower towards the south and east coasts in Folkestone and Hythe and Rother. The extract of the map below is taken from the latest published authorised caravan count data of January 2019[4] and highlights the differences in the South East.

Map 1- Kent wide caravan count data (Source: Number of Authorised Caravans - January 2019 - Extract from MHCLG Count of Traveller Caravans January 2019 England)

3.28 Due to these patterns, some parishes in the borough have a higher number of Gypsies and Traveller in residence. The image below shows the broad settlement patterns, by Parish, of where the Gypsy and Traveller community live in Ashford borough. This was highlighted as a particular issue in the Issues and Options consultation feedback.



Map 2 - Broad distribution of Traveller Sites in Ashford by Parish - January 2019

3.29 The PPTS Policy C states that 'When assessing the suitability of sites in rural or semi-rural settings, local planning authorities should ensure that the scale of such sites does not dominate the nearest settled community'. It is therefore essential to consider the geographical concentration of current sites when addressing the possible location of new or extended sites in order that the overall scale and impact can be assessed.

3.30 We will also assess local services where a site may be in one parish but due to infrastructure and proximity to other villages (within or outside the borough) it might have a greater impact on another settled community than the parish it is located within, or create an unsustainable cumulative pressure.

3.31 However, there is also the issue of family needs to be balanced with the pitch distribution assessment. As set out and calculated for in the GTAA, the need for additional pitches is often derived from the need to accommodate additional family members as they grow older and seek their own accommodation. Culturally, Gypsy and Traveller communities often live and travel together in family groups, even after forming new households through marriage. This may require the expansion of a site to include either an additional caravan, or an additional pitch on a larger site.

3.32 As it may be unrealistic to assume family groups would relocate completely to a new part of the borough as their needs change, existing site expansion is being considered as one of the options for new pitch delivery (see Chapter 4) . It is proposed as Option 1 below that part of the site assessment process for sites requiring expansion will be to address the issue of borough distribution and the family needs as an overall balanced assessment. We are seeking views on this below, and Option 2 provides the opportunity to object to this approach and provide further comments on this issue.