P. 192. Policy HOU16. We agree that the new criteria for travellers to qualify for a pitch should be rigorously applied and protection of the landscape should be paramount.

P. 191 Para. 5.120. The limited number of allocated sites and reliance on windfalls, however, may lay the Borough open to criticism for not having a five-year supply of pitches. This would make containment of numbers virtually impossible and lead to sporadic and unplanned development.

HOU 16 new traveller's sites Consideration should be given to identifying brown field sites for such provision as this works effectively elsewhere, e.g. Thamesmead.

This policy must be backed up by enforcement and the Council must do more to help traveller and local communities to build more positive relationships

TRAVELLER SITES Policy HOU 16, referring to new applications should also include points that are in EMP3 Employment Premises – bearing in mind that such sites tend to combine business and residential use, such as: "there would be no significant impact on the amenities of any neighbouring residential occupiers; and that the development can be integrated sensitively into its context, respecting the character of the landscape, existing historic or architecturally important buildings and sites of bi

The criteria should include the same considerations as in EMP 3 because it seems many traveller or gypsy sites combine residential and business or commenrcail or industrial -type use. They are not always solely residential and this needs to be covered adequately.

CPRE broadly supports this policy. Section (g) of the policy omits reference to heritage assets/ designations.

Introduction This submission is made on the basis that the plan is unsound and not legally compliant. This submission has been prepared in respect of both policies S44 and HOU16 and is submitted individually in respect of both. However the statement is a joint submission as the reasons set out apply to both policies as the underlying issues are the same. In essence it is submitted that the Council have not looked adequately for sites for gypsies and travellers that are not located in "sensit

The Parish Council welcomes para 5.125: '...the impact of new Traveller accommodation on existing communities and how well proposals can be integrated is an important consideration in the determination of applications for Traveller provision'. High Halden parish has the highest proportion of traveller and gypsy families of any area in the borough; the parish has 2.1% of the borough's population but 16% of the gypsy and traveller population. Of the children attending the local primary school, 21

Smarden Parish Council are concerned at the lack of provision for Gypsy and Traveller families within the draft Local Plan and the conditions suggested HOU16. We are strongly opposed to the view that it should generally be left for 'windfall sites' to bear the brunt of any incursions by Gypsy and Traveller families which are generally within the rural Parishes as these are clearly the most attractive to move onto. We strongly suggest that many of the conditions suggested are not adhered to, and