Gypsy and Traveller and Traveller Showpeople Development Plan Document (G&T DPD)

DRAFT

Gypsy and Traveller and Travelling Showpeople

Site Allocations Development Plan Document 2018 – 2036

Regulation 19 Publication November 2023

TABLE OF CONTENTS

PREFACE

1.0 INTRODUCTION

1.1 General introduction

1.2 What is the purpose of the Site Allocations document?

1.3 Background and next steps in preparing the G&T DPD

2.0 NATIONAL AND LOCAL POLICY CONTEXT

2.1 National Policy Context

2.2 Local Policy Context

3.0 ACCOMMODATION NEEDS ASSESSMENT

4.0 TRANSIT PROVISION

5.0 CURRENT AND FUTURE PROVISION

6.0 THE SITE IDENTIFICATION AND ASSESSMENT PROCESS

7.0 SITE ASSESSMENT AND DELIVERABILITY

8.0 DUTY TO COOPERATE

9.0 PROPOSED POLICIES

10.0 MONITORING AND REVIEW

(published separately for this consultation)

11.0 PROPOSED SUBMISSION Policies map (WITH INSETS)

12.0 G&T DPD SITE Delivery Study 2023

13.0 G&T DPD Sustainability Appraisal 2023

14.0 Technical Note: Gypsy, Traveller and Travelling Showmen Access Review 2023

15.0 Technical Note: Summary of flood predictions at Gypsy & Traveller site allocations 2023

16.0 Explanatory Note: Arun Gypsy & Traveller and Traveller Showman Local Plan - Significance of PPG Changes with regard to Flooding and Climate Change, Sequential and Exceptions Tests

This document is also available to download as a PDF:  G&T Regulation 19 Publication DPD - Gypsy and Traveller and Traveller Showpeople Development Plan Document (G&T DPD) [pdf] 1MB

Preface

1. This document is the Arun Gypsy & Traveller and Travelling Showpeople Site Allocations Development Plan Document 2018-2036 (G&T DPD) which is at  Publication stage (i.e. Regulation 19 of ‘The Town and Country Planning (Local Planning) (England) Regulations 2012’). The public consultations runs for 6 weeks from 13^th December 2023 closing on 24^th January (5pm) 2024.
2. At this stage, you can view the document and associated evidence studies including the Sustainability Appraisal and can only comment on legal and soundness matters in relation to the G&T DPD.
3. You can respond to the consultation by accessing the council’s web page here and commenting on the document using the online portal. https://www.arun.gov.uk/gypsy-and-traveller-development-plan-document-dpd
4. Alternatively, you can download the online form (or ask for copies at your local library or the main reception at the Civic Office in Littlehampton and at Bognor Regis where these consultation documents can also be inspected) and email your response electronically to the address at the foot of this page or send hard copy via post. Please ensure that you read the guidance notes on how to respond which will also be available at these locations.

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1.0 Introduction

1.1 General introduction

1.1.1   This document is the Arun Gypsy & Traveller and Travelling Showpeople Site Allocations Development Plan Document 2018-2036 (G&T DPD). The G&T DPD is a statutory Local Plan for decision making and determining planning applications, as it forms part of the Development Plan for Arun which includes the Adopted Arun Local Plan 2018 (ALP 2018).

1.1.2   The G&T DPD sets out how future Gypsy & Traveller and Traveller Showpeople (G&T) needs will be accommodated. Specifically, it sets out provision for Gypsy & Traveller pitches and Traveller Showmen plots, to accommodate the identified need in Arun over the period 2018 to 2036. In producing this G&T DPD the council has considered responses to the earlier G&T ‘Preferred Options’ consultation in October 2020 including an Issues & Options consultation in November 2019 together with a number of existing and new evidence studies in order to assess the potential suitability and deliverability of the sites.

1.1.3   The G&T DPD therefore, sets out the council’s approach to meeting future G&T accommodation needs (i.e. the need for 9 pitches and 14 plots) through policies:-

• Safeguarding eight existing Gypsy & Traveller (G&T) sites and five Traveller Showpeople (TP) sites (including a new broad location); and
• Proposing three existing G&T sites for pitch intensification and three existing TP sites for plot intensification;
• Allocating broad location for a new site towards the end of the plan period to accommodate a residual need for 1 pitch;
• Site delivery criteria for Development Management purposes.

1.1.4   Separate to the G&T DPD, the ALP 2018 provides policy criteria for determining windfall G&T pitch and plot planning applications. It does not however, make specific site allocations for G&T needs. This is because the Government changed the definition of G&T households during preparation of the ALP 2018 (i.e. ‘Planning Policy for Traveller Sites’ August 2015) requiring an update to the supporting evidence on G&T need set out in a Gypsy & Traveller & Traveller Showpeople Accommodation Needs Assessment 2015 (GTAA 2015).

1.1.5    To allow for the GTAA 2015 to be updated, Policy H SP5 ‘Traveller & Traveller Showpeople accommodation’ (clause 4) and supporting text (paragraph 12.7.6) of the ALP 2018 required Arun District Council to prepare a separate G&T DPD to make site allocations to meet revised needs to be set out in the updated GTAA. The updated joint GTAA study (jointly commissioned with other authorities across West Sussex) was published in October 2018 and re-published with an addendum in April 2019 as the final signed off document (i.e. Joint GTAA 2019).

1.2 What is the purpose of the Site Allocations document?

1.2.1   The G&T DPD is necessary in order to allocate suitable G&T pitches and TS plots that are deliverable and viable in order to accommodate the identified need set out in the updated joint GTAA 2019. The G&T DPD must also include policies to be applied to the safeguarding and allocation of sites for intensification and to regulate their development.

1.2.2   The G&T DPD and ALP 2018 together, form part of the Development Plan to guide development management decisions through the planning process.

1.3 Background and next steps in preparing the G&T DPD

1.3.1   The stages achieved and next steps in the preparation of the G&T DPD are as follows:

Evidence base gathering

• GTAA 2015 updated to the Joint GTAA April 2019 based on the new planning definition of G&T households and rebasing need to start in 2018 to 2036;
• Call for sites 2018 (inviting landowners to offer available land for G&T purposes);
• Arun District Gypsy and Traveller Site Identification Study April 2019 (DLP Planning Ltd) identifying deliverable sites (i.e. suitable, available, and achievable) to address GTAA 2019 accommodation needs;
• Sustainability Appraisal (Lepus consultants) of the site options in conjunction with the G&T Site Identification Study.

Issues and Options Document

• Regulation 18 (Part 1) – Issues & Options consultation seeking views on site options, site selection/assessment methodology and delivery matter;
• Responses informed draft policy formulation and site allocations for pitches and plots to be set out in the draft ‘Preferred Options’ G&T DPD.

Gypsy & Traveller and Travelling Showpeople Site Allocations Development Plan Document ‘Preferred Options’

• Regulation 18 (Part 2) – Preferred Options consultation with amended site allocations and policies following Issues & Options consultation;
• Sustainability Appraisal of the site allocations and policies changes.

Gypsy & Traveller Publication Development Plan Document [The Current Stage]

• Regulation 19 Publication G&T DPD consultation inviting comments on legal and soundness issues before submission to the Secretary of State by the council as a ‘sound’ plan;
• Call for sites 2023 (inviting landowners to offer available land for G&T purposes - non received);
• Any representations made on the soundness of the G&T DPD will be published and forwarded to the Inspector to consider at Examination;
• The council may invite the Inspector to make main modifications to the plan in light of this.

Examination in public

• A formal hearing conducted by a Planning Inspector to consider evidence on matters and issues identified by the Inspector, inviting supporters and objectors to the plan to present evidence at the hearing.

Adoption

• If the plan is found to be sound as a result of the Examination in Public with or without Modifications and further consultation, it is adopted by the council and becomes a statutory part of the development plan. Development management decisions will need to be in accordance with this unless material indications indicate otherwise.

1.4 Current Evidence Base and Approach to Meeting Needs in the G&T DPD

1.4.1   Following the G&T ‘Preferred Options’ DPD consultation, a number of issues addressed in that document were maintained by some stakeholders in their consultation responses which broadly related to: -

• Highways, access and traffic impact.
• Flood risk and sewerage;
• Landscape, heritage and amenity.

1.4.2   Further evidence work was therefore commissioned and added to the existing evidence base. The existing evidence base included:-

• Joint GTAA April 2019 (identifying the 9 pitch and 14 plot requirements over the period 2018- 2036;
• G&T Site Identification Study 2019 which identified the most suitable, available, achievable (i.e. deliverable) sites while sieving out those are not deliverable;
• G&T Sustainability Appraisal 2019 (Lepus Consulting) which assessed the sites for sustainability including economic, social and environmental considerations to assess the sustainability effects of the emerging G&T DPD and to ensure that its preparation and assessment meets the requirements of the SEA Directive [1] 2001/42/EC. An updated G&T SA 2023 has been prepared to inform the site selection and deliverability.

1.4.3   The additional evidence work added to the evidence base to address outstanding matters includes: -

• G&T Site Deliverability Study 2023 (Troy Planning & Design consultants) which demonstrates feasible site layouts of pitches and plots to address landscaping and amenity and to avoid future surface water flooding (where some sites are affected by future Climate Change allowances), including finding additional pitch and plot capacity;
• Sustainability Appraisal 2023 (Lepus consultants) which demonstrates the sustainability of the sites and the G&T DPD economically, socially, and environmentally;
• Technical Note: Gypsy, Traveller and Travelling Showmen - Access Review 2023 (WSP consultants) which demonstrates that there are no significant traffic impacts on the highway network from the sites (having minimal intensification of pitches and plots) although several sites may need visibility/safety mitigation (provision for such measures are included within the criteria for the Development Management Policy G&T DM1 ‘Site Delivery Criteria’);
• Technical Note: Summary of flood predictions at Gypsy & Traveller site allocations 2023 (JBA consultants) which demonstrates that new Environment Agency Climate Change allowances do not adversely impact on sites or can be mitigated (through locating pitches and plots away from areas at risk), with the exception of Dragonfly (ARU051) and the Caravan site (ARU-NS-1) which should not be proposed for intensification;
• Explanatory Note: Arun Gypsy & Traveller and Traveller Showman Local Plan - Significance of PPG Changes with regard to Flooding and Climate Change, Sequential and Exceptions Tests, which shows that there are no reasonably available alternative sites to meet G&T needs based on the site evidence.

1.4.4   The additional evidence work has therefore, demonstrated that the proposed approach to meet G&T needs though intensifying on existing sites and allocating a broad location towards the end of the plan period is the correct approach with the exception of proposed pitch intensification on Dragonfly (ARU051) and A259 Caravan sites (ARU_NS_1):-

• Dragonfly Site Eastergate was identified for intensification for 1 pitch, but it is impacted by future climate change AEP scenarios for surface water flooding across the whole site and therefore no longer being proposed for intensification. This shortfall of 1 pitch will be accommodated on the broad location at Little Meadow Bilsham Corner towards the end of the plan period.
• The Caravan Site contributes existing 1 pitch towards the baseline need (being implemented in 2018) and was also identified for intensification for 1 additional pitch. However, the evidence indicates that while traffic impact is acceptable, other highway safety considerations (e.g. the study recommended that acceleration and deceleration lanes requiring land take, be considered on the A259 highway) including amenity make intensification unsustainable. Therefore, no additional intensification is proposed for the Caravan Site, and this is offset by additional capacity being identified by the Delivery Study at Limmer Pond for an additional pitch.
• The G&T Delivery Study identifies additional spare capacity for 1 TS plot at Aldingbourne Farm Shop which removes the deficit of 1 TS plot towards the end of the plan period.

1.4.5   The Publication G&T DPD therefore proposes to meet the identified need for 9 permanent Gypsy & Traveller Pitches and 14 permanent Traveller Showpeople Plots over the period 2018 to 2036. This provision is set out through small scale intensification on existing sites and one new site as a Broad Location to accommodate 1 pitch, at Little Meadow, Yapton (ARU-HELAA-46b) towards the end of the plan period. The reduced number of sites identified for intensification are therefore:-

Existing G&T Sites

• Fieldview, Junction (ARU031).
• Limmer Pond Stables (ARU049).
• 2 Wyndham Acres (ARU044).

Existing TS Sites

• Aldingbourne Farm Shop AL4714.
• The Old Barns (ARU054).
• Nyton Stables (ARU046).

1.4.6   Chapter 9 of the G&T DPD sets out the revised policy approach

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2.0 NATIONAL AND LOCAL POLICY CONTEXT

2.1 National Policy Context

2.1.1   Plan making, evidence preparation, policy formulation and decision making for the accommodation of needs of Gypsies and Travellers and Travelling Showpeople should comply with:-

• the statutory duties of section 8 of the Housing Act 1985 (as amended by section 124 of the Housing and Planning Act 2016);
• the Planning and Compulsory Purchase Act 2004 and the Town and Country Planning (Local Development) (England) Regulations 2012;
• NPPF July 2023;
• PPTS August 2015;
• PPG  (2020) and as amended;
• the Draft guidance to local housing authorities on the periodical review of housing needs: caravans and houseboats (March 2016);
• the Equalities Act 2010.

2.1.2   To be found ‘sound’ a DPD will need to have complied with the above legal and plan making regulatory requirements, including national policy e.g. as set out in the National Planning Policy Framework (NPPF) 2023. The NPPF requires DPDs to set out strategic polices (e.g. overall spatial strategy, quantum of need etc.) and local policies (e.g. allocating sites or providing development management criteria). In addition, the  NPPF sets out the ‘soundness’ tests which require DPDs to be ‘positively prepared’ (e.g. meeting objective needs) ‘justified’ (e.g. an appropriate strategy) and ‘effective’ (e.g. deliverable).

2.1.3   Significantly, the household definition for G&T households changed in 2015 with the Government publishing PPTS (2015). The planning definition is set out in Annex 1 and states that:-

“For the purposes of this planning policy ‘gypsies and travellers’ means: Persons of nomadic habit of life whatever their race or origin, including such persons who on grounds only of their own or their family’s or dependants’ educational or health needs or old age have ceased to travel temporarily, but excluding members of an organised group of travelling showpeople or circus people travelling together as such. In determining whether persons are “gypsies and travellers” for the purposes of this planning policy, consideration should be given to the following issues amongst other relevant matters: a) Whether they previously led a nomadic habit of life. b) The reasons for ceasing their nomadic habit of life. c) Whether there is an intention of living a nomadic habit of life in the future, and if so, how soon and in what circumstances. For the purposes of this planning policy, ‘travelling showpeople’ means: Members of a group organised for the purposes of holding fairs, circuses or shows (whether or not travelling together as such). This includes such persons who on the grounds of their own or their family’s or dependants’ more localised pattern of trading, educational or health needs or old age have ceased to travel temporarily, but excludes Gypsies and Travellers as defined above.” (Planning Policy for Traveller Sites, Department for Communities and Local Government (DCLG), August 2015).

2.1.4   The NPPF requires Local Planning Authorities (LPAs) to identify and allocate sufficient sites to meet the needs of Gypsies, Travellers and Travelling Showpeople within DPDs by providing specific deliverable sites sufficient to provide 5 years’ worth of sites against locally set targets and to identify a supply of specific developable sites or broad locations for growth for years 6-10 and where possible years 11-15. The primary guidance for undertaking the assessment of housing need for Gypsies, Travellers and Travelling Showpeople is set out in the PPTS (2015). This states that allocated sites must be evidenced as both deliverable and developable. Footnotes 4 and 5 to Paragraph 10 of the Planning Policy for Travellers Sites (PPTS) defines the terms ‘deliverable’ and ‘developable’ as:-

4 “To be considered deliverable, sites should be available now, offer a suitable location for development, and be achievable with a realistic prospect that development will be delivered on the site within five years. Sites with planning permission should be considered deliverable until permission expires, unless there is clear evidence that schemes will not be implemented within 5 years, for example they will not be viable, there is no longer a demand for the type of units or sites have long term phasing plans”.

5 “To be considered developable, sites should be in a suitable location for traveller site development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged”.

2.1.5   However, PPTS 2015 should be read in conjunction with the NPPF which includes further requirements for sites to be considered ‘Deliverable’ (Appendix 2 Glossary).

2.1.6   In addition, the Housing and Planning Act makes provisions for the assessment of need for those Gypsy, Traveller and Travelling Showpeople households living on sites and yards who do not meet the planning definition – through the assessment of all households living in caravans. The Objectively Assessed level of need behind the Adopted Arun Local Plan already includes an allowance for such need as referred to in the joint GTAA April 2019 (see also sections 5.15 and 5.1.4 below).

2.1.7   The G&T DPD is being developed in accordance with the requirements of the Planning and Compulsory Purchase Act 2004 and the Town and Country Planning (Local Development) (England) Regulations 2012.

2.2 Local Policy Context

2.2.1   The Development Plan for Arun District, for the areas falling outside of the South Downs National Park includes:-

• The Arun Local Plan 2011-2031(Adopted July 2018).
• The West Sussex Joint Minerals Local Plan 2018.
• The West Sussex Waste Local Plan 2014.
• The ‘Made’ Neighbourhood Development Plans.

2.2.2   Arun District Council adopted the Arun Local Plan 2011-2031 in July 2018 (ALP 2018), The ALP2018 now forms part of the statutory development plan for Arun District covering the local planning authority area outside of the South Downs National Park. The ALP 2018 sets out the spatial development strategy and growth for the years up to 2031 to deliver the social, economic and environmental needs of the area. The ALP 2018 sets out the strategic polices for the area which includes the number of homes which need to be built in the in the period to 2031, together with Strategic Allocations for development, key employment policies and development management policies to ensure that development protects the environment and landscape within the district.

2.2.3   Within the ALP 2018, Chapter 12 sets out how housing needs will be delivered in the District and this chapter includes how particular housing needs for Gypsies and Travellers will be accommodated for the period to 2031.

2.2.4   Section 12.7 of the ALP 2018 helps to ensure accommodation needs for Gypsies and Travellers are met across the Plan area. Policy H SP5 Traveller and Travelling Showpeople accommodation, states that:-

'Arun District Council will produce a Gypsy and Traveller and Travelling Showpeople Site Allocations document (DPD) to identify land for permanent pitches to meet the need identified.’

2.2.5   The policy also safeguards existing Gypsy and Traveller pitches and Traveller showmen sites:-

‘Planning permission will not normally be granted for development involving the loss of lawful accommodation for Gypsy and Travellers and Travelling Showpeople unless alternative provision is made to make good any loss.’

2.2.6   Nine criteria a)-j) are also included within Policy H SP5 to guide the allocation or approval of sites. The policy and full Arun Local Plan 2018 can be accessed here:-

https://www.arun.gov.uk/adopted-local-plan

2.2.7   The G&T DPD, once adopted, will sit alongside the ALP 2018 other DPDs and ‘made’ (adopted) Neighbourhood Plans. The G&T DPD will cover the whole of the Arun District.

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3.0 ACCOMMODATION NEEDS ASSESSMENT

3.1.1   The evidence on accommodation needs is required to comply with the statutory duties of section 8 of the Housing Act 1985 (as amended by section 124 of the Housing and Planning Act 2016) and was prepared in accordance with national policy including the NPPF 2021, PPTS 2015, the Draft guidance to local housing authorities on the periodical review of housing needs: caravans and houseboats (March 2016) and the Equalities Act 2010. The evidence covers the needs of Gypsies and Travellers as well as the needs of Travelling Showpeople.

3.1.2   In respect of meeting the above requirements, the council commissioned and updated the Gypsy & Traveller & Traveller Showpeople Accommodation Needs Assessment (GTAA) which sets out the objective evidence on G&T need incompliance with the legislative and national policy requirements.

3.1.3   The previous GTAA2015 covered the period 2012-2027 and the new Joint GTAA 2019 covers the period 2018-2036. For the period 2012-2017 the new Joint GTAA 2019 assessment assumes that supply and demand net to zero, and the new assessment then starts with a new baseline and identifies all current and future need as of January 2018. As such, there is no unmet need to be provided for the preceding period under the new planning definition.

3.1.4   One of the main considerations is to provide evidence to support the provision of pitches and plots to meet the current and future accommodation needs of Gypsies, Travellers and Travelling Showpeople. A pitch is an area normally occupied by one household, which typically contains enough space for one or two caravans but can vary in size [1]. A site is a collection of pitches occupied by Gypsies and Travellers. For Travelling Showpeople, the most common descriptions used are a plot for the space occupied by one household and a yard for a collection of plots occupied by Travelling Showpeople.

[1] Whilst it has now been withdrawn, Government Guidance on Designing Gypsy and Traveller Sites recommended that, as a general guide, an average family pitch must be capable of accommodating an amenity building, a large trailer and touring caravan, parking space for two vehicles and a small garden area.

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4.0 TRANSIT PROVISION

4.1.1   PPTS (2015) requires an assessment of the need for any transit sites or temporary stopping places.  In order to investigate the potential need for transit provision when undertaking work to support the Joint GTAA 2019 study, ORS sought to review the West Sussex Transit Study (2013); to undertake analysis of any records of unauthorised sites and encampments; and to review information from the MHCLG Traveller Caravan Count. The outcome of the interviews with Council Officers, Officers from neighbouring local authorities and other stakeholders was also taken into consideration when determining this element of need in the study area.

4.1.2   Due to potential changes to travelling behaviour as a result of changes to the PPTS in 2015, the use of historic evidence to assess current and future transit need is not recommended by the Joint GTAA 2019. Any recommendations for any new transit provision will need to make use of a robust post-PPTS (2015) evidence base. It is therefore recommended that the situation relating to levels of unauthorised encampments throughout the area should be monitored over the next few years whilst any potential changes associated with PPTS (2015) develop. West Sussex County Council are now the lead authority for monitoring unauthorised encampments (since 2019) in Arun and following recent contact have not indicated that any issues are known that the existing Public Transit site in Chichester does not currently as address with respect to unauthorised encampments.

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5.0 CURRENT AND FUTURE PROVISION

5.1.1 The assessment of current and future provision is based upon a combination of the household interviews, planning records, stakeholder interviews and a ‘call for sites’. In many cases, the interview data is not used in isolation, but instead is used to validate information from planning records or other sources, on current provision and potential supply.

5.1.2 The baseline data on supply is set out in the Joint GTAA 2019. It is notable that there is 1 public site with 12 pitches; 7 private sites with permanent planning permission for 17 pitches. There are no sites with temporary planning permission; no sites that are tolerated for planning purposes. There is 1 unauthorised site with 2 pitches and 5 Travelling Showpeople yards with 20 plots.

Table 1: Total amount of provision in Arun (January 2018) GTAA 2019

(this table sets out the supply of existing sites, purely numerically, in 2018, as lifted from the 2019 Gypsy and Travelling Showpeople Availability Assessment)

Total amount of provision in Arun (January 2018) GTAA 2019

Status	Sites/Yards	Pitches/Plots
Private sites with permanent planning permission	7	17
Private sites with temporary planning permission	0	0
Public sites (Council and Registered Providers)	1	12
Public transit provision	0	0
Private transit provision	0	0
Tolerated sites	0	0
Unauthorised sites	1	2
Travelling Showpeople yards	5	20

5.1.3 Gypsies and Travellers that meet the Planning Definition: There is a need for 9 additional permanent pitches in Arun over the JGTAA base 2018 period to 2036 for Gypsy and Traveller households that met the planning definition; a need for up to 3 additional pitches for unknown Gypsy and Traveller households that may meet the planning definition; and a need for 13 additional pitches for Gypsy and Traveller households who did not meet the planning definition.

5.1.4   It is not a requirement for the Joint GTAA 2019 to include an assessment of need for households that do not meet the planning definition (this will already be a component of the Objectively Assessed Need for the adopted Arun Local Plan) and will not therefore be a matter for the DPD but will be addressed by the policies of the adopted ALP 2018. The Joint GTAA 2109 also advises that because of the sample size and uncertainty over the status of the 3 unknown households (that may meet the planning definition), that these needs should be appropriately addressed through the criteria policies of the ALP 2018.

5.1.5   Travelling Showpeople: There is a need for 14 additional plots in Arun over the JGTAA base 2018 period to 2036 for Travelling Showpeople households that meet the planning definition; a need for up to 1 additional plot for unknown Travelling Showpeople households that may meet the planning definition; and a need for no additional plots for Travelling Showpeople households who did not meet the planning definition. The unknown household needs should therefore, be appropriately addressed through the criteria policies of the ALP 2018.

5.1.6   The DPD only needs to allocate specific deliverable sites for pitches and plots for the first 1-5 years and identify developable sites or broad locations for years 6 to 10 and 11-15 and beyond if possible. This would include any identified need for transit provision – however, there is not currently a requirement for transit provision in Arun - subject to future monitoring.

5.1.7   Therefore the G&TT 2019 identified needs to be addressed in the G&T DPD are as below:

Table 2: Pitch needs- Gypsy and Travellers that met the Planning Definition GTAA 2019

(this tale sets out the number of pitches needed for the years of the plan).

Table 2: Pitch needs- Gypsy and Travellers that met the Planning Definition GTAA 2019

Years	0-5 2018-23	6-10 2023-28	11-15 2028-33	16 2033-34	17 2034-35	18 2035-36	Total
	5	1	2	0	0	1	9

Table 3: Plot needs - Travelling Showpeople that met the Planning Definition

(this table sets out the number of plots needed against the years of the plan).

Table 3: Plot needs - Travelling Showpeople that met the Planning Definition

Years	0-5 2018-23	6-10 2023-28	11-15 2028-33	16 2033-34	17 2034-35	18 2035-36	Total
	11	2	1	0	0	0	14

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6.0 THE SITE IDENTIFICATION AND ASSESSMENT PROCESS

6.1.1   The council appointed Consultants DLP Planning Ltd in 2018 to provide evidence to help assess and identify suitable sites to address identified accommodation needs.  The result of this study was reported in the Arun District Gypsy and Traveller Site Identification Study (G&T SIS April 2019). At the same time Lepus consultants were appointed to undertake a Sustainability Appraisal alongside the Site Identification Study and this was reported in the Arun District Council Gypsy & Traveller Development Plan Document Regulation 18 Report February 2019 (G&T SA February 2019).

6.1.2   The G&T SIS April 2019 and G&T SA February 2019 evidence informed the Regulation 18 (Part 1) Issues and Options consultation and Regulation 18 (Part 2) draft G&T DPD ‘Preferred Options’ consultation. Representations from these consultations   have been considered together with the Gypsy and Traveller Site Deliverability Study 2023, The were used to shape this submission G&T DPD Regulation 19 document.

6.1.3   The review of sites included sources from:-

• ‘Call for Gypsy and Traveller Sites’ consultation October 2018;
• Sites promoted through the ‘HELAA Call for Sites’ consultation May 2018;
• Authorised Sites;
• Unauthorised Sites;
• Sites with a previous planning history of G&T / TSP;
• Sites with live planning applications;
• West Sussex County Council land;
• Arun District Council Owned Land; and
• Surplus Public Sector Land.

6.1.4   The G&T SIS April 2019 and G&T SA February 2019 methodology screened each site following a 2 staged approach which firstly integrated NPPF considerations:-

• Suitability;
• Availability;
• Developability (e.g. viable and deliverable).

Part 1

• First stage of the assessment involved screening 47 sites on the basis of fundamental criteria (coded red) at a high level to screen out sites inherently unsuitable due to significant constraints e.g. national designations, scheduled monuments etc;
• 32 sites consequently rejected (See rejected Stage 1 and Stage 2 rejected sites’ list within Appendix 2, of the Issues and Options consultation document setting out clear reasons for rejection).

Part 2

• Second stage more detailed screening assessment of suitability, availability, and achievability of 15 remaining reasonable alternative sites.

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7.0 SITE ASSESSMENT AND DELIVERABILITY

7.1.1   In allocating land for gypsy and traveller sites, national and local planning authorities are required to consider a number of matters via evidence studies, in order to identify sustainable, realistic and inclusive locations in which to meet identified needs and which reduce tensions between settled and traveller communities and protect the local environment (criteria g, h and k and paragraph 8 PPTS 2015). These considerations are part of site options assessment via the objective criteria in the site identification work and performance against Strategic Objectives in the sustainability appraisal evidence.

7.1.2   The reasonable alternative sites were identified in accordance with the above, via the G&T SIS April 2019 and G&TSA February 2019.

7.1.3   Table 4 lists the 15 reasonable alternative sites identified. The G&T SA February 2019 evidence suggests that the majority of these 15 sites would all be expected to have similar, minor, or negligible impacts, and would in any case, likely be improved via polices in the adopted ALP 2018. The list of sites included in the Issues and Options and the Preferred sites consultation documents are listed in Table 4 below.

Table 4: The sites considered as part of the Issues and Options

(this lists the references and names of the sites considered at the Issues and Options stage)

Table 4: The sites considered as part of the Issues and Options

Site Reference	Address
AL4714	Land at Aldingbourne Farm Shop
ARU022	The Drive, Eastergate Lane
ARU023	Fairfield, Eastergate Lane
ARU030	Ryebank Caravan Park, Yapton Road
ARU031	Fieldview, Junction Common Mead Land and
ARU046	Nyton Stables, Nyton Road
ARU051	Land at Limmer Pond Stables, Church Road
ARU049	Dragonfly, Eastergate Lane
ARU052	The Cottage Piggeries, Church Lane
ARU054	The Old Barns, Arundel Road
ARU_NS_1	The Caravan Site, North site of New Road
ARU040	The Old Stables, Brook Lane and Penfold Lane
ARU044	2 Wyndham Acres, Northfields Lane
ARU045	The Paddocks, Northfields Lane
ARU_HELAA_046b	Land at Little Meadow Yapton (Bilsham Corner)

7.1.4   However, the site identifications study (G&T SIS April 2019) undertook a further discounting of the 15 sites listed in Table 4 which reduced to 8 sites based on suitability issues. In meeting identified need, the study suggested adopting a sequential approach through safeguard existing sites and granting permission for additional suitable sites (particularly existing private sites) in accordance with the criteria in ALP 2018 policies. The remaining provision required could then be met by allocating existing/previously existing sites for intensification on a permanent basis.

7.1.5   Furthermore, this study considered the selection of sites for allocation should be guided by the degree of fit with specific accommodation needs of the different households; viability and timing of delivery (in particular for the first 5 years); and the relationship with the development strategy and settlement hierarchy (e.g. adopted ALP 2018). To help meet these requirements, the option of allocating the implemented/unimplemented consents was identified:-

Pitches

• 1 pitch at the Caravan Site (ARU_NS_1) being implemented;
• 3 pitches at Fieldview (ARU031) implemented licenses.

Plots

• 1 plot to be implemented at Old Barns (ARU054);
• 4 plots implemented at Aldingbourne Farm Shop (AL4714);
• 3 plots to be implemented at Nyton stables (ARU046).

7.1.6   However, since G&T Preferred Options DPD consultation in 2020 the five-year requirements is updated in 2023 following the G&T Delivery Study 2023 as discussed below.

7.1.7   National Planning Policy (NPPF 2023) states that a DPD needs to set out specific deliverable sites to meet identified needs within the first 5 years, developable sites 6-10 and or broad locations for years 11-15.

7.1.8   In 2023 and based on the 5-year requirements set out in the G&T Site Identification Study 2019 (DLP consultants), in the first 5 years a residual of 1 pitch and 5 plots is unmet (1 April 2018- 31 March 2023). Allowing for updated supply (G&T Delivery Study 2023) the revised requirement for the next 5 years taking forward unmet need for deliverable sites (1 April 2023-31 March 2028) is calculated as follows:-

Table 5: Five Year Requirement updated 2023

(this sets out the figures of the requirements against 5 year periods, as updated in 2023)

Table 5: Five Year Requirement updated 2023 - pitches

Pitches	2018-2023	2023-2028	2028-2033	2033-2036
Need 1-5yrs	5	-	-	-
Implemented	4	-	-	-
Shortfall	-1	-	-	-
Need year 6-11	-	1	-	-
Implemented	-	0	-	-
Need plus shortfall	-	2	-	-
Need year 15+	-	-	2	-
Implemented	-	-	0	-
Residual	-	-	2	-
Need year 11-15	-	-	-	1
Implemented	-	-	-	0
Residual	-	-	-	1

Table 5: Five Year Requirement updated 2023 - Plots

Plots	2018-2023	2023-2028	2028-2033	2033-2036
Need 1-5yrs	11	-	-	-
Implemented	6	-	-	-
Shortfall	-5	-	-	-
Need year 6-11	-	2	-	-
Implemented	-	0	-	-
Need plus shortfall	-	7	-	-
Need year 15+	-	-	1	-
Implemented	-	-	0	-
Residual	-	-	1	-
Need year 11-15	-	-	-	0
Implemented	-	-	-	0
Residual	-	-	-0

7.1.9   There is a consequent residual need for 2 deliverable pitches in 2023-28 (this provided by Wyndam Acres and Limmer Pond Stables which can compensate for 1 pitch shortfall in 2028-2033. There is a need for 7 deliverable permanent plots in 2023-2028 (this met by bringing forward the Old Barns, and additional capacity at Aldingbourne Farm shop and the residual provision at Nyton Stables).

7.1.10 The most suitable allocation within the sites for intensification and Broad Location to meet the residual need over 5 years and the remaining need for years 6-10 and 11-15 and beyond are set out in Tables 6 and 7. 

Table 6: Joint GTAA 2019 Gypsy & Traveller potential pitch provision against residual need

(This table, as named, sets out numbers for the potential pitch provision available against the residual need against the respective time period)

Table 6: Joint GTAA 2019 Gypsy & Traveller potential pitch provision against residual need

Site Ref	2018-23	2023-2028	2028-2033	2033-2036	2018-2036
ARU031 Fieldview Junction	3	0	0	0	3
ARU051 Limmer Pond	0	1	1	0	2
ARU_NS_1 The Caravan Site	1	0	0	0	1
ARU044 2 Wyndham Acres	0	2	0	0	2
Need	5	2	2	1	8
New Broad Location Land at Little Meadow, Yapton (	0	0	0	1	1
Total Capacity	4	3	1	1	9
Net	-1	+1	-1	0	-

Table 7: Joint GTAA 2019 Traveller Showpeople potential plot provision against residual need

(As named, this sets out the potential plot provision against the residual need for the mentioned time periods)

Table 7: Joint GTAA 2019 Traveller Showpeople potential plot provision against residual need

Site Ref	2018-23	2023-2028	2028-2033	2033-2036	2018-2036
AL4714 Aldingbourne	4	4	1	0	9
ARU054 The Old Barns	1	1	0	0	2
ARU046 Nyton Stables	1	2	0	0	3
Need	6	7	1	0	14
Total Capacity	6	7	1	0	14
Net	0	0	0	0	-

7.1.11 The Gypsy & Traveller Accommodation Needs assessment 2019 identified a need for 9 permanent Gypsy & Traveller (G&T) pitches and 14 permanent Traveller Showpeople (TSP) plots to be accommodated within Arun over the plan period (from 2018 to 2036).

7.1.12 The council commissioned further evidence studies to address the site objections maintained by consultees from the G&T Preferred Options consultation, looking at capacity, site layout and deliverability, flood risk, access and traffic impact of the identified preferred sites for intensification and one Broad Location. The studies included:-

• G&T Delivery Study (Troy Planning + Design);
• Technical Note: Gypsy, Traveller and Travelling Showmen - Access Review 2023 (WSP consultants);
• Technical Note: Summary of flood predictions at Gypsy & Traveller site allocations 2023 (JBA consultants).

7.1.13 The Studies together, present resolutions and mitigation measures to the constraints/key issues which need to be overcome to deliver the proposed sites for intensification and concluded that sites are deliverable with the exception of two existing sites. These are the Caravan Site (ARU_NS_1) and Dragonfly Site (ARU051) Eastergate.

7.1.14 The Caravan Site has an implemented pitch counting towards need; however, a further proposed pitch is not considered sustainable and although traffic impact is acceptable, there are safety, flood concerns - being impacted by Environment Agencies updated future climate change Annual Exceedance Probability (AEP) scenarios (with respect to surface water flooding only), as well as health and amenity considerations. Therefore, no additional intensification is proposed in the G&T DPD for the Caravan site.

7.1.15 The shortfall of 2 pitches is offset by additional capacity identified at Limmer Pond for an additional pitch and 1 pitch can be accommodated on the Broad Location at Little Meadow Bilsham Corner towards the end of the plan period.

7.1.16 Similarly, additional plot capacity is also identified at Aldingbourne Farm Shop which removes the deficit of 1 plot towards the end of the plan period.

7.2. What is Flood Risk?

7.2.1   “Flood risk’ is a combination of the probability and the potential consequences of flooding. Areas at risk of flooding are those at risk of flooding from any source, now or in the future. Sources include rivers and the sea, direct rainfall on the ground surface, rising groundwater, overwhelmed sewers and drainage systems, reservoirs, canals and lakes and other artificial sources. Flood risk also accounts for the interactions between these different sources……For areas at risk of river and sea flooding, this is principally land within Flood Zones 2 and 3 or where a Strategic Flood Risk Assessment shows it will be at risk of flooding in the future." [1]