Brook Cottage
Elberton
Olveston
South Gloucestershire
BS35 4AQ
Tel: 01454 418249
23rd February 2008
Spatial Planning Team.
South Gloucestershire Council
The Council Offices.
Castle Street.
Thornbury.
BS35 1HF
Dear Sir/Madam
AUST PARISH COUNCIL REPRESENTATION ON
SGC’S GYPSY AND TRAVELLER SITES
DEVELOPMENT PLAN DOCUMENT
While we understand the reason behind the production of this document you will not be surprised to learn that Aust Parish Council (APC) disagrees with many of the assumptions made, and also finds difficulty with many of the pairs of options offered. Aust is a Parish with considerable first hand experience of gypsy and traveller issues, and this response is based upon that experience, and upon the views of our settled population.
Some examples of the anti-social behaviour experienced by the Aust settled community is documented in our recent evidence to the Greenacre Public Inquiry (reference APP/P0119/A/07/2043318/NWF and APP/P0119/C/07/2046804).
Paragraph 1.31 claims that “Gypsies and Travellers will not receive any preferential treatment and are subject to the same planning rules and restrictions as the ‘settled’ community”. This has clearly not been the case in Aust, as revealed by a comparison of the enforcement action taken against a caravan at the Boar’s Head Public House and the lack of action taken against the two main gypsy and traveller sites elsewhere in the village – Greenacres and Sandy Lane. Nothing in this DPD suggests that the settled community will accept that a lack of preference favouring gypsy/travellers exists. For example we do not believe that a request to build conventional housing on Greenacres would ever have been considered, yet a traveller site was recommended by officials!
Paragraph 1.6 asserts that the allocation of new sites will foster safer, stronger and more cohesive communities. We are not aware of evidence supporting that view, and it is most certainly not the APC experience. The issue of planning appeals addressed in Para. 1.8 is interesting, particularly the aspect of enforcement, where South Gloucestershire Council (SGC) and its predecessor have long had adequate powers but have seldom, if ever, employed them. The two sites in Aust immediately come to mind.
Paragraph 1.9 implies that there is less community tension with authorised sites. Whilst we do not have first hand experience of an authorised site in Aust, we cannot believe that just because a site becomes authorised that the anti-social behaviour will stop. Evidence from other local villages with authorised sites would support this view, for example the site in Over, near Almondsbury where police have been frequently involved, and have uncovered significant quantities of stolen goods.
The stated aims of the DPD in Paragraph 1.11 shows a lack of understanding of living close to a gypsy/traveller site. Our experience from Aust is that violence is used both in ‘controlling’ on-site residents and for settling perceived grievances with the settled population. Therefore how can the DPD “support and create healthy and inclusive communities in South Gloucestershire”? In addition, it is unclear how this DPD will ‘promote high quality design that leads to attractive, safe and functional environments…”.
Throughout the document there is an assumption that providing authorised sites will stop unauthorised sites. Little if any evidence is given to support this assertion. On the contrary, sites in Bristol and South Gloucestershire have been abused, and in one case, closed. If the sites that are authorised do not suit the gypsy/traveller community they will continue to use unauthorised sites. We believe that they are not overly concerned about the niceties of DPDs, or even planning consents, as their experience is that the local planning authority will do the minimum or less to enforce the law.
Whilst we fully accept and agree that it should be “unlawful for any individual or organisation to treat Gypsies or Irish Travellers less favourably than other groups, or to discriminate against them indirectly”, it is also presumably unlawful to treat the settled community less favourably than Gypsies or Irish (or any other nationality) Travellers. Indeed this principle is accepted in paragraph 1.31. Our experience is that SGC’s officials tend to discriminate in their favour.
Paragraph 1.31 states that the Council wishes to “promote sustainable, inclusive communities”, however is there any evidence that the Gypsy/Traveller community are equally keen on inclusive communities? It seems that the settled community is expected to accept the Gypsy/Travellers’ values and behaviour, but not visa versa. Therefore the Council’s aspirations for an inclusive community is unrealistic and unattainable.
Throughout the document the word ‘sustainable’ is frequently mentioned. Of course it is a difficult concept to define, but a reasonable view is that a development is sustainable where there is the right balance between the long term economy, environmental protection and societal needs. Again the experience from Aust shows that Gypsy and Traveller communities have little regard for the environment, and we would suggest that to use the word ‘sustainable’ in the context of a DPD for gypsies and travellers is inappropriate.
Paragraph 2.13 talks of consultation. The only consultation between APC and SGC has been at APC request and was misleading and unproductive.
Paragraph 3.10 states “… the majority being well-managed and an accepted part of the local community”. We would be interested to know what the criteria are for judging a well-managed site. These sites may be ‘accepted’ only because the local settled community feel powerless to do anything about them, i.e. they are tolerated because there is no perceived alternative.
Throughout the document there are statements such as “research shows” and “research indicates”, but no references are provided to this research, and we suspect that it is being selective and possibly misquoted. The document is written in a repetitive and condescending manner, that wastes paper and fails to provide any real evidence of is assertions. What, for example, is the source of the DSLG evidence quoted in paragraph 3.12? If there is to be a meaningful consultation then we need access to SGC’s evidence base.
“Paragraph 3.16 asserts that “As unauthorised encampments are very short term …..there is rarely an opportunity to pursue legal processes, ….” Two unauthorised sites in Aust have existed for a number of years – hardly “very short term!”
Much is made of the need to achieve satisfactory community relations, however our experience suggests that without major changes in attitude and culture on the part of the traveller community this is unlikely to be achieved by the provision of large sites, with transit sites worse than permanent ones. Disputes seem to be resolved violently, even amongst families, while the mix of cultures, Irish Travellers versus Romanys etc is problematic to say the least. Our experience suggests that these issues are minimised on small single family, effectively permanent, sites.
We believe that the DPD is deficient in that it does not give the option between a large number of small sites and a small number of large sites. Our experience in Aust is that a small site gives rise to fewer problems that a large site.
We have little knowledge of the generation of the GTAA, but strongly suspect that normal economic rules will apply, specifically that an increase in provision will encourage an increase in need. In this context we do not know whether the population of Aust qualify as “hard to reach” but there has been little if any communication prior to this document. We were also particularly concerned at the apparent assumption that the Greenacres Appeal would succeed. Wishful thinking presumably, or was there some pre-ordination?
Paragraph 4.7 states that the GTAA survey “represents an advance in community involvement and should facilitate better community relations”. We believe this statement to be wrong. To APC ‘better community relations’ means relationships between the people who live in the Parish, whether from the settled community or not, whereas we suspect the DPD means between relationship between one group of the community and SGC officials. This is not the same thing. The officials, many who do not live in South Gloucestershire, do not have to face on a daily basis the prevalent anti-social behaviour.
Paragraph 5.86 discusses the health and safety consideration of site selection and states “sites situated near refuse sites, industrial processes or other environmental hazards will obviously (our emphasis) have a detrimental effect on the general health and well being of residents…”. This seems to imply that there should be no residential development near any waste management sites (we presume this is what is meant by a refuse site), or any industrial process, irrespective of any site specific assessment of its impact. Some industrial processes give rise to an insignificant environmental impact. Is this policy within the Core Strategy and does it just apply generally or just to gypsy/traveller sites?
In summary APC finds the DPD issues and options paper unsatisfactory. However, given the importance of the issue to the local community we have responded to the questions asked as detailed below.
ACP RESPONSE TO THE SPECIFIC CONSULTATION QUESTIONS
Question 1
Option 2. We believe that subject to an acceptable study, provision should be made to 2016.
Question 2
Option 3. Transit sites traditionally cause greater problems than do permanent sites. Dispersal offers an element of “burden sharing” which should reduce management problems, and would avoid an unwelcome concentration.
Question 3
We believe the ranking criteria to be realistic.
Question 4
No. The presence of traditional Romany gypsies causes little concern, particularly as they typically display greater concern for their environment. However the type of site illustrated in your brochure is likely appear alien in an AONB, while the nature of the sites within our experience at Aust would be entirely inappropriate. The illustrations also provide an interesting comparison between gypsy/traveller sites and settled housing densities.
Question 5
Yes. Self evident. Nor should they be located in areas having unacceptable noise, air quality or contaminated land.
Question 6
No. It is difficult to visualise what “wider sustainability benefits to the community could be accrued”.
Question 7
Yes. Degradation of such sites must be resisted as they represent an investment for future generations.
Question 8
No. See Question 7. APC has a strong commitment to the maintenance and protection of the Green Belt and Coastal Zone.
Question 9
Yes. Self evident.
Question 10
No, because our experience in Aust is that bigger sites are more likely to give rise to a loss of local amenity for the settled community. The bigger the gypsy/traveller community on a site the less they will be inclined to co-operate with the local settled community, with the result that there will be less social cohesion.
Question 11
We do not fully understand the significance of this question, for example we do not believe that temporary planning permission should be employed as a “backdoor” means of achieving longer term permission.
Question 12
No. We cannot fully anticipate the future, nor can we fully understand how privately held ground can be guaranteed to remain a site over time. However properly approved sites should have a significant element of bilateral security in their use. We do agree that the provision of approval should not be a “backdoor” means to achieve planning permission for conventional development. However, it is interesting to note that land suitable for gypsy and traveller accommodation would not normally be considered for conventional housing for example, i.e. it is treated specially, contrary to a number of assertions in this paper.
Question 13
Yes.
Question 14
Option 6. To ensure reasonable sustainability. With respect to Paragraph 5.70 we fully agree that sites should not dominate the existing built environment. However following the recommendation by SGC planning officials to permit (temporary) development of a >3 hectare site overlooking the 4 hectare village at Aust we believe that expediency will often rule. We therefore have little confidence that this requirement will be observed.
Question 15
We do not think that mixed business and accommodation should exist together. It is our experience that such mixed activity is a source of friction both on and off site and often contributes to site and locale degradation. We agree with Paragraph 5.72.
Question 16
We believe that the document should be explicit in defining those areas it would reject i.e. where a site does not meet the normal environmental requirements for residential use. This would include considerations of air quality, contaminated land, noise, land stability, flood risk, waste management, biodiversity and light pollution, as would be the case for settled development. We note that caravans typically enjoy lower standards of environmental protection than conventional buildings, and believe therefore that more stringent requirements should apply to such sites.
Question 17
Yes.
Question 18
Yes.
Question 19
We do not understand the relevance of the indicators identifying application success rate and the outcome of appeals. We have little confidence that the issue of “need” is properly defined, we have previously expressed the concern that normal economic rules will apply, and that greater provision of sites will generate greater demand.
Question 20
We have no confidence in SGC’s ability to adequately enforce, or in its attitude towards enforcement. As stated previously Aust has two major illegal sites, neither of which have been subject to any enforcement activity in at least the last 10 years, despite various appeals, inquiries etc up to and including Secretary of State all confirming illegality.
Assuming that sites will need to be imposed upon localities it will be essential to reduce local resentment by visible and effective reduction of site sourced anti-social behaviour and crime. Apart from rather pious assumptions this document does not address this vital concern.
This response is clearly negative, but please understand that this does not arise from any racial bias or the like, but entirely from the experience and views of the local settled population. We would have welcomed any relevant approach by SGC officials to those people that might have better informed them, as we would welcome any approach that would reduce the unsocial behaviour that they have to tolerate.
Yours faithfully
M J Hawkins.
Chairman
Aust Parish Council.
.
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