Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

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Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

Policy GNLP5014

Representation ID: 24925

Received: 05/03/2023

Respondent: Beighton Parish Council

Number of people: 70

Representation Summary:

Beighton Parish Council held a Public Meeting on 22nd February for Parishioners to put forward their views and concerns about the proposed Gypsy and Travellers site on the A47 at North Burlingham (GNLP5014). The meeting was attended by over 70 parishioners who all expressed very strong and well founded concerns about the proposal. This letter is a representation of those views.

Communication:
The Parish Council, along with most Parishioners, only discovered that there were proposals for a Gypsy / Travellers site when it was announced in the Press; none of the immediate neighbours of the site received any notice of the proposal, nor did the Parish Council. Considering its size, position and the potential ramifications for the local area if it goes ahead, the lack of communication with the Public is very disappointing and of concern in itself. The Government’s planning policy for Traveller sites specifically states that, “…local planning authorities should pay particular attention to early and effective community engagement with both settled and traveller communities”

Need for the Site:
The Consultation documents state that 53 sites need to be found by 2038 in order for the GNLP to be approved.
However, what is the actual need of the Gypsy / Traveller community? Have they been directly consulted with to corroborate this need or state that the proposed overall number of pitches is really necessary? Has the Gypsy / Traveller community been consulted about this particular site and an identified need shown? The Government’s policy on such sites states that there must be an identified need from the Traveller community and that a site cannot just be imposed on an existing population. For several reasons, this could not be an attractive site to the Traveller community as it is so far from any large urban town or city with all the amenities that such places have to offer. Is this more a case of Government pressure forcing stipulated ‘need’ on to communities where, in reality, there is none?
There is real concern that as the Gypsy / Traveller community tends to be mainly transient, no real connections would be made with the local area and as a result they would not be invested in the community in the same way that a permanent resident is.
The proposed site is basically in the middle of nowhere and provides nothing that is within walking distance. To get the bus, train, or go to the shops, schools etc, would all involve driving as none of these is accessible on foot. If each pitch has a minimum of two vehicles, that will mean at least 60 extra vehicles accessing the site day and night. This all adds to the continued pressure put on small, local roads which already suffer from overuse.
The Sustainability Appraisal (Lepus Consulting) SA11: Economy, states that the site “is located approx. 3 km from the market town of Acle, which would be expected to provide a range of employment opportunities for site end users….. . Therefore, a minor positive impact on the local economy would be expected”.
The Parish Council would strongly question that, as there are very few employment opportunities or vacancies in Acle and certainly not enough to provide employment for the number of people who would potentially be living on the site. Also, with the transient nature of the Traveller community, they are not likely to want to take up permanent employment in the area. The vast majority of working people who live in Acle and the surrounding villages work outside the area and have to commute. According to Government Policy, the local authority must “provide a settled base that reduces the need for long-distance travelling”. This would not be possible at this site and would directly contradict that statement.
The Sustainability Appraisal document also acknowledges the fact that the schools are located outside the preferred “target distance”. It also says, “whilst the site is in close proximity to a school bus route, there is somewhat limited access to local services in Lingwood as there is currently no footpath on the local road.” This again would necessitate people living on the site having to travel by car to access any of the local services and amenities.

Impact on Local Area:
The pressure on the amenities available in Acle, in terms of schools (one primary, one secondary), doctors (one surgery), and dentist is already very high and is set to increase yet further by the many new houses that are already being and have been built. This is set to be compounded further by current applications to build at least another 200+ houses. With the 15 proposed pitches (which actually translates to 30 as there is enough room for 2 families on each pitch) and the subsequent numbers of people who could potentially be there, this is yet another pressure on an already very overstretched village infrastructure.
The Government’s policy documents on such sites highlights the need to avoid any undue pressure on local facilities and amenities. Given, that there has been no increase in the capacity of the local amenities, despite significant building in the area, the proposed site would certainly amount to an undue pressure.
For the people living in the immediate neighbouring houses, they would have to put up with not only additional noise from a much larger road but also the noise that would come from a community directly across the road from them. According to the Government’s Planning Policy for Travellers Sites, any site should be proportionate to the surrounding population: “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.” The proposed site is for 15 (30) pitches yet the number of dwellings in the immediate area is 4. The site is also outside the settlement boundary.
The Constraints Analysis of the site, as provided in the Consultation documents, shows Access to Services as Amber (Amber – constraints identified are either not significant enough to prevent development and/or could be mitigated), and Utilities Infrastructure and Market Attractiveness as Green (Green – no identified constraints). Given that water supply, a sewage system and electricity supply would all be vital, to mark them as Green would imply that the infrastructure for all of these are already in place in the site area. We would strongly refute that, as there is no mains sewage system (the houses in the vicinity have septic tanks), and the nearest treatment plants are in Acle and Lingwood. The cost of laying the pipes needed for water supply and sewerage treatment and the costs of electricity supply would be considerable. With the definition of Green being, “no identified constraints”, this is quite clearly not the case.
With Access to Services being highlighted as Amber implies that it must already be recognised that services in the area are already limited and under strain.
An increase in wildlife crime, along with more general crime, were raised as areas of concern, with the Gypsy / Traveller communities often being associated with this, in particular Hare Coursing. With the proposed site being in a rural area, there is an associated vulnerability for communities and, as such, they would want to see specific measures put in place that would properly protect the wildlife, environment and community in general.
The Sustainability Appraisal scores Crime as ‘0’ meaning that “either no impacts are anticipated, or any impacts are anticipated to be negligible”. That would appear to be a very objective statement as the impact of crime in a small community is rarely negligible.

Safety
There is concern for the safety of Gypsy / Traveller families and animals who would be living so close to what will be a 70mph main road. Children and animals could wander into the road and be hit and killed or cause an accident. Fences would presumably need to be put up around the perimeter and need to be either close boarded (which easily blow down in windy conditions) or wire mesh. Both would need to be of a significant height and neither would make for a particularly attractive barrier and would not be in keeping with the rural nature of the area. It would be difficult to see how a hedge, which would be more in keeping, would provide the necessary safety of a proper barrier to the road from children and animals.
What would be put in place to protect the gypsy / traveller community from pollution generated from the road? The Site Appraisal states that the majority of the site is within 200 mts of the A47 and that development at the site “could potentially expose end users to higher levels of transport associated air and noise pollution”

Site Properties:
According to the Consultation documents, the proposed site is Grade 1 agricultural land and covers an area of 1 hectare (sitting within a larger area of 2.48 hectares). Can this be ethically argued that such land should be taken out of food production and used for a Travellers site, when a more suitable Brown Belt site that won’t affect food production could be found and used instead? There is no mention of what the remaining 1.48 hectares would be used for.
The Government’s Planning Policy for Traveller Sites clearly states that Green Belt land should be protected from inappropriate development. It specifically states that, “Traveller sites (temporary or permanent) in the Green Belt are inappropriate development” and, “… are unlikely to clearly outweigh harm to the Green Belt”
The Site Appraisal document, in relation to urbanisation of the Countryside, states, “Site GNLP5014 comprises previously undeveloped land and is located outside the existing settlements of Lingwood and Burlingham Green. Therefore, the proposed development at this site could potentially contribute towards the urbanisation of the countryside…”
Point E7 in the Sustainability Appraisal notes that, “Negative impacts were mainly related to issues associated with the location of development outside of sustainable target distances to services such as schools and healthcare facilities, and the potential for threats or pressures to environmental assets including biodiversity features, watercourses and the loss of ecologically or agriculturally valuable soil associated with development on previously undeveloped land” The site in question will result in a further loss of agricultural land (given that the new road will already mean a loss) and has been noted as being outside target areas for both schools and hospitals.

Having reviewed the consultation documents and listened to the views and concerns of Parishioners, the Parish Council does not support this proposal and does not believe that this would be a suitable or desirable site for the Gypsy / Traveller community. The site is in open countryside, is not close enough to schools or hospitals and the existing infrastructure of Acle is already under considerable strain. We believe that a brownfield site situated closer to a larger, more urban area, with the necessary infrastructure already in place, or an extension of an existing site, would be much more suitable and beneficial to the Traveller community than the site proposed at Burlingham.

Full text:

Beighton Parish Council held a Public Meeting on 22nd February for Parishioners to put forward their views and concerns about the proposed Gypsy and Travellers site on the A47 at North Burlingham (GNLP5014). The meeting was attended by over 70 parishioners who all expressed very strong and well founded concerns about the proposal. This letter is a representation of those views.

Communication:
The Parish Council, along with most Parishioners, only discovered that there were proposals for a Gypsy / Travellers site when it was announced in the Press; none of the immediate neighbours of the site received any notice of the proposal, nor did the Parish Council. Considering its size, position and the potential ramifications for the local area if it goes ahead, the lack of communication with the Public is very disappointing and of concern in itself. The Government’s planning policy for Traveller sites specifically states that, “…local planning authorities should pay particular attention to early and effective community engagement with both settled and traveller communities”

Need for the Site:
The Consultation documents state that 53 sites need to be found by 2038 in order for the GNLP to be approved.
However, what is the actual need of the Gypsy / Traveller community? Have they been directly consulted with to corroborate this need or state that the proposed overall number of pitches is really necessary? Has the Gypsy / Traveller community been consulted about this particular site and an identified need shown? The Government’s policy on such sites states that there must be an identified need from the Traveller community and that a site cannot just be imposed on an existing population. For several reasons, this could not be an attractive site to the Traveller community as it is so far from any large urban town or city with all the amenities that such places have to offer. Is this more a case of Government pressure forcing stipulated ‘need’ on to communities where, in reality, there is none?
There is real concern that as the Gypsy / Traveller community tends to be mainly transient, no real connections would be made with the local area and as a result they would not be invested in the community in the same way that a permanent resident is.
The proposed site is basically in the middle of nowhere and provides nothing that is within walking distance. To get the bus, train, or go to the shops, schools etc, would all involve driving as none of these is accessible on foot. If each pitch has a minimum of two vehicles, that will mean at least 60 extra vehicles accessing the site day and night. This all adds to the continued pressure put on small, local roads which already suffer from overuse.
The Sustainability Appraisal (Lepus Consulting) SA11: Economy, states that the site “is located approx. 3 km from the market town of Acle, which would be expected to provide a range of employment opportunities for site end users….. . Therefore, a minor positive impact on the local economy would be expected”.
The Parish Council would strongly question that, as there are very few employment opportunities or vacancies in Acle and certainly not enough to provide employment for the number of people who would potentially be living on the site. Also, with the transient nature of the Traveller community, they are not likely to want to take up permanent employment in the area. The vast majority of working people who live in Acle and the surrounding villages work outside the area and have to commute. According to Government Policy, the local authority must “provide a settled base that reduces the need for long-distance travelling”. This would not be possible at this site and would directly contradict that statement.
The Sustainability Appraisal document also acknowledges the fact that the schools are located outside the preferred “target distance”. It also says, “whilst the site is in close proximity to a school bus route, there is somewhat limited access to local services in Lingwood as there is currently no footpath on the local road.” This again would necessitate people living on the site having to travel by car to access any of the local services and amenities.

Impact on Local Area:
The pressure on the amenities available in Acle, in terms of schools (one primary, one secondary), doctors (one surgery), and dentist is already very high and is set to increase yet further by the many new houses that are already being and have been built. This is set to be compounded further by current applications to build at least another 200+ houses. With the 15 proposed pitches (which actually translates to 30 as there is enough room for 2 families on each pitch) and the subsequent numbers of people who could potentially be there, this is yet another pressure on an already very overstretched village infrastructure.
The Government’s policy documents on such sites highlights the need to avoid any undue pressure on local facilities and amenities. Given, that there has been no increase in the capacity of the local amenities, despite significant building in the area, the proposed site would certainly amount to an undue pressure.
For the people living in the immediate neighbouring houses, they would have to put up with not only additional noise from a much larger road but also the noise that would come from a community directly across the road from them. According to the Government’s Planning Policy for Travellers Sites, any site should be proportionate to the surrounding population: “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.” The proposed site is for 15 (30) pitches yet the number of dwellings in the immediate area is 4. The site is also outside the settlement boundary.
The Constraints Analysis of the site, as provided in the Consultation documents, shows Access to Services as Amber (Amber – constraints identified are either not significant enough to prevent development and/or could be mitigated), and Utilities Infrastructure and Market Attractiveness as Green (Green – no identified constraints). Given that water supply, a sewage system and electricity supply would all be vital, to mark them as Green would imply that the infrastructure for all of these are already in place in the site area. We would strongly refute that, as there is no mains sewage system (the houses in the vicinity have septic tanks), and the nearest treatment plants are in Acle and Lingwood. The cost of laying the pipes needed for water supply and sewerage treatment and the costs of electricity supply would be considerable. With the definition of Green being, “no identified constraints”, this is quite clearly not the case.
With Access to Services being highlighted as Amber implies that it must already be recognised that services in the area are already limited and under strain.
An increase in wildlife crime, along with more general crime, were raised as areas of concern, with the Gypsy / Traveller communities often being associated with this, in particular Hare Coursing. With the proposed site being in a rural area, there is an associated vulnerability for communities and, as such, they would want to see specific measures put in place that would properly protect the wildlife, environment and community in general.
The Sustainability Appraisal scores Crime as ‘0’ meaning that “either no impacts are anticipated, or any impacts are anticipated to be negligible”. That would appear to be a very objective statement as the impact of crime in a small community is rarely negligible.

Safety
There is concern for the safety of Gypsy / Traveller families and animals who would be living so close to what will be a 70mph main road. Children and animals could wander into the road and be hit and killed or cause an accident. Fences would presumably need to be put up around the perimeter and need to be either close boarded (which easily blow down in windy conditions) or wire mesh. Both would need to be of a significant height and neither would make for a particularly attractive barrier and would not be in keeping with the rural nature of the area. It would be difficult to see how a hedge, which would be more in keeping, would provide the necessary safety of a proper barrier to the road from children and animals.
What would be put in place to protect the gypsy / traveller community from pollution generated from the road? The Site Appraisal states that the majority of the site is within 200 mts of the A47 and that development at the site “could potentially expose end users to higher levels of transport associated air and noise pollution”

Site Properties:
According to the Consultation documents, the proposed site is Grade 1 agricultural land and covers an area of 1 hectare (sitting within a larger area of 2.48 hectares). Can this be ethically argued that such land should be taken out of food production and used for a Travellers site, when a more suitable Brown Belt site that won’t affect food production could be found and used instead? There is no mention of what the remaining 1.48 hectares would be used for.
The Government’s Planning Policy for Traveller Sites clearly states that Green Belt land should be protected from inappropriate development. It specifically states that, “Traveller sites (temporary or permanent) in the Green Belt are inappropriate development” and, “… are unlikely to clearly outweigh harm to the Green Belt”
The Site Appraisal document, in relation to urbanisation of the Countryside, states, “Site GNLP5014 comprises previously undeveloped land and is located outside the existing settlements of Lingwood and Burlingham Green. Therefore, the proposed development at this site could potentially contribute towards the urbanisation of the countryside…”
Point E7 in the Sustainability Appraisal notes that, “Negative impacts were mainly related to issues associated with the location of development outside of sustainable target distances to services such as schools and healthcare facilities, and the potential for threats or pressures to environmental assets including biodiversity features, watercourses and the loss of ecologically or agriculturally valuable soil associated with development on previously undeveloped land” The site in question will result in a further loss of agricultural land (given that the new road will already mean a loss) and has been noted as being outside target areas for both schools and hospitals.

Having reviewed the consultation documents and listened to the views and concerns of Parishioners, the Parish Council does not support this proposal and does not believe that this would be a suitable or desirable site for the Gypsy / Traveller community. The site is in open countryside, is not close enough to schools or hospitals and the existing infrastructure of Acle is already under considerable strain. We believe that a brownfield site situated closer to a larger, more urban area, with the necessary infrastructure already in place, or an extension of an existing site, would be much more suitable and beneficial to the Traveller community than the site proposed at Burlingham.

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