We note the allocation of land within our ownership, for five gypsy and traveller pitches as part of the BEX3c allocation. We are disappointed that the local planning authority did not positively prepare this allocation by prior engagement with the objector prior to publishing this draft DaSA allocation. There are several issues with this allocation that make it unsound. These are set out below;
1. The land included within the allocation is encompassed within the planning application for NBAR as part of the landscape mitigation scheme as included in planning permission for the road (ref: RR/2015/2260/P) granted in February 2016.
2. The site itself is bounded on three sides by other land owners who may not be willing to provide a route of access via their land for the proposed use, leading us to conclude an access onto NBAR would be required.
There is a significant levels difference between the road and this site which would need to be graded with a suitable treatment to allow access for full size caravans. The construction of such an access would at this point in the road would utilise a significant portion of the site and be a costly endeavour, leading us to doubt the ability of this site to be delivered without subsidy from a wider development which we are not able to offer as our efforts are focused on commercial development and employment creation within the area, which in itself has a requirement for subsidy and has a considerably lower potential for profit than the housing allocations being brought forward in this plan.
3. We consider the approach of allocating the traveller sites to cover the entirety of a single land ownership parcel already dedicated for the delivery of an existing planning permission detrimental to the viability of delivery for this development. In proposing this the local planning authority limits the potential for securing the viable
delivery of these pitches within the plan period. As a result of the above highlighted issues, we are of the view that the proposed allocation was not positively prepared and is unlikely to be effective. While we recognise that this land has potential to contribute towards meeting housing needs and will support the council in bringing forward viable development to contribute towards this on this site, we consider it unlikely that that could be achieved without achieving prices in excess of those
previously achieved in the UK market for these pitches.
We recognise the identified need for these pitches and the planning authorities legal duty to allocate them but would consider it a more appropriate approach to incorporate these pitches as part of more profitable use allocations to allow them to be effectively secured as part of planning conditions for these schemes and ensuring that the needs of the gypsy and traveller communities can be met throughout the plan period.