Development and Site Allocations (DaSA) Local Plan - Options and Preferred Options

I do not object to the allocation of land at Loose Farm Lane and around Bexhill, but I do not agree with the preferred sites for permanent GT pitches for the following reasons-

1-fails to address existing need (which is clearly underestimated in the Core Strategy). The need is clearly far greater than 6 pitches. There are at least 4 households on existing sites with temporary consents. Policy fails to explain the approach to be taken for those who do not meet the definition of GT in PPTS but who are ethnically Gypsy Travellers and whose preference to live in caravans even if they no longer travel for work needs to be addressed under the Council's Equality Duty and Human Rights obligations.
2- fails to meet the immediate need from the two sites with temporary consent-they will not be accommodated on the single small family site as proposed.
3-fails to provide sufficient choice of site by location and choice. It is unclear what additional social provision will be made for those using the Robertsbridge site. Sites are concentrated in just 2 locations in the south of the district at Battle and Bexhill. No additional provision is made in the rest of the district yet housing is proposed in many rural settlements. The sites looked at may have been spread across the district but the choice made if too limited and does not reflect where GTs are living.
4-Inequitable approach to site provision. Exceptions are made to AONB for many housing schemes in villages in the AONB yet there is no provision for any GT sites for those families living in the AONB at present as part of these housing schemes or on site with temporary consents nearby. This approach breaches the Equality duty. Provision is made for housing but not caravans in the AONB..
5-Uncertainty when the Bexhill sites will be delivered . it will be v dependent on housing schemes being granted and implemented. Unclear what mechanism is in place to ensure the sites will be developed and when. Experience elsewhere suggests house builders will aim to develop sites for GTs last in the hope they will get out of doing so,

Site allocation Policy should be amended to include the two sites with temporary consents at

BL4 Coldharbour Farm estates, Dallington-because there is no good reason to reject this site. it is no more intrusive in the AONB that other housing schemes in the district. The visual harm relied on is v weak. The harm identified by Inspectors is overstated and they have not done the comparison with other sites granted eg Beeches Brook. This part of the AONB is not devoid of residential development. The fact a site can be seen from some v distant and v limited viewpoints does not necessarily man that it is causing harm to the landscape characteristics of the wider surroundings. This site is viewed in association with the adjoining commercial and residential buildings. This site can be delivered . The occupiers have access to buildings on adjoining land for the storage of goods/ equipment used as part of the need to travel for work. There is no suitable alternative site for the existing occupiers.

SP6/7-Brambles Farm Ewhurst because of the length of time this site has been occupied / consent renewed and the Council has still failed to make alternative provision for this site as part of housing schemes nearby in the same AONB. Officers recognise that this site is well screened behind existing farm buildings. Harm to the AONB is exceptionally limited due to other authorised development on this site. The location is good and the Council has permitted additional housing nearby. At p322 the Council agree that the village has a number of services and amenities. If Staplecross is acceptable for more housing (including affordable housing) there is no justification to take issue with this location for a GT site. This is not an unsustainable rural location. It has been established at appeal that the kids on this site walk into Staplecross to catch the bus. This site is deliverable and there is no suitable alternative site for the existing family-who now have need for their adult children. To dismiss this site for want of some more screening is pitiful. At the last appeal we had to stand on tip toe to see over the hedge to glimpse the top of the caravans on the site. The new houses in Staplecross encroach into the AONB requiring the development boundary to be amended. The schemes make no concession to the AONB setting. It is quite shocking that no provision was made for a Traveller site knowing that there is a need locally for this type of accommodation which is every bit as pressing as the need for affordable housing in the Ewhurst Parish. As the village of Staplecross is considered suitable for affordable housing there is no justification to doubt the suitability of Brambles Farm for a Traveller site. The occupants will be no further to services and no less reliant on a car than the occupiers of the new homes in Staplecross. No one would expect any one to live in Staplecross without access to a car as the local amenities, whilst good, area still limited. Given this site is part of a small holding with land and buildings which are used in connection with the wok undertaken by the occupants this is a very suitable site for Travellers who still travel for work.

Neither of these two sites is any more intrusive than the development permitted at Beeches Brook, Telham lane, Battle. Indeed, having represented all these clients I am of the opinion Beeches Brook is visually the most sensitive site, especially in winter. It is clear from the appeal decisions at Beeches Brook that different Inspectors view things differently. What matters is that a comparative assessment is made of the most suitable sites. This is not undertaken at planning appeals. The Council has FAILED to undertake a proper, meaningful assessment of the merits of all these sites relying instead on appeal decisions where Inspectors were not invited to weigh up the benefits of individual sites.
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The occupants of these two sites do not want to / and should not be expected to have to relocate to Battle or Bexhill which are no where near where they have settled and lived for many years. If these sites are not considered acceptable provision should be made in nearby villages for these families-not some distance away in Bexhill or Battle.

For the above reasons policy as drafted fails to address need in an appropriate way and is contrary to PPTS/NPPF

Transit site provision

There is a national shortage of transit sites. Most stopping places have been blocked off or developed.

This approach fails to appreciate the need for more transit provision to ensure families are able to travel for work as required by PPTS and have some where safe to stay. The need for transit provision is driven by national policy not just unauthorised encampments. The absence of UEs should not determine whether there is a need as this ignores the fact many GTs stop with family and friends , or on holiday caravan sites when owners permit or find stopping places the Council is not aware of and are not recorded as UEs. But many struggle to find suitable places as holiday sites will often turn them away when they realise they have a works vehicle and are Travellers.

There is clear unmet need for transit sites across the country and this is the main reason many are no longer able to travel for work.

It is not good enough for Councils to say they will work with others local authorities to allocate land-because none do. That is an excuse to do nothing in the hope some one does something.

Bridies Tan is not suitable to meet all needs. It is not a good example. Transit provision needs to be properly planned and managed. Families are not going to pull onto unmanaged sites not knowing who else is stopping there or whether their caravans/ generators etc will be safe.

In my experience many clients in the SE region travel along the south coast for work in the summer months, There is a clear need to make provision in this area as there is across the south coast.

There is a clear need to make provision to ensure that Travellers can meet the planning definition in PPTS. Failure to make provision to ensure GTs can travel for work as is now required by the Government should be mandatory not optional or else policy fails the Equality Duty by failing to ensure GTs are able to travel for work.