Allocations Submission Document

LAND OPPOSITE 2 GOLDSMITH DRIVE, RAYLEIGH ESSEX (IDENTIFIED AS GT7)

Thank you for your email of 10th January 2013, and for giving us an opportunity to make comments on your latest version of the Allocations Submission Document November 2012. We have carefully reviewed the Allocations Submission Document and our comments are set out below.

In February 2010, the land was suggested as one of the options (given ref: Option GT7) for providing a permanent site for Travelling Showpeople within the Allocations DPD Discussion and Consultation Document Regulation 25. In April 2010, on behalf of our clients, representations were made in support of promoting the land as a permanent site for Travelling Showpeople within the emerging Allocations DPD. In July 2012, in accordance with the Planning and Compulsory Purchase Act 2004, the Council published an updated 'Discussion and Consultation Document Sustainability Appraisal'. This document recommends that the land meets overall sustainability criteria and it is suitable and appropriate to allocate as a permanent site for Gypsy and Traveller Site.

We note that the site (ref: GT7) has now been removed from the latest version of the Allocations Submission Document November 2012. No other site is made available for Travelling Showpeople to meet our client's needs within the emerging Allocations Document. Since 2010, the applicants have been looking at all possible alternative sites including industrial estates to meet their needs elsewhere on other sites, but none site were found. In summary, no site is available to meet the client's needs within the Rochford District.

It should be noted that, in March 2012, the DCLG published 'Planning Policy for Traveller Sites (PPTS)' which sets out the Government's planning policy for Gypsy and Traveller Sites including Travelling Showpeople. The government advice in PPTS states that local planning authorities should make their own assessment of need for the purposes of planning and increase the number of traveller sites in appropriate locations with planning permission. The PPTS also advises that local planning authorities develop fair and effective strategies to meet need through the identification of land for sites. Paragraph 17 of the PPTS states that local planning authorities should have regard to the need that travelling showpeople have for mixed-use yards to allow residential accommodation and space for storage of equipment.

As mentioned above, the client's need for a permanent site for Travelling Showpeople has been demonstrated since 2010 through making representations (April 2010) in response the Allocations DPD Discussion and Consultation Document Regulation 25. A report was submitted (prepared by Cunnane Town Planning LLP, April 2010) providing a detailed justification and outlining the need for sites within Rochford and the applicant's needs for this particular site. However, the Council has failed to recognise the applicant's needs for a permanent site for Travelling Showpeople within the Allocations Submission Document. The Local Planning Authority has a duty to assess the needs of Travelling Showpeople just as for the Settled Community. The Local Planning Authority is failing in their duty in not making any assessment of need not to mention meeting it.

Submitting this representation, we again notify that there is an immediate need for a permanent site for Travelling Showpeople within Rochford District. The Allocations Submission Document may be found "unsound" if the Planning Inspector accepts our submission that the Council was failed to recognise the need for Travelling Showpeople within the Allocations Submission Document. We will represent our client's need to the Planning Inspector at the forthcoming Examination in Public.

I trust that these comments will be given due consideration in your final assessment of the Allocations Submission Document.