Local Development Plans - Consultation Checklist
INTRODUCTION
This guidance is intended to assist in making responses to consultations on Draft Local Plans
before they are submitted for examination by the Planning Inspectorate.
Check the end date of the consultation period carefully. Planning authorities cannot normally
accept late responses.
Check the whole Local Plan, not just the Gypsy/Traveller policy because other policies can
have an impact on Gypsy/ Traveller provision (see below).
If policies seem sound, write in support- it is as important to support good policy as to oppose
bad policy.
In making comment you will be asked to whether you feel the Local Plan is:
(a) Legally compliant – (it will rarely be appropriate to answer this negatively).
(b) Compliant with the Duty to Co-operate
(c) Sound (where you identify concerns, this should be answered – “no”)
GYPSY/TRAVELLER POLICY
The policy should include:
1 The allocation of sites to meet the need shown in an up-to-date Gypsy and Traveller
Accommodation Assessment (GTAA) or a commitment to allocate sites in a future separate
policy document.
2 Criteria to be used in the selection of sites for allocation and in the determination of
planning applications.
In regard to the allocation of sites:
Where policies state how many sites are to be provided through allocations:

The policy should state that these are minimum figures

Check the figures against the relevant GTAA.

Check that the GTAA is up-to-date and covers the period of the Local Plan.
If time allows, check the GTAA, to see if the assessment of estimated need includes:

Likely underestimates of housed Gypsy/Traveller families

Pitch turnover or ‘churn’ (discredited as a source of supply in some Panel reports)

Whether account has been taken from movement from housing to sites

Movement out of area accounted for, but no allowance for movement into area

Whether site conditions have been taken into account, particularly very poor sites

Calculate whether a 3% compound annual growth rate has been correctly applied or not

Check latest Caravan Count data for significant changes.
Where authorities have produced a joint GTAA which has included an element of
redistribution, check to see if other local authorities have used the redistributive approach or
whether the GTAA figures have been used.
Gaps in provision likely to arise as local
authorities select the lowest figures.
In regard to criteria for determining applications:
Check for discrepancies between the approach to Gypsy/Traveller provision and the approach
to affordable housing provision, for example:

Where locational requirements are more restrictive for Traveller sites.

Where Traveller pitch figures are stated to be maximum.
Check criteria for restrictive wording which may not accord with National policy as set out in
Planning Policy for Traveller Sites (PPTS), in particularly where the criteria:

Any requirement to prove need – Government guidance in Planning Policy for Traveller
sites (PPTS) requires that criteria must be provided for determination of applications even
where there is no need. (Need is relevant in determining the scale of allocations but not in
determining applications).

Limiting the area of search (and thus excluding what might be otherwise acceptable sites).

Requiring sites to be within a specified distance to facilities and services

Excluding areas which are subject to local designations (eg- Special Landscape Areas).
Other issues

Do policies for urban extensions/large-scale housing allocations require provision for
Gypsy/Traveller sites? This should not be the only mechanism of site delivery, but can
contribute and, alternatively could provide contributions towards off-site traveller pitch
provision through Section 106 obligations.

Tenure – what delivery options are there for socially rented sites, or affordable pitches

Check for previous consultation responses on Gypsy/Traveller policy to see what issues
have been raised locally from settled and Gypsy/Traveller people or representative bodies,
in case other issues need addressing too.
OTHER LOCAL PLAN POLICIES
All policies in a Local Plan must be applied to all development proposals. It is sometimes the
case that other Local policies in the Local Plan can make it difficult to secure Traveller
provision. Check for instance that:

Policies protecting the countryside to not preclude Gypsy/Traveller sites being located
outside settlement boundaries.

Policies requiring developments to meet very high standards of energy efficiency do not
apply to caravans.
HEARINGS:
It is usually worthwhile indicating that you wish to attend the Hearing sessions. It shows you
are serious in putting forward your case and you can always decide against attending when
you are contacted by the Programme Officer
Produced by the National Federation of Gypsy Liaison Groups