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Friends, Families and Travellers and Traveller Law reform Project response to West Oxfordshire Council Core Strategy Preferred Approach Consultation Accommodation for Travelling Communities (para 4.38 and 4.39) FFT and TLRP welcome the fact that attention is being given to this small but important issue. The EiP has been held and the results will soon be available and so there is no reason to delay in making site allocations. The requirement must be delivered through site allocations in a relevant DPD (see para 33) and not rely on a criteria based policy to deliver sites. However the criteria based policy should be used to guide allocations and meet unexpected demand (para 31 1/2006). We are pleased that a criteria based policy is being developed but have some concerns about it which in our view must be addressed so that it can be conformable with national policy. We agree with the approach outlined of safeguarding existing sites, extending existing sites where appropriate and also allocating new sites. The criteria listed for new sites have some problems: 1. The requirement (i) for sites to be in or near existing settlements does not take into account affordability and availability issues for land for sites. Circular 1/2006is clear that rural and semi-rural locations are acceptable in principle and that local authorities should be realistic about alternatives to the car in accessing services ( para 54 1/2006). As such the wording of this criterion as it stands may be unduly restrictive in locating suitable sites. A more suitable alternative wording would be ‘ be a reasonable distance from local services’. 2. The requirement (iii) not to have adverse impact is overly onerous. Any development by its very nature can be held to have impact on environmental assets and the use of this wording does open the door to NIMBY objections. If there is a concern about impact on character and appearance of the surrounding area an alternative more suitable form of wording may be ‘not have an unacceptable impact…’ The core strategy as it stands gives no indication of the timing of delivery of much needed sites. The needs have already been outlined, the EiP held and the results for that will be available soon. As such in view of the significant and pressing need in our view West Oxfordshire Council should consider developing the dedicated DPD in parallel with or in advance of the core strategy as recommended by Circular 1/2006 para 43 The Government is clear that ‘ The current position on site delivery remains unsatisfactory. It is also clear that local authorities need to increase the pace at which sustainable locations are identified that can be used as Gypsy and Travellers sites.’ (Progress report on Gypsy and Traveller Policy, CLG July 2009). Hence the Council should make a start now on identifying sites.
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