West Midlands Regional Spatial Strategy Phase Three Revision - Interim Policy Statements and Policy Recommendations March 2010
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West Midlands Regional Spatial Strategy Phase Three Revision Interim Policy Statements and Policy Recommendations March 2010
Contents
AA Introduction 4
A Development of the Interim Policy Statements and Policy Recommendations 5
AA Interim Policy Statements 7
Provision of New Accommodation for Gypsies, Travellers and Travelling Showpeople 8
A Sub-Regional Apportionment for Construction Aggregates 29
AA Policy Recommendations 33
Rural Renaissance 34
Rural Services 34
Culture, Sport and Tourism 37
Culture and Sport 37
Tourism and the Visitor Economy 42
Quality of the Environment 50
Integrated Approach to the Management of Environmental Resources 50
Restoring Degraded Areas and Managing and Creating High Quality New Environments 53
Green Infrastructure 55
Protection and Enhancement of Historic Environment 57
Conservation, Enhancement and Restoration of Region’s Landscape 59
Protecting, Managing and Enhancing Region’s Biodiversity and Geodiversity 61
Trees, Woods and Forestry 65
Protection of Agricultural Land 66
Air Quality 67
Promoting Energy Efficiency within Existing Development 68
Renewable Energy – Targets 69
Criteria for Ensuring that Renewable Energy is Appropriately Located 72
Positive Uses of Green Belt 74
Minerals 76
Safeguarding Mineral Resources in the West Midlands 76
Future Brick Clay Provision 80
AA Appendix 83
List of WMRSS Policies 84
Contact Information 86
All maps in this document are available in colour on the West Midlands Regional Assembly website at:
www.wmra.gov.uk/Planning_and_Regional_Spatial_Strategy/
WMRSS_Revision/WMRSS_Revision_Phase_3.aspx
All images (unless otherwise specified) are from the West Midlands Library (www.westmidlandslibrary.co.uk)
2Introduction
Context AA Phase Three looked at rural In the light of these legislative
services, gypsies, travellers and changes, WMRA, GOWM and
Following the publication of Regional travelling showpeople, culture, Advantage West Midlands (AWM)
Planning Guidance for the West sport and tourism, environment and agreed in September 2009 that the
Midlands in June 2004 which minerals. The Phase Three Revisions issues covered in the Phase Three
subsequently became the Regional are the focus of this document. Revision should be progressed
Spatial Strategy (WMRSS) for the through the new Regional Strategy
West Midlands, the West Midlands Interim Policy process rather than through the
WMRSS Phase Three Revision. It was
Regional Assembly (WMRA), in its Statements and Policy
role as Regional Planning Body agreed that the Phase Three issues
Recommendations be taken forward in one of two ways:
(RPB), was tasked by the Secretary
of State to further develop selective
The Local Democracy, Economic 1) Interim Policy Statements
elements of the WMRSS. This
Development and Construction Act which will provide a framework for
revision process has been undertaken
2009 will, amongst other things, bring relevant policies in the preparation
in the following three phases:
together Regional Spatial Strategies of Local Development Frameworks.
and Regional Economic Strategies Two Policy Statements have been
AA Phase One was completed
into a single Regional Strategy developed which cover the provision
in January 2008 and sets
for each of the English regions. of pitches for gypsies, travellers
out a long-term strategy for
the Black Country area. and travelling showpeople and
From 1st April 2010, the Regional the sub-regional apportionment
Strategy in the West Midlands of construction aggregates;
AA Phase Two focused on housing will consist of the West Midlands
development, employment land, town Regional Spatial Strategy (January
centres, transport and waste together 2) Policy Recommendations
2008 version which incorporates which will feed into the preparation
with overarching policies relating WMRSS Phase One) and the existing
to climate change and sustainable of the new Regional Strategy.
Regional Economic Strategy (RES). The majority of issues within the
development. This Phase was subject
to an Examination in Public (EiP) Phase Three Options document
Any WMRSS Phase will be progressed in this manner.
in Spring 2009. The Panel Report Three legacy work will be
was published in September 2009, incorporated in developing
but in March 2010 the Government the new Regional Strategy.
advised WMRA that the Secretary
of State’s Proposed Changes
would not be published before July
2010. Further details can be found
on the Government Office for the
West Midlands (GOWM) website
at: http://www.gos.gov.uk/gowm/
Planning/515750/863204/
3Introduction
The Policy Recommendations GOWM also confirmed that
were approved by the WMRA in the Policy Recommendations
February 2010. The Interim Policy should be progressed as part
Statements were approved by of the new Regional Strategy.
the WMRA in March 2010. The
Interim Policy Statements and GOWM letters elating to the
Policy Recommendations were Interim Policy Statements and
also noted by the Joint Strategy Policy Recommendations can
and Investment Board (JS&IB) in be downloaded from the WMRA
March 2010 as a basis for future website at http://www.wmra.
work by the two responsible regional gov.uk/Planning_and_Regional_
authorities, the West Midlands Spatial_Strategy/WMRSS_Revision/
Leaders Board and AWM. WMRSS_Revision_Phase_3.aspx
This document draws together all If you have any queries relating to
of the Interim Policy Statements the Interim Policy Statements or
and Policy Recommendations. Policy Recommendations please
contact the West Midlands Leaders
Use of the Interim Policy Board - contact details on the
back cover of this document.
Statements and Policy
Recommendations
On 30th March 2010 GOWM
confirmed that they now expect
planning authorities to ensure
Olwen Dutton
that their Development Plan
Chief Executive
Documents are sufficiently
West Midlands Regional Assembly
flexible to enable them to deliver
the requirements set out in the
March 2010
Interim Policy Statements.
4Development of the Interim Policy Statements
and Policy Recommendations
The first stage of the WMRSS Phase In order to test the Interim Under EU Directive 92/43, the
Three Revision process was the Policy Statements and Policy Regional Planning Body is required to
publication of a Project Plan which Recommendations at each stage undertake a Habitats Regulations
set out the issues to be covered in of development, Sustainability Assessment (HRA). The purpose
the Revision. A Draft Project Plan was Appraisals (SA), Habitats Regulations of a HRA is to assess the impacts
issued for consultation in November Assessments (HRA) and Rural of policies against the conservation
2007. Following extensive dialogue Proofing were undertaken. objectives of European habitat sites
with GOWM, the final Project Plan and to ascertain that policies do
was published in May 2009. A Sustainability Appraisal (SA) not adversely affect the integrity
is mandatory for Regional Spatial of any of these sites. The Habitats
Because there were choices as to the Strategies under Section 39(2) Regulations Assessments for the
nature and content of new or revised of the Planning and Compulsory Interim Policy Statements and Policy
policies, an Options document Purchasing Act 2004. The aim of Recommendations were undertaken
was issued for consultation from a SA is to promote a better quality by Treweek Consulting Limited.
June to August 2009 to help of life through the achievement of
identify those choices (and the sustainable development. The SA Rural Proofing is the process by
consequences of adopting them). incorporates the requirements of which strategies, plans and policies
the EU’s Strategic Environmental are evaluated for their impact on
Following the Options consultation Assessment (SEA) Directive. those who live and work in the
a “Preferred Option” would normally SEA is a process for assessing countryside to ensure that rural
have been developed which would and mitigating the negative needs are not overlooked. Rural
then have been submitted to the environmental impacts of specific Proofing also assesses the different
Secretary of State. However, as plans and programmes, and impacts that a strategy or policy
explained in the Introduction, is required for Regional Spatial might have in rural areas compared
following legislative changes Strategies under the Directive as to elsewhere. Rural Proofing of the
arising from the Local Economic transposed into UK law by the Interim Policy Statements and Policy
Development and Construction Environmental Assessment of Plans Recommendations was led by the
Act 2009 (and advice from GOWM and Programmes Regulations 2004. Rural Accord’s Rural Proofing Team.
in April 2009) it was agreed by The Sustainability Appraisals of the
WMRA, GOWM and AWM in Interim Policy Statements and Policy
September 2009 that the issues Recommendations was undertaken
should be taken forward into the by URSUS Consulting Limited.
new Regional Strategy through
Interim Policy Statements and
Policy Recommendations.
5Development of the Interim Policy Statements
and Policy Recommendations
The chart below outlines the key Group on the Draft Interim Policy To accompany the Interim
stages in the development of the Statement for the Provision of Policy Statements and Policy
Interim Policy Statements and New Accommodation for Gypsies, Recommendations, Background
Policy Recommendations. Travellers & Travelling Showpeople Reports have also been produced
between October – November 2009, for each of the topics considered.
In addition to public consultations and also January – February 2010
at the Project Plan and Options Copies of all the supporting material
stages, the development of AA Consultation with West Midlands for the Interim Policy Statements
the Interim Policy Statements Regional Aggregates Working Party and Policy Recommendations can
have also been informed by the (WMRAWP) and Minerals Planning be found on the WMRA website
following technical consultations: Authorities on the Draft Interim at http://www.wmra.gov.uk/
Policy Statement for Sub-Regional Planning_and_Regional_Spatial_
AA Consultation with Local Apportionment of Aggregates Strategy/WMRSS_Revision/
Planning Authorities and Gypsy between December 2009 – January WMRSS_Revision_Phase_3.aspx
and Traveller WMRSS Reference 2010, and also in February 2010
Sustainability Launch Draft Public
November 2007 Project Plan Consultation
Appraisal (SA)
Baseline Study and
Scoping Report Undertaking of
Ongoing Process technical work
Strategic Authorities
May - Jul 2008 advise RPB
SA + HRA of
Options
June to Public
Options Consultation
Consultation
August 2009
SA + HRA of September 2009 Development of Interim
Interim Policy Policy Statements and Technical
- March 2010 Policy Recomendations Consultations
Statements
on Interim
and Policy
Recommendations
February 2010 Interim Policy Policy
- March 2010 Statements and Policy Statements
Recomendations
Approved by Regional
Assembley
March 2010 Submission of Interim
Policy Statements and
Policy Recomendations
to Government office for
the West Midlands
6WMRSS Phase Three Revision
Interim Policy Statements
7Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
1. Purpose of Interim 3. Summary of 3.3 There are sound housing,
humanitarian, social and welfare
Policy Statement accommodation
reasons for increasing the supply
issues for gypsies and of good quality Gypsy and Traveller
1.1 The West Midlands Interim Policy
travellers and benefits sites. The benefits will be felt by
Statement has been developed
by the West Midlands Regional
to be realised through Gypsies and Travellers, by members
Planning Body to inform the Local increased provision of the settled community and by
local authorities. The need for
Development Framework (LDF)
3.1 Gypsies and Travellers experience enforcement action in relation to
process. The overall aim is to
the worst health and education unauthorised sites will be less,
increase existing rates of delivery on
status of any disadvantaged group and will be more straightforward, if
new pitches and plots for Gypsies,
in England. Life expectancy is, for unauthorised sites continue once
Travellers and Travelling Showpeople
example, 12 years less for women adequate provision has been made.
in the West Midlands within national
policy aimed at increasing such and 10 years less for men than
provision (see Appendix 1). among the settled community. In 4. Summary of
2007, 7% of children of Gypsy/ accommodation issues
Romany origin and 8.4% of for travelling showpeople
2. Scope
Traveller children of Irish Heritage
achieved 5 or more A* to C grades
2.1 The Interim Regional Policy 4.1 Travelling Showpeople are an
in GCSE or equivalent exams
Statement addresses the pitch occupational group who make
including English and mathematics
requirements by District for: their living running funfairs and
in England compared to a national
circuses. Traditionally they have
average of 45.4%. Research has
AA Residential pitches for Gypsies travelled between engagements
consistently shown a link between
and Travellers – from 2007 -2017 except in winter months when they
such measures of disadvantage
dealing with undersupply occupied ‘winter quarters’ where
and the shortage of good quality
they lived, and stored, maintained
Gypsy and Traveller sites.
AA Residential pitches for Gypsies and tested equipment. Changing
and Travellers – from 2017 -2027 patterns of trade and lifestyle mean
3.2 Gypsies and Travellers without
giving indicative requirements and that some Showpeople now travel
an authorised pitch for their caravans
to more local engagements from a
are homeless. Shortage of authorised
AA Transit sites of various types fixed base throughout the year or
sites underlies the unauthorised
for Gypsies and Travellers. need to return to base on occasion
development of sites by Gypsies
through the year. Some family
and Travellers without planning
2.2 The needs of Travelling members are retired and again
permission, and unauthorised
Showpeople are addressed on a occupy a base through the year.
encampments on roadsides, car
County-wide basis or by group of parks or other pieces of land. Such
authorities due to the low level of 4.2 Sites for Travelling Showpeople
unauthorised sites provide uncertain
numbers involved and the wider are sometimes referred to as ‘yards’
and often very poor living conditions
areas of search for this residential which may be subdivided into
for Gypsies and Travellers, disruption
and commercial land use. ‘plots’ each occupied by a single
and anxiety for settled neighbours,
family with one or more trailers. A
and costs to local authorities in
2.3 The Interim Policy Statement ‘plot’ is the unit of land occupied
management and enforcement. They
also sets out some supporting policy by a single nuclear family, and is
exacerbate community tensions
to facilitate LDF production and broadly equivalent to a ‘pitch’ for
and make community cohesion and
further textual advice and guidance. Gypsies and Travellers. Plots and
social inclusion harder to achieve.
yards for Travelling Showpeople
normally accommodate both living
vehicles and trade equipment
8Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
which has to be maintained, tested Table 1 : Current Provision of Gypsy and Traveller Pitches and Travelling A
and stored while not in use. The Showpeople Plots
needs of Travelling Showpeople
are different from those of Gypsies Gypsy and Travelling
and Travellers but again a shortage Local authority Traveller Showpeople
of appropriate sites is leading to Pitches Plots
accommodation problems for Staffordshire & Stoke 282 13
families and sometimes to problems Cannock Chase 41 3
in carrying out business activities
East Staffordshire 17 -
sufficient to threaten livelihoods.
Lichfield 2 -
Newcastle-under-Lyme 17 2
5. Current levels South Staffordshire 83 5
of provision in the Stafford 71 -
West Midlands Staffordshire Moorlands 1 2
Stoke-on-Trent 50 1
5.1 In 2007, there were 1,094 Tamworth - -
authorised pitches for Gypsies Warwickshire 159 12
and Travellers across the region, North Warwickshire 21 -
mostly for residential rather than Nuneaton & Bedworth 36 2
transit use. There were 209 plots Rugby 66 -
for Travelling Showpeople. Table Stratford-on-Avon 36 5
1 shows current provision at local Warwick - 5
authority level and demonstrates the
Worcestershire 240 56
current uneven spread of provision
Bromsgrove 18 8
for both Gypsy and Traveller pitches
Malvern Hills 20 17
and Travelling Showpeople plots.
Redditch - 31
Worcester 20 -
5.2 National issues of shortage of
site accommodation for Gypsies, Wychavon 123 -
Travellers and Travelling Showpeople Wyre Forest 59 -
are applicable in the West Midlands. Birmingham, Black Country,
The sub-regional Gypsy and Traveller Coventry & Solihull 169 108
Accommodation Assessments Birmingham 10 25 (1 yard)
(GTAA’s - with a few slight corrections Coventry 20 -
where further evidence has been Dudley 27 10
provided subsequently) estimated Sandwell 15 13
requirements between 2007 and Solihull 37 -
2017 for 938 additional residential Walsall 20 55
and 219 additional transit pitches Wolverhampton 40 5
for Gypsies and Travellers. They Herefordshire, Shropshire,
estimated requirements for an Telford & Wrekin 244 20
additional 118 plots for Travelling Herefordshire 81 -
Showpeople between 2007 and Shropshire 124 12
2012. These figures are further Telford & Wrekin 39 8
explained in the accompanying text REGIONAL TOTAL 1,094 209
to the Interim Policy Statement.
There is a need for a significant and
urgent increase in the provision of
sites for Gypsies and Travellers,
and for Travelling Showpeople.
9Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
5.3 Against this background, the aims environmental landscape and habitat 6.4 The regional Interim Planning
of the Interim Policy Statement are: assets, are properly applied. Statement was led by WMRA and
involved close liaison with local
(i) To increase significantly the authority colleagues and a wide range
6. Development of an
number of Gypsy and Traveller of stakeholders, including direct
pitches across the West Midlands,
Interim Policy Statement contact with the various Travelling
in order to address existing communities across the Region and
6.1 The regional Interim Policy
under-provision as expressed the (Travelling) ‘Showmen’s Guild
Statement has developed from Phase
in the sub-regional Gypsy of Great Britain’. The key stages
3 of the Regional Spatial Strategy
and Traveller Accommodation and activities can be summarised:
Revision. The provision of sites for
Assessments (GTAAs).
Gypsies, Travellers and Travelling
1. Assembling an evidence base.
Showpeople was one of five planning
(ii) To ensure there are sufficient 2. Development of ‘Options’ for
policy areas which formed the
plots in the Region to meet new regional planning policy.
WMRSS Revision Phase 3 which
the accommodation needs 3. Consultation on ‘Options’ for
commenced in January 2008.
of Travelling Showpeople. new regional planning policy.
4. Assessment of responses
6.2 The West Midlands Regional
(iii) To ensure that all revised submitted to the WMRSS Phase
Assembly (WMRA) and Government
Gypsy, Traveller and Travelling 3 Revision consultation.
Office for the West Midlands (GOWM)
Showpeople policies in the West 5. Development of a regional Interim
decided that a ‘Preferred Option’
Midlands Regional Spatial Strategy Policy Statement, including further
developed within the former statutory
(WMRSS), Local Development consultation with local authorities
framework for Regional Planning for
Frameworks (LDFs) and other and other stakeholders.
the provision of sites for Gypsies,
regional and sub-regional 6. Endorsement and adoption of the
Travellers and Travelling Showpeople
strategies recognise, protect and regional Interim Policy Statement.
would not be appropriate. However,
ensure a traditional travelling way
to ensure the avoidance of a policy
of life for Gypsies, Travellers and 6.5 Appendix 2 gives further details
vacuum, WMRA and GOWM agreed
Travelling Showpeople, whilst of the activities involved in each
to formulate a Regional Policy
also respecting the interests stage. A Background Paper is also
Statement, which will serve as
of settled communities. available on the Assembly web site,
planning guidance, until the ‘Strategy
which provides further explanation of
for the West Midlands’ is confirmed.
(iv) To ensure that all Development how the ‘Options’ were developed:
Plan Documents (DPDs)
6.3 Until the Strategy for the West
include fair, realistic and http://www.wmra.gov.uk/
Midlands has been completed,
inclusive policies in relation to documents/Gypsies%20
the status of this Regional A
the accommodation needs of Travellers%20Trav%20
Interim Policy Statement for
Gypsies, Travellers and Travelling Showpeople%20Background%20
Provision of New Accommodation
Showpeople and that the
for Gypsies, Travellers and
potential for Gypsies, Travellers
Travelling Showpeople has been
and Travelling Showpeople
confirmed by GOWM as having
to be evicted and thereby
‘similar weight to a submitted
become homeless is avoided.
draft WMRSS’. Discussions with
the Planning Inspectorate indicate
(v) To ensure issues of sustainability,
that the Statement will ‘carry
both socially and economically
weight in both Development Plan
for Gypsy and Traveller
Document (DPD) examinations
communities and for the
and Planning Inquiries’.
protection of significant
10Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
7. Key messages and Traveller WMRSS Reference AA In the context of such polarisation
Group) this figure was subsequently in the consultation opinions and
from the WMRSS
slightly adjusted in the light of lack of consensus on which Option
Phase Three Revision further evidence provided by local was preferred, WMRA decided
consultation period authorities to 938 additional pitches. to develop a further Option which
combined elements of each of the
7.1 In developing the Interim AA There were fundamental and Options consulted upon, maintaining
Policy Statement, WMRA had irreconcilable differences in the commitment to delivering the
particular regard to the responses preferences between different full 939 (now 938) pitches by 2017,
submitted to the public consultation categories of consultee over and being as sensitive as possible
on Options, along with other whether a redistributive Option is to the effects and sustainability
comments, contributed from a preferred. Three-quarters of Gypsy issues attendant upon developing
range of sources, throughout the and Traveller individual consultees a further distributive Option.
lifetime of the Phase 3 process. preferred the non-redistributive
Option 1 (so that family links could 7.3 Key messages from the
7.2 Key messages from the be retained) while the majority of Options Consultation process
Options consultation process in other consultees preferred one of the in regards to additional transit
regards to additional Residential redistributive Options to widen areas pitches for Gypsies and
pitches for Gypsies and of provision and share ‘the burden’. Travellers were as follows:
Travellers were as follows:
AA 7 out of 10 local authorities AA Opinions differed on whether the
AA Opinions differed on whether the total transit pitch requirements (244)
preferred a redistributive Option,
total residential pitch requirements but this was split between Option would meet the accommodation
(939 at the time of the Options 2 (partly influenced by planning needs of Gypsies and Travellers. 39%
Consultation - summer 2009) opportunities and constraints), thought the figure was about right,
for Gypsies and Travellers were Option 3 (redistribution to provide 28% thought it was too low, 17%
appropriate. 26% agreed with the a minimum of 14 additional pitches that it was too high, and 17% made
figure, 31% thought it was too in every local authority area), and some other comment. Gypsy and
low, 30% that it was too high, and a view that none of the Options Traveller individuals were most likely
13% made some other comment. was sufficiently redistributive. to think the figures too low. Many
Gypsy and Traveller individuals were of those who thought residential
most likely to think the figures too pitch requirements too high also
AA There was no consensus
low on the basis of their own and thought transit requirements were
between local authorities across
their children’s experiences. District too high. Shropshire, Herefordshire
the Region or within sub-regions
and Parish Councils from across and Birmingham authorities later
on the preferred Option.
the Region, but particularly from adduced evidence that figures
Staffordshire, were most likely to think for transit pitch requirements
AA The Options preferred by local
the figures too high arguing that they had been interpreted too high
authorities were incompatible with
may be based on aspirations rather because of misunderstandings of
achieving the regional total of 939
than need for site accommodation. the GTAA findings. Amendments
(now 938) additional residential
pitches to be provided. Most local to redress these gave an
AA In the context of such very diverse adjusted total transit pitch
authority consultees preferred the
responses, WMRA decided to requirement of 219 pitches.
Option which gave their authority
retain the 939 additional residential
the lowest additional requirement.
pitches as the planning total for AA A single geographical distribution
Combining preferred Options would
the Region since it was based of transit provision was consulted
have had the effect of lowering
on the local authorities’ Gypsy on, based on the findings of the
the regional total by up to 20%
and Traveller Accommodation sub-regional Gypsy and Traveller
which was unacceptable as it
Assessments. Following the Accommodation Assessments.
would not meet evidenced need.
November 2009 consultation (with 35% of consultees thought that
local authorities and the Gypsy this distribution would meet the
11Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
accommodation needs of Gypsies with the wishes of the Travelling relieve pressure on some authorities
and Travellers; 52% thought that Showpeople community and and make equitable redistributions
it would not and 14% were not metropolitan authorities. 21% of pitch requirements in the most
sure. Reasons for thinking the favoured Option 2 as widening pressured Warwickshire sub-region.
distribution would not meet needs potential choice, and 25% did
included the need for a more even not indicate a preferred Option 9. Interim Regional Policy
spread across the region, fear but made a comment.
of over-provision in some areas
and need for greater provision in AA The Options for Travelling
Policy 1 - Residential
metropolitan and urban areas. Showpeople were expressed on a Pitches for Gypsies and
County basis rather than at District Travellers 2007 – 2017
AA In view of the range and level. 60% of consultees agreed with
balance of opinion, the regional this approach; 19% disagreed and 9.1 In view of the work undertaken
Interim Policy Statement retains 21% expressed no preference. by the West Midlands Regional
the geographical distribution Planning Body, as part of WMRSS
of transit pitches as that AA WMRA consider that the Phase 3 Revision process, the
which was consulted upon. consultation response justifies Options Consultation and further
This distribution was based the regional figure of 118 consultation on a Draft Interim
upon the Gypsy and Traveller additional plots for Travelling Regional Policy Statement, the
Accommodation Assessments Showpeople, and that these Interim Regional Policy recommends
undertaken by local authorities should be distributed on a County the delivery of the following level
and represents the best and basis according to Option 1 – of new accommodation:
most robust evidence available. need where it arises as evidenced
by the Gypsy and Traveller
7.4 Key messages from the Options Accommodation Assessments. Policy 1: Pitch Requirements
Consultation process in regards for Gypsies and
to additional plots for Travelling Travellers, 2007 – 2017
8. Further consultation
Showpeople were as follows:
660 additional Residential pitches
8.1 Further consultation was required between 2007-2012
AA There was more agreement undertaken in November 2009 with
amongst those responding to local authorities, other stakeholders
the consultation that the number 278 additional Residential pitches
and the Gypsy and Traveller required between 2012-2017
of plots allocated for Travelling Reference Group on a draft of the
Showpeople (118) during the five Interim Policy Statement. A note
year period 2007-2012 will meet 224 additional Transit pitches
summarising representations and between 2007-2017
these accommodation needs. the WMRA response is available
65% of consultees agreed that it at: http://www.wmra.gov.uk/
would, 18% said that it would not Planning_and_Regional_Spatial_
and 17% were unsure but made Strategy/WMRSS_Revision/
a comment. Many of those not WMRSS_Revision_Phase_3.aspx.
agreeing with the figures questioned
the validity of the Gypsy and Traveller 8.2 All representations were carefully
Accommodation Assessments as a considered and taken into account
basis for predicting need, but failed where possible. In particular,
to provide alternative evidence. evidenced amendments to GTAAs’
findings on current pitch provision
AA The majority of consultees (54%) figures and requirements were
favoured Option 1 as being in line incorporated. Efforts were made to
12Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
9.2 At a District level the proposed allocation of additional 9.3 Appendix 3 sets out for
residential pitches for Gypsies and Travellers is: each local authority its pitch
requirement on the basis of need
Policy 1: Local Authority Allocation of Additional Residential where it arises (Consultation
Pitches for Gypsies and Travellers 2007 – 2017 Option 1) and its proposed
requirement for provision in this
Local Authority Allocation 2007-2017 Interim Policy Statement. The
Staffordshire & Stoke: final column explains derivation
Cannock Chase 35 pitches of the proposed figure.
East Staffordshire 15 pitches
Lichfield 14 pitches
Newcastle-under-Lyme 20 pitches
Justification
South Staffordshire 42 pitches
Stafford 37 pitches 9.4 The principles underlying
Staffordshire Moorlands 2 pitches the proposed allocations are:
Stoke-on-Trent 40 pitches
Tamworth 10 pitches AA The regional total of 938 additional
Warwickshire: pitches 2007-2017, based on the
North Warwickshire 16 pitches GTAAs amended in the light of
Nuneaton & Bedworth 29 pitches subsequent evidence from local
Rugby 42 pitches authorities, is to be achieved.
Stratford-on-Avon 42 pitches
Warwick 23 pitches AA There is a need to take a strategic
Worcestershire: view across local authorities in
Bromsgrove 14 pitches accordance with Circular 1/2006, and
Malvern Hills 33 pitches not simply to develop strategy just on
Redditch 14 pitches the views of the individual authorities
Worcester 22 pitches themselves taken in isolation.
Wychavon 42 pitches
Wyre Forest 42 pitches AA ‘Need where it arises’ (Option
Birmingham, Black Country, 1 in the public consultation) as
Coventry & Solihull estimated by the region’s GTAAs was
Birmingham 19 pitches
the starting point. This is in accord
Coventry 15 pitches
with Gypsy and Traveller community
Dudley 23 pitches
wishes and those of some authorities,
Sandwell 5 pitches
as expressed in the consultation.
Solihull 28 pitches
Walsall 39 pitches
AA A limited redistribution of pitches
Wolverhampton 36 pitches
Herefordshire, Shropshire, was undertaken to reduce the
Telford & Wrekin number of additional pitches to
Herefordshire 109 pitches be provided in some Districts
Shropshire 93 pitches where Option 1 requirements
Telford & Wrekin 37 pitches were particularly high. The primary
REGIONAL TOTAL 938 pitches objective was where possible, to
increase deliverability by reducing the
task for Districts which had already
made significant provision. An ideal
maximum additional requirement
was set at 42 pitches, three times
the figure 14 which was used as
a minimum pitch requirement (for
a local authority area though
13Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
not necessarily all on one site) in AA South Staffordshire: South Coventry, North Warwickshire and
consultation Option 3 as a minimum Staffordshire has 8 pitches in excess Tamworth. Diversions were primarily
sustainable Gypsy and Traveller of the 42 threshold. These have determined by proximity and/or
community to recognise family links been shared between Lichfield, accessibility along the A5 route
and avoid isolation. Appendix 4 Sandwell and Telford & Wrekin which formed the underlying rational
provides further information on the as the geographically closest for the Local Authorities’ GTAA in
derivation of the 14 pitch minimum areas with either low need where this area. Diversions in excess of 3
and 42 pitch maximum premises. it arises requirements or high pitches to Warwick, Coventry and
capacity evidenced by the extent North Warwickshire were made on
AA In order to maintain the regional of unconstrained land. Individually, the grounds of current provision
total of 938 pitches, redistribution the increased allocations were small and ‘needs where they arise’
obviously requires additional pitches and never exceeded 3 pitches. requirements which are low relative
to be provided in some other Pitch allocations in Cannock Chase, to other authorities in this sub-
Districts. Thus a decrease in any Stafford, Wolverhampton and Walsall region. The allocation to Nuneaton
local authority area’s allocation had were not increased despite their & Bedworth was not increased
to be balanced by an increase in proximity to South Staffordshire because it has the highest current
provision in other local authorities because of their relatively high provision and requirements among
nearby. This was done on a case current provision and need where it potential ‘importers’ of pitches.
by case basis, aiming to ‘divert’ arises requirements. In addition, the
pitches over as short a distance Habitats Regulations Assessment of Policy 2 - Residential
as possible while at the same time the draft Policy Statement highlighted
Pitches for Gypsies and
increasing choice for Gypsies and the sensitivity of Cannock Chase
Travellers by raising provision in as a significant European site. Travellers beyond 2017
some Districts with low requirements
under consultation Option 1 (need AA Wychavon and Wyre Forest: Policy 2: Pitch Requirements
where identified in the GTAA) together these authorities had beyond 2017
requirements 26 pitches in
9.5 Given West Midlands geography excess of the 42 pitch maximum. A co-ordinated review of
and the current pattern of provision Requirements were diverted from sub-regional GTAAs should
for Gypsies and Travellers, these Wychavon to adjoining Bromsgrove be undertaken no later than
principles played out differently and Redditch, both of which have 2015 or sooner if refreshed
in different sub-regions, and very low current provision and evidence is agreed by the
the distribution of pitches in the need where it arises requirements. Responsible Regional
Interim Policy Statement reflects In both instances the allocation Authorities to be required
necessary pragmatic decisions to achieves the 14 pitch threshold from the local authorities to
balance often conflicting factors. set for a sustainable community. inform the Strategy for the
Local authorities with a need where Two pitches were diverted from West Midlands (Regional
it arises requirement of over 42 Wyre Forest to Dudley primarily Strategy). In the meantime
pitches form four sub-regions: on the grounds of geographical Local Planning Authorities are
proximity, easing the sub regional expected to use the indicative
AA Shropshire and Herefordshire: pressure with only marginal impact figures in Table 1 below to
both unitary authorities have relatively on adjoining authority areas. provide a basis for planning
high current provision and need for pitch provision beyond
where it arises requirements. There AA Rugby and Stratford on Avon: 2017 if fresh GTAA evidence
was no redistribution because together these authorities had has yet to be established.
of the large spatial size of these requirements 34 in excess of the 42
authorities and the extent of pitch threshold. Pitches were diverted
unconstrained land available. to Redditch, Solihull, Warwick,
14Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
Table 2 : Indicative Requirements for Residential 9.6 In the absence of new GTAA
Pitches for Gypsies and Travellers Beyond 2017. evidence and subject to further
higher level strategic policy which
Indicative requirements may subsequently be approved
Local Authority 2017-2022 2022-2027 or come into force, local planning
Staffordshire & Stoke 77 pitches 89 pitches authorities are expected to use the
Cannock Chase 13 pitches 15 pitches indicative figures in Table 2 post
East Staffordshire 5 pitches 6 pitches 2017, so that provision will be made
Lichfield 5 pitches 6 pitches across the region. This is based upon
Newcastle-under-Lyme 7 pitches 8 pitches an anticipated household growth
South Staffordshire 15 pitches 17 pitches which is an annual 3% compound
Stafford 13 pitches 15 pitches increase in the level of residential
Staffordshire Moorlands 1 pitches 1 pitches pitch provision for Gypsies and
Stoke-on-Trent 14 pitches 17 pitches Travellers, assuming the back log of
Tamworth 4 pitches 4 pitches provision has been made by 2017.
Warwickshire 54 pitches 63 pitches
North Warwickshire 6 pitches 7 pitches 9.7 Indicative additional pitch
Nuneaton & Bedworth 10 pitches 12 pitches allocations 2017-2022 and 2022-
Rugby 15 pitches 17 pitches 2027 at District Level, assuming
Stratford-on-Avon 15 pitches 17 pitches that each District will take a similar
Warwick 8 pitches 10 pitches proportion of the regional total as in
Worcestershire 60 pitches 69 pitches 2007-2017, are outlined in Table 2.
Bromsgrove 5 pitches 6 pitches
Malvern Hills 12 pitches 14 pitches Policy 3 - Transit Pitch
Redditch 5 pitches 6 pitches Provision for Gypsies
Worcester 8 pitches 9 pitches and Travellers
Wychavon 15 pitches 17 pitches
Wyre Forest 15 pitches 17 pitches 9.8 For the purposes of this regional
Birmingham, Black Country, Interim Policy Statement, transit
Coventry & Solihull 59 pitches 68 pitches pitches are identified as any type
Birmingham 7 pitches 8 pitches of accommodation which meets
Coventry 5 pitches 6 pitches the needs of Gypsies and Travellers
Dudley 8 pitches 9 pitches on a temporary basis, for example
Sandwell 2 pitches 2 pitches a formal transit site, an informal
Solihull 10 pitches 12 pitches stopping-place or designated location
Walsall 14 pitches 16 pitches to address seasonal demands or
instances of emergency. A wide
Wolverhampton 13 pitches 15 pitches
range of transit provision is required
Herefordshire, Shropshire,
in the West Midlands, to facilitate
Telford & Wrekin 85 pitches 99 pitches
movement both around and through
Herefordshire 39 pitches 45 pitches
the Region reflecting the culture and
Shropshire 33 pitches 39 pitches
lifestyle of Gypsies and Travellers.
Telford & Wrekin 13 pitches 15 pitches
REGIONAL TOTAL 335 pitches 388 pitches
15Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
9.9 The proposed District allocation for additional transit pitches for Gypsies Justification
and Travellers is:
9.10 Following the public
Policy 3: Local Authority Allocation of Additional Transit Pitches for consultation, the proposed provision
Gypsies and Travellers 2007 – 2017. in this regional Interim Policy
Local Authority Allocation 2007 - 2017 Statement for additional transit
Staffordshire & Stoke 44 pitches pitches for Gypsies and Travellers,
Cannock Chase 5 pitches 2007-2017 was directly based on
East Staffordshire 5 pitches the findings of the sub-regional
Lichfield 5 pitches GTAAs, amended for evidence
Newcastle-under-Lyme 5 pitches provided by local authorities through
South Staffordshire 5 pitches consultation. These determined both
Stafford 2 pitches the regional pitch total, the allocation
Staffordshire Moorlands 2 pitches
between County groups and the
Stoke-on-Trent 10 pitches
indicative allocations to Districts.
Tamworth 5 pitches
Warwickshire 40 pitches
North Warwickshire 5 pitches Further Advice
Nuneaton & Bedworth 5 pitches and Guidance
Rugby 5 pitches
Stratford-on-Avon 10 pitches 9.11 To facilitate movement around
Warwick 15 pitches and through the West Midlands,
Worcestershire 68 pitches all authorities are encouraged
Bromsgrove 0 pitches to contribute to the creation of
Malvern Hills 10 pitches a ‘Transitory Network’. Since
Redditch 18 pitches unauthorised encampments can
Worcester 20 pitches occur anywhere and the resulting
Wychavon 20 pitches tensions can best be resolved
Wyre Forest 0 pitches
through a collaborative response,
Birmingham, Coventry
this includes those authorities where
& Solihull 20 pitches
the GTAA has identified nil need.
Birmingham 10 pitches
Coventry 5 pitches
Solihull 5 pitches 9.12 Each District will be expected
Black Country 12 pitches to identify locations to deliver
Dudley 3 pitches the number of additional Transit
Sandwell 3 pitches pitches identified. However, whilst
Walsall 3 pitches indicative pitch numbers are
Wolverhampton 3 pitches allocated on a District basis, it is
Herefordshire, Shropshire, hoped that joint working between
Telford & Wrekin 40 pitches local authorities will enable the
Herefordshire 5 pitches identification of suitable sites over a
Shropshire 20 pitches wider geographical area and thereby
Telford & Wrekin 10 pitches contribute to speedier delivery.
REGIONAL TOTAL: 219 pitches
16Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
Policy 4 - Identification of Residential and Transit Sites for
Gypsies and Travellers and the LDF Process
Policy 4 : Identification of Sites / LDF Process:
A
a) Local Development Frameworks – each Local Planning Authority (LPA) should identify the location
of specific sites within their Development Plan Documents (DPD's), to ensure the requirements set out
in the regional Interim Policy Statement (see ODPM Circular 01/2006) are met. These locations must
be attractive to Gypsies and Travellers and take into account factors such as: impacts on significant
environmental assets, access to the highways network and key services, any local evidence in relation
to unauthorised encampments and historical patterns of travel and annual events. Where joint LDFs are
prepared, the distribution of pitch numbers between authorities can be adjusted, where appropriate.
b) Criteria-based Policies – criteria-based policies can accompany site allocations in DPDs but these should be
supplementary only, with primary significance given to meeting the pitch numbers in the above Policies. A criteria
based supplementary policy must be fair, reasonable, realistic and should not place undue constraints on the
development of Gypsy and Traveller sites.
c) Identification of a Range of Sites – each LPA is encouraged to identify a range of sites within their DPDs,
which will meet the variety of accommodation needs, required by Gypsies and Travellers. Specifically:
i. the allocation of small sites is particularly recommended to facilitate the delivery of private family sites, together with
larger allocations to deliver publicly owned and run sites.
ii. the allocation of land to meet the specific accommodation needs of New Travellers should also be made within
DPDs where locationally required.
iii. both stopping places and more formal transit sites, which offer a range of basic services will be required.
Where formal transit sites are required (as identified in the GTAAs) LPAs are encouraged to prioritise the delivery
of these in order to directly address travelling patterns or repeated incidence of roadside encampments.
d) Consultation with Travelling communities -LPAs are expected to consult with the Travelling communities within
their respective areas, as part of their LDF process, to determine the most appropriate type of sites which will best
meet their needs.
e) Rate of Delivery – LPAs should endeavour to actively promote policies and practices which encourage
applications for new accommodation and prioritise addressing the existing backlog of need. LPAs may choose
to take individual action or work in partnership with local Registered Providers (RPs) or Private providers but it is
important that positive progress is made at regular stages and will be subject to a regular monitoring regime.
17Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
Policy 5 - Plots for Travelling Showpeople
9.13 At a County level the proposed allocation of additional Plots for Travelling Showpeople is:
Policy 5: Allocation of Additional Plots by County and Local Authority Grouping for A
Travelling Showpeople 2007 - 2012
County Allocation 2007 – 12
Shropshire, Herefordshire and Telford & Wrekin 9 Plots
Staffordshire and Stoke-on-Trent 23 Plots
Warwickshire 1 Plot
Worcestershire 22 Plots
Birmingham, Black Country, Coventry & Solihull* 63 Plots
REGIONAL TOTAL: 118 Plots
* As at Jan 2010, 30 of these plots were required for the relocation and
expansion of an existing funfair operator in Birmingham. As the operator’s area
of search extends south beyond the conurbation, provision could be made
elsewhere e.g. within Warwickshire, if a suitable site were to be required and
identified. Please note Policy 6 (b) below.
Justification sub-regional GTAAs. These well as more traditional concerns
determined both the regional pitch of housing needs. Consequently,
9.14 The regional Interim Policy total and the allocation between when allocating land for new plots/
Statement considered additional plot Counties and groups of authorities. yards, both accommodation needs
requirements at County level rather and commercial requirements
than at District level because of AA In its response to the WMRSS should be taken into account. In
the problems of allocating relatively Phase 3 Options consultation, circumstances where a part yard
small plot numbers between Districts the West Midlands Branch of or whole yard (a collection of
for a group who often have a wide the Showmen’s Guild supported plots) relocation is required, LPAs
area of search and must satisfy Option 1, to distribute additional should acknowledge that this may
commercial as well as residential plots upon the basis of ‘Need result in significant geographical
criteria when developing sites. Where It Arises’ and subsequently movement across the Region.
expressed its agreement with the
AA The time period is 2007-2012 draft Interim Policy Statement.
because of difficulties in predicting
requirements over a longer period in
a changing occupational market. Identification of Sites in
Relation to Commercial
AA Following the Options consultation,
Requirements
the WMRA proposed provision in
the regional Interim Policy Statement
9.15 The accommodation needs of
for additional plots for Travelling
Travelling Showpeople are influenced
Showpeople, 2007-2012, directly
by economic considerations as
based on the findings of the
18Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
Policy 6 - Identification of Residential and Transit Sites for
Gypsies and Travellers and the LDF Process
Policy 6 : Supporting Travelling Showpeople Policy
a) Identification of Sites – LPAs should allocate sufficient sites within their Local Development Frameworks, to
address the level of need identified within the Interim Regional Statement after discussion with this business sector’s
representatives and neighbouring authorities to ensure relevant, sensitive and appropriate allocations of plots.
b) Relocation - By working collaboratively, LPAs should address any individual cases for re-location as they arise,
which will not only meet the needs of the Travelling Showpeople communities concerned but also bring economic
benefits for the individual local authorities affected and the wider regional economy overall. Relocation requirements
should be justified, and clear mechanisms and criteria, including planning constraints, for identifying any necessary
alternative site(s) need to be set out.
c) Relocation - Where such a relocation is required between local authority areas, the resultant change
overrides the plot numbers given in Policy 5. Annual Monitoring will track any such adjustments.
d) To ensure all allocations are appropriate, in terms of size (to meet both residential and commercial needs), design
and location (to facilitate ease of movement by large vehicles from the yard to the Highways network), it is
recommended that the guidelines produced by Showmen’s Guild of Great Britain are referred to in assessing site
capacity and scheme design.
Active Dialogue with the West Midlands Branch of the Showmen’s Guild – to enable the delivery of new
Travelling Showpeople plots / yards it is essential that LPAs develop an effective channel of communication with the
Travelling Showpeople communities within their areas and those of neighbouring areas. The Showmen’s Guild holds
specific knowledge as to the accommodation requirements of Showpeople, which should be beneficial in enabling
delivery and meeting need.
Plot Requirement for Travelling Showpeople beyond 2012
9.16 An annual growth rate of 1.5% compound should be assumed beyond 2012 based on plot requirements at the start
of the period. At regional level this produces an indicative estimate of between 25 and 30 additional residential plots each
five year period beyond 2012.
Policy 7 - Supplementary Policy to Facilitate Delivery
of the Interim Regional Policy Statement
Policy 7 : Supplementary Policy for Gypsy, Travellers and Travelling Showpeople Accommodation
Consultation and Active Dialogue with Travelling communities – to enable the identification of suitable sites, LPAs or
groups of authorities are encouraged to open an active dialogue with the Travelling communities within their areas,
to obtain a better understanding of their patterns of residence, travel and lifestyle. Local authority support for the
establishment of local / sub-regional forums or networks would be helpful in terms of improving the capacity of
individual Gypsy and Travellers and organisations to contribute to the debate around new accommodation and foster a
more inclusive approach to Gypsy, Traveller and Travelling Showpeople issues overall.
19Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
Design and Size of Sites 9.20 A figure of 14 pitches – not all Maintenance of Sites
necessarily in the same place – has
been identified in the Interim Policy
9.17 It is essential that Development 9.23 As additional accommodation
Statement as an approximation to
Control understands the specific will only be delivered as result of
an ideal minimum provision at the
needs and issues involved in new the input of a considerable range
District level to facilitate the creation
site/yard delivery. When considering of resources, it is essential that
of sustainable communities and
site design, Development Control good quality accommodation is
guard against potential isolation.
policy and processes should retained. Effective management
However, it is recognised that
refer to the guidance produced and maintenance arrangements
individual sites may be much
by both Communities Local should be put in place as a
smaller or larger, as determined
Government (CLG) and the Homes condition of new and refurbished
by local requirements, and that an
and Communities Agency (HCA), pitch provision to ensure that sites
allocation of 14 pitches does not
along with any examples of Best do not fall into disrepair, leading to
have to be met in one location.
Practice from within the West abandonment and loss of provision.
Midlands and from other Regions,
and, importantly, any advice Enabling of both Private Role of the Homes and
obtained through consultation with and Public Sites Communities Agency
local Travelling communities.
9.21 LPAs are encouraged to actively 9.24 The Homes and Communities
9.18 Those preparing the design enable the delivery of both public Agency (HCA) administers the
and layout of sites and preparing and private provision for Gypsies Gypsy and Traveller Site Grant
planning applications for Gypsy and Travellers. Whilst it is anticipated Programme which provides public
and Traveller accommodation that half or more of the additional funding for the delivery of new
should consult the Police and Fire pitch requirements will be met by and refurbished accommodation
Services for their advice, expertise Gypsies and Travellers themselves, by local authorities, RSLs and
and experience in ensuring the is it is essential that public provision Registered Providers. The HCA
consistent delivery of high design is facilitated to meet the needs will use the ‘Single Conversation’
standards across the West Midlands. of the more vulnerable sections process to discuss the delivery of
of the Travelling communities, new accommodation for Gypsies,
9.19 LPAs should acknowledge the including the elderly, young people Travellers and Travelling Showpeople
diversity and complexity of the range and those with health issues. with each local authority and thereby
of communities that are encapsulated ensure that this element of housing
within overall Gypsy and Traveller 9.22 It is likely that most new need is not left unaddressed.
communities, which necessitates a provision for Travelling Showpeople
variety of site layouts. For example, will be privately funded, but in
some sites for New Travellers may be view of the prevailing economic
quite informal in design and may not circumstances this assumption
feature all standard facilities, whereas should be kept under regular
some sites for other Gypsies and review. Any emerging evidence
Travellers may require additional land of an increasing inability to
in order to accommodate animals make self-provision should be
and/or commercial activities. investigated to see whether public
support can be made available.
20Provision of New Accommodation for Gypsies,
Travellers and Travelling Showpeople
9.25 Consequently, local authorities The Green Belt Joint Working / Cross-
are encouraged to consider
Boundary Working
developing bids to the Grant 9.27 ODPM Circular 01/2006
programme and to seek advice acknowledges the difficulties that 9.28 It is recognised that the
from the HCA, the Assembly (or many rural authorities face in delivery of additional pitches and
its successor body) and GOWM, terms of the supply of affordable plots will be challenging for many
where appropriate. Examples of land to meet the accommodation local authorities and it is therefore
innovation in delivery are particularly needs of Gypsies and Travellers. suggested that a collaborative
encouraged, with creative partnership Consequently, while development approach may benefit some of the
arrangements between local within the Green Belt is normally issues involved. The delivery of
authorities, RSLs and Registered inappropriate, authorities in this new accommodation for Gypsies,
Providers, and Gypsy and Traveller situation should consider including Travellers and Travelling Showpeople
communities. Proposals for a ‘Rural Exception Policy’ in their must be seen within the wider
shared-ownership or self-build DPDs and bear in mind the possibility agendas of community cohesion and
schemes may be suggested. of adjustments to Green Belt social inclusion. Local authorities are
boundaries which can be made in encouraged to consider undertaking
9.26 Local authorities are also exceptional circumstances for the community development work
asked to encourage the provision provision of Gypsy and Traveller sites. to secure improved community
of sites through private funds, such
understanding of the issues
as private developer contributions
involved and to develop local
and Gypsy and Traveller pitch
leadership in order to drive forward
provision within new large-scale
a sustainable pattern of delivery.
residential developments.
Monitoring
9.29 Progress on the delivery of new
accommodation by each LPA will
be monitored through the Annual
Monitoring Report (AMR). The HCA
will be partners with the regional
bodies monitoring this and will include
the results in its Single Conversation
work with local authorities.
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