Central Bedfordshire Pre-submission Local Plan (January 2018)

Core Policies

The following sections contain a series of Core Policies on economic growth, housing, historic and built environment, environmental management, transport and infrastructure. It is through the delivery and monitoring of these policies that the Vision and Strategic Objectives of this Central Bedfordshire Local Plan will be achieved.

11 Housing

11.1 Housing Mix

11.1.1 An appropriate and inclusive housing mix contributes to well-designed places that produce strong community cohesion and cater for a diverse range of household needs. This emphasises the importance of achieving a suitable housing mix as part of this Local Plan.

11.1.2 The main evidence base underpinning a good mix of housing will predominantly be based on the Strategic Housing Market Assessment (SHMA) 2017. The SHMA explores the housing types, sizes, mix and tenure types needed in Central Bedfordshire, and forecasts the housing requirements for the period up to 2035. It takes into consideration population forecasts, births, deaths and migration to indicate the household need, and will highlight growth in particular groups such as the elderly and first time buyers and self builders. This information will form the basis of ensuring that an appropriate mix and volume of housing is achieved.

11.1.3 Other evidence considered will include:

• Local Housing Market analysis
• Use of housing needs assessment
• Population projections
• Housing Market Gap Analysis
• Regard for the under-supply and loss of bungalows
• Current housing market conditions
• Existing housing mix in the locality
• Self and Custom Build register data

11.1.4 Within the mix of housing, we need to ensure that development provides good quality housing; a variety of homes including, flats, bungalows, and family housing for all parts of the community. It is also important to ensure that homes are built to a good standard with particular attention given to well insulated and ventilated homes with adequate room, space and light.

11.1.5 Before the Council can begin constructing a suitable housing mix, we must have regard for the amount of homes required to meet the Objectively Assessed Need (OAN) for both market and affordable housing within the area. The Strategic Housing Market Assessment (SHMA) sets out the evidence base which supports the OAN. This assessment of need within the SHMA states that 32,000 dwellings are required in the new plan period 2015-2035, this amounts to 1,684 dwellings per annum. Finally the SHMA has emphasised that 30% of housing on all development sites should be affordable housing.

11.1.6 Affordable housing can be delivered in many forms, including affordable rented accommodation and shared ownership.

11.1.7 Aside from affordable housing, other alternatives are available to help individuals access homeownership such as Right to Buy or the Help to Buy; Equity Loan scheme which has been extremely popular in the last few years within Central Bedfordshire.

Housing requirements

11.1.8 The information from the SHMA supports a requirement for smaller homes for people to downsize into. This is particularly relevant as the implications of the Spare Room Subsidy means that many working age families have to downsize. There is still a need for family sized homes, for growing families, as demographic information from the SHMA identifies that as children grow they need their own room and space.

11.1.9 There is a need similarly for younger households, particularly first time buyers who find it difficult to access the housing market at open market values. Smaller properties at the entry-level end of the market are needed to meet this specific demand. Housing options for younger people will include purchasing an affordable unit such as starter homes or a shared ownership property at first. Smaller units are also required for older people to downsize into – freeing up larger family homes.

11.1.10 An appropriate housing mix will need to have regard for people with specific care needs, e.g. learning disabilities and other vulnerable groups, such as gypsies and travellers (i.e. those that do not meet the PPTS definition) care leavers and homeless families. Properties need to be well designed, in good locations and easily adapted to suit individual's care needs.

Empty Homes

11.1.11 Central Bedfordshire has approximately 1,200 empty homes which is only a small proportion of the housing stock, and is around 1.5% of the total number of houses. However some of these properties have been empty for many years, and through effective stock management, these empty homes could potentially provide much needed housing for several families.

11.1.12 The Council intends to continue to take a pro-active approach to bringing empty properties back into use in order to maximise housing delivery, which can be viewed in the Housing Strategy 2016-21.

11.2 Housing Standards Review

11.2.1 The Council will adhere to the most up to date Government Legislation and new planning guidance to determine the appropriate housing standards to be applied within Central Bedfordshire. The National Planning Policy Framework (NPPF) is clear that local planning authorities should plan to create safe, accessible environments and promote inclusion and community cohesion. This includes buildings and their surrounding spaces. Local planning authorities should take account of evidence that demonstrates a clear need for housing for people with specific housing needs and it should plan to meet this need.

Space standards

11.2.2 Where a local planning authority wishes to apply an internal space standard, they should only do so by reference to the Nationally Described Space Standard within their Local Plan. The Nationally Described Space Standard (NDSS) is the published guidance recommended from the Government's Housing Standards review. Central Bedfordshire Council will endorse the use of the Nationally Described Space standards, as prescribed by Central Government.

11.2.3 The Housing Standards Review stated that all new properties should be built to Category 1 standards as Part M of Building Regulations. Whilst this is a good basic standard of building and offers good design, it does not promote flexible or adaptable design.

11.2.4 Local planning authorities have the option to set additional technical requirements exceeding the minimum standards required by Building Regulations in respect of access. Local planning authorities will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans.

Disabilities

11.2.5 The Council spent £2.132m on Disabled Facilities Grants (DFGs) in 2015/16. This was primarily for level access shower/wet room adaptations but also other minor adaptations. It is inevitably more costly to retrospectively fit adaptations into existing properties rather design them into new build properties; hence the £2.1m spend on DFG on existing housing stock. The expenditure on DFG's would have been avoided if there was a good supply of flexible and adaptable homes within new delivery. As such, the Council has built an evidence base of DFG expenditure and also with the backlog of need through the preceding years can demonstrate a requirement for category 2 homes in future. Planning conditions may be used to secure Category 2 M4 (2) dwellings on all applications.

11.2.6 Information from the Projecting Adult Needs and Service Information (PANSI) states that currently 13,159 people between the age of 16-64 years have a moderate physical disability and a further 3,930 people have a severe physical disability, This is set to increase to 14,518 people with a moderate disability and 4,433 people with a severe physical disability by 2030.

11.2.7 Category 3 M4 (3) is fully wheelchair accessible homes that specifically caters to the needs of occupants who have severe, physical mobility issues. These incorporate more extensive design requirements. The Council will analyse the need for both wheelchair accessible and wheelchair adaptable homes, bearing in-mind the projected 4,433 people that will have a severe physical disability by 2030.

11.2.8 This analysis of need will form the basis for individual site negotiations as a direct response to need. In requiring wheelchair accessible homes from all future development; the Council will be targeted, strategic and opportunistic about how it negotiates for wheelchair accessible homes.

11.2.9 The emphasis will be on an evidence-led approach which uses internal knowledge of applicants on the housing register that have a physical disability to target delivery on future new build development.

Learning Disabilities

11.2.10 People with learning disabilities have the same aspirations as any other person's requirements for appropriate, accessible housing. Many people with learning disabilities do live at home until carers (parents) are deceased or the carers are no longer able to care for them. Some people come through the adult care system sooner for many different reasons and will often require help with basic life skills.

11.2.11 Central Bedfordshire is forecasting a rise in its learning disability population. The increase includes those people with severe learning disabilities and those presenting with challenging behaviour.

11.2.12 12.2.12 In 2017 the total population predicated to have a learning disability between the age of 18 – 64 is 4,134 and this is expected to increase by 539 people in 2035 a 11.5% increase. Older people from 65 years with a moderate to severe learning disability is predicted to increase from 143 people in 2017 up to 220 in 2035 a 35% increase.

11.2.13 People with a learning disability should have choice about where they live and who they live with. There is growing evidence to support that inappropriate housing arrangements increase the likelihood of people presenting with behaviours described as challenging, which can lead to placement breakdown and an avoidable admission into hospital. There is an expected 10% increase in the number of people with challenging behaviour from 2017 – 2035.

11.2.14 An increase in the housing options for people with learning disabilities and/or autism will enable people to access the right home and support at the right time and increase people's ability to live as independently as possible. Housing options should be based on individual need and be an integral component of person centred care and support. Everyone should either be offered their own tenancy in settled accommodation or to own their own home.

11.2.15 Supported living is becoming the preferred model of accommodation, care and support and it is where an individual's support and housing needs are built around them rather than fitter an individual into a service. It is enabling people to live life with the same choices, rights and responsibilities as other citizens. Models of supported living vary; people may have their own property within a wider development for other people who need support with some schemes offering communal living space as well. The environment could also offer a blend of services that can safely manage risks for more complex individuals living in a community setting. Accommodation for people with a learning disability and/or autism should feel well integrated within the local community, with good access to transport links, local amenities and services.As there is a limited supply of settled accommodation options available. The council will encourage developers to come forward and bring innovative ideas in accommodating individuals with learning disabilities. All possibilities will be considered.

11.3 Supporting an Ageing Population

11.3.1 The demographics of Central Bedfordshire is no different from the current demographics of England, whereby there is an increase growth of people over 65+ and a further noticeable growth of the 85+. This rise becomes even more significant in the               85+ age range where the population of people is set to rise by over two-              and-a-half times from 5,400 in 2015 to 13,700 by 2035. Besides the growth of the older population, residents of Central Bedfordshire have a longer life expectancy than the national average, ranging from 84 years for women and 81 years for men. (The UK Quality of Life Index – rates Central Bedfordshire 13th best place to live in the UK 2015). With later life come increasing ill health and disability and the prevalence of health problems and frailty increases sharply in later old age. This can lead to complex and challenging care needs, and therefore requiring specialist care.

11.3.2 Central Bedfordshire is a relatively affluent area where the majority of older residents (76.9%) own their home. Of the remainder 17.0% rent from a social landlord, 3.6% privately rent and 2.5% live rent free. Research shows that older people prefer to retain the same tenure arrangement if they move. (ORS - Assessment of the Housing Needs of Older People in Central Bedfordshire March 2017)

11.3.3 As there is a lack of suitable accommodation options for older people in Central Bedfordshire Council, and the Council would like to work with the market to deliver the following:

• Mainstream homes designed for older people
• Housing-with-care and housing-with support schemes to meet local needs
• Care homes that meet modern standards and customer expectations, providing an attractive living environment as well as high quality care

11.3.4 There is only 2% of housing that is aimed at older people and there is a need for appropriate housing for older people, and as the population grows older, there is a further demand for care and support needs. This is supported by evidence provided in the ORS report, whereby mainly older people are now relying on having support and care needs provided from external companies.

11.3.5 Providing suitable accommodation for older people is a key requirement because it provides an attractive option to encourage older people to downsize and free-up larger properties which are more suitable for families; therefore making an efficient use of current housing stock.

11.3.6 In the last ten years there has been significant research undertaken into the needs and aspirations of older people[13]. Emerging from them is the conceptof 'downsizing' - the phenomenon of older people moving from their existing homes to smaller properties that better suit their needs thus releasing larger homes back into the pool of available housing. The need for smaller units is essential due to the particular growth of the over 65 population in Central Bedfordshire. There needs to be a mix of 1 and particularly 2 beds to cater for the older population, in the form of bungalows, mobility homes standards, possibly flatted maisonettes and other mainstream housing. As well as various house types, a good housing mix will also incorporate various housing tenure options such as outright purchased properties, shared ownership and other available options.

11.3.7 There is a particular need to retain bungalows for older people, as this is one of the preferred accommodation types for people who are aging yet want to retain a high level of independence. However, there has been a noticeable loss of these units due to existing bungalows being converted into two storey family homes. This places an additional requirement on future new supply to compensate for the backlog of chronic under-delivery and loss of existing bungalows.

11.3.8 Central Bedfordshire wants more bungalows and level access homes, such as ground floor apartments and apartments with appropriate lifts to cater for people with mobility issues. However, in the last few years a number of bungalows have been demolished and replaced with two storey family homes; therefore losing ideal homes for older people with specific needs. The authority area has seen over 19 bungalows lost in the last 3 years (2013-16 financial years) but the broader housing development market has not looked at replacing them. The ORS report also states that the need for bungalows is greatly the preferred type of accommodation for older people however; this is causing issues with affordability. The result is that during the period to 2035 period there will be a demonstrable need for at least 9050 of new dwellings to be suitable for older people wishing or needing to downsize. This represents 23% of the planned housing growth during that period.

11.3.9 There is demand and many people do wish to downsize to these types of properties, but older people feel that the affordability of such a unit is too costly, and therefore do not move.

11.3.10 Sites within existing settlements (especially those close to town centres) can be ideal for specialist housing schemes and this option should be explored before alternative uses are permitted. Downsizers have a strong preference to retain their tenure type when downsizing. In Central Bedfordshire 80% of people over 65 are owner-occupiers and this should be reflected in the tenure mix of schemes. Intermediate tenancies (shared ownership) are considered to be a downsizer option for owner-occupiers who may lack the means to access similar accommodation on the open market.

11.3.11 Therefore to support our ageing population, suitable and appropriate accommodation for older persons should be part of the overall inclusive housing mix. We would want to see developers provide housing for older people as part of their development schemes, in the form of bungalows and low level maisonettes.

11.4 Affordable Housing

11.4.1 The NPPF sets out the government's clear intention to provide good quality affordable housing for all. This forms part of a wider agenda to create sustainable, mixed and integrated communities.

11.4.2 The case for affordable housing is well documented both nationally and particularly within Central Bedfordshire. For example, Land Registry information highlights how the average house price within Central Bedfordshire has risen over the years rising to £270,546 as at April 2016. When this is coupled with the fact that the average household earnings have not risen in line with house prices, this gives a stark depiction of just how serious the problem is. Further evidence will be contained in the Housing topic paper.

11.4.3 Based on the results of the SHMA, this Local Plan requires that 30% of all units from qualifying sites will be for affordable housing. As part of the affordable housing requirement the SHMA outlines the Council's tenure requirements. Qualifying sites will be expected to provide 73% affordable rent and 27% intermediate tenure. This policy, together with the rural exceptions policy, should help to meet the affordable housing needs within Central Bedfordshire.

Viability Testing Framework (LP)

11.4.4 The viability of each site will continue to be considered on a case by case basis and will be discussed with the applicant. The emphasis of these discussions will be to enable a viable degree of affordable housing on site.

11.4.5 The applicant will be expected to provide comprehensive supporting information to enable the Council to make an informed decision on the financial viability of the proposed development scheme. This information will include, as a minimum, a detailed cost plan and specification together with properly analysed evidence justifying proposed sales values and a detailed valuation of existing use value. The information will be assessed by the Council advised by an independent assessor as and when required, and the applicant will be expected to pay the cost of this assessment.

11.4.6 If a scheme is approved on the basis of a robustly evidenced affordable housing offer which is below policy requirements, the section 106 agreement will include provision for a re-appraisal of viability. The purpose of this viability review will be to seek a future uplift in affordable housing provision.

11.4.7 Applicants should expect that a restriction on occupation of an appropriate number of market units to reflect the policy shortfall will be required to secure any further contribution from the assessment process. The applicant will be required to submit detailed evidence to the Council on an open book basis of the actual costs expended and values generated by the scheme and, where viability has improved, the applicant will be expected to make further affordable housing provision up to the maximum policy shortfall. This further affordable provision will be sought in accordance with the Central Bedfordshire Local Plan.

11.4.8 In order to secure delivery and provide mixed new communities, the Council has a preference for affordable housing delivery on-site. However, there may be specific circumstances relating to appropriateness of location, where a commuted sum towards off-site provision may be considered in lieu of part of the 30% requirement to complement the on-site affordable housing provision. The formal mechanisms required to secure off site contributions will be detailed in standard clauses in the Council's section 106 agreement.

11.4.9 Commuted sums are calculated on the basis of 50% of the open market value for each unit in question. If the policy compliant commuted sum can not be achieved a viability will determine the sum.

11.5 Rural Exception Sites

11.5.1 Central Bedfordshire contains a number of small settlements which are rural in character. Typically, because of their attractive rural location and character, house prices in these villages are relatively high in comparison to the more urban areas. This often makes it difficult for some households to purchase or privately rent properties within the villages.

11.5.2 Historically there has been a shortfall in the delivery of affordable housing within these rural areas, partly due to the limited opportunity for in-fill developments within these villages. Rural exception sites – sites outside of the Settlement Envelope used for affordable housing have been the most efficient way of providing affordable housing for rural communities to date. With the implications of the NPPG restricting affordable contributions on sites of 10 or less dwellings, rural exception sites are becoming more critical for the delivery of affordable housing in the rural communities of Central Bedfordshire.

11.5.3 In addition, there is also a need for additional affordable housing provision around the larger settlements. While development opportunities are greater here, so is the level of affordable housing need. The policy below therefore enables exception sites to be brought forward around the larger settlements.

11.5.4 Whilst neighbourhood planning could potentially bring forward a degree of affordable housing, the continued delivery of exception sites will form a key part of affordable housing delivery. To help increase the delivery from exception sites, a limited number of open market dwellings can be provided if a rural exception scheme is not viable as 100% affordable.. The Council will allow for up to 20% market housing on exception schemes if viability issues are demonstrated.

11.5.5 A careful balance must be struck in terms of having regard for a settlement's character and settlement boundaries whilst being mindful of the need to meet an identified local housing need from that settlement. The use of sites which relate well to the settlement boundary go some way to achieving this balance.

11.5.6 The underlying purpose of an exception site is to meet the identified housing needs of local people. It is designed to accommodate households local to the settlement in accordance with the Council's adopted Local Lettings Policy. It is envisaged that the supply of exception sites will provide a means for people who would ordinarily not be able to afford to live within that settlement to remain within their local community.

11.5.7 A pre-requisite of any household being eligible for these properties will be that they have a demonstrable housing need and a strong local connection to the Parish in question. The housing need will be evidenced by the household being registered with the Council, Registered Provider or alternative affordable housing provider.

11.5.8 A local housing needs' survey will be conducted within the settlement to evidence the level of demand for affordable housing. It will identify the number of affordable homes, the tenure and size of the property needed. The identified needs and requirements will form the evidence base upon which the Council, landowners, Registered Providers, house builders and the Town or Parish Council will work-up plans for the exception site.

11.5.9 The sites in rural areas will usually be limited to 10 dwellings in order to preserve the character of the settlement. However, if a housing needs' survey supports a demand for more than 10 dwellings and it can be demonstrated that a larger development will not have an adverse effect on the character of the settlement, larger sites may be considered.

11.5.10 The exception site will be subject to a Section 106 agreement which will set out that the affordable properties must remain as affordable housing in perpetuity. A householder for a shared ownership property will be able to buy additional equity shares of their property. This will be restricted to a maximum of 80% equity share of the property meaning the property is not completely owned outright by the householder and remains as affordable in perpetuity.

11.5.11 Any re-sale of shared ownership properties will go to a household in housing need as directed by the Council's Local Lettings Policy in regard to the procedure for shared ownership. The Section 106 agreement will also ensure the appropriate phasing of the affordable and open market dwellings.

11.5.12 The overall aim of the policy overleaf is to provide high quality affordable homes for local people in housing need.

11.6 Starter Homes

11.6.1 The Housing and Planning Act 2016 sets out the Government's agenda to support homeownership, particularly through the delivery of Starter Homes.

11.6.2 A starter home is a new build property which is offered at a minimum of 20% below market value. The discounted price should be no more than £250,000 outside London and £450,000 in London.

11.6.3 Starter Homes are specifically aimed at the first-time buyer market and will be offered to people who are under 40 years old at the time of purchase and have not previously owned a home. The Starter Home property cannot be sold or re-let for a period of 8 years after initial sale; after which, the property can be sold on the open market at full value.

11.6.4 The appropriate balance between compliance with the Housing & Planning Act and also the strength of local evidence must be struck. Previous chapters adequately explain the overwhelming demand for affordable rented properties (as demonstrated by the SHMA 2015). Central Bedfordshire Council is of the opinion that appropriate weight should be given to this factual evidence when determining planning applications in support of a suitable local housing mix.

11.6.5 The Housing and Planning Act requires that local planning authorities may only grant planning permission if applicants enter into a planning obligation to provide a certain number of Starter Homes.

11.6.6 Starter homes are now considered to be an Affordable Housing tenure under the revised NPPF and the Government expects local planning authorities to deliver a proportion of Starter Homes as part of affordable housing delivery through S106 agreements. This will be confirmed following the consultation within the Housing White paper.

11.6.7 The provisions within the Housing & Planning Act and subsequent discussions with DCLG confirm that the starter homes will apply to each individual qualifying site so Central Bedfordshire Council must have regard for the duty.

11.6.8 Para 5 (2) of the Housing and Planning Act states that Local planning authorities can dispense with the planning condition relating to starter homes where:

• (a) An application is made for planning permission in respect of a rural Exception site, and
• (b) The application falls to be determined wholly or partly on the basis of policy contained in a development plan for the provision of housing on rural exception sites.

10.6.9 Therefore the Starter Homes planning condition does not apply to rural exception sites or land allocated for the provision of rural exception sites.

10.6.10 Para (4) of the Housing and Planning Act states:

• "The starter homes requirement" means a requirement, specified in the regulations, relating to the provision of starter homes in England

10.6.11 We await the publication of the aforementioned regulations to specify the actual Starter Home requirement. However, the Housing White Paper has made its intention clear to specify a minimum 10% requirement which will encompass various homeownership options as well as Starter Homes. Until the consultation on the Housing White paper is concluded, and secondary legislation is enacted, The Council will work on this assumption.

16.6.12 This local plan policy seeks to provide interim guidance on the Starter Homes requirement in the absence of secondary legislation.

11.7 Self and Custom Build Housing

11.7.1 The Self-build & Custom Housebuilding Act (2015) (as amended) places a duty on local authorities to:

• keep a register of people and groups interested in acquiring serviced plots to build their own homes,
• have a regard to their register as a material consideration in planning decisions, and;
• to meet the demand for self-build and custom housebuilding in the Council's area within statutory time limits

11.7.2 Self and custom build housing is housing built or commissioned by individuals or groups of individuals for their own occupation. A serviced plot is defined by the Act as a plot of land that has access to a public highway and has connections for electricity, water and waste water, or can be provided with those things in specified circumstances or a specified period. This definition may be amended by future legislation and guidance from the Government.

11.7.3 The Council operates its own Self & Custom Build Register (the register) which determines the local level of demand for serviced plots. To fulfil this demand, the Council will look to support applications for the delivery of serviced plots on suitable sites.

11.7.4 This policy sets out requirements for the delivery of serviced plots to support self and custom house building and does not set requirements for the building of dwellings by individuals on plots other than serviced plots.

Serviced Plots Delivery

11.7.5 The Council recognises that there is a growing interest from people to influence the design and specification and even to build their own home. The Council also recognises the potential of self and custom housebuilding to increase delivery of new build homes in the local area.

11.7.6 The national Ipsos Mori survey in 2015 showed that 53% of the adult population in the UK would like to build their own home at some stage of their lives and 14% were researching or planning building it in the next 12 months.

11.7.7 For the period 2011 to 2016, only around 40 new houses a year build as single house on single plots of land in Central Bedfordshire. The data from the Council's own register indicates that the demand is much higher, with 150 people registered in the first year of its operation alone. The National Custom and Self Build Association cite finding a suitable plot of land as the biggest barrier to self and custom housebuilding.

11.7.8 To address the issue of a shortage of land the Council will work with local partners, such as local agents and landowners, to grant suitable planning permissions in order to provide enough serviced plots to meet the local demand (as demonstrated by the register) and help self and custom builders realise their ambitions of building their own home. The Council will support delivery of serviced plots on sites suitable for residential development within settlement envelopes. Delivery of serviced plots outside settlement envelopes will only be supported where it enables delivery of affordable housing on rural exception sites (please see Rural Exception Sites Policy).

11.7.9 Sites allocated in the Local Plan will be expected to deliver up to 20% of the planned dwellings as serviced plots for self and custom builders. The number of plots to be delivered on each site will be determined on a case by case basis at the time of application, reflecting the demand demonstrated on the register at that time.

Legal agreement

11.7.10 To ensure the delivery of serviced plots to self and custom builders the Council will require developers to enter into section 106 agreement that will cover issues including timescales and phasing of plots delivery, appropriate marketing of plots to self and custom builders and lengh of time after which unsold plots will be returned to the developer.

11.7.11 All serviced plots will be required to have, or have been provided, within a specified period access to a public highway and connection to electricity, water and waste water as minimum required by the legislation, and gas where the gas network present in the area and connection is viable.

Meeting housing needs

11.7.12 While the Council is supportive of proposals for self and custom build projects, it is important that these applications do not compromise the ability of the Council to meet housing needs. Therefore all applications for delivery of serviced plots must comply with all housing and other policies as set out in this Plan.

11.8 Planning for Gypsy and Traveller Sites

11.8.1 The pitch and plot requirements for Gypsies and Travellers and Travelling Showpeople are set out in Strategic Policy SP7 at the head of this Plan. This establishes the need for those Gypsies, Travellers, and Travelling Showpeople which accord with the planning definition, as defined in Annex 1 of the revised 2015 Planning Policy for Traveller Sites (PPTS). However, the Council is also mindful of its duties under the Equality Act. In particular there may be travellers who no longer travel, and therefore no longer fall under the planning definition, but for whom the Council may still need to provide culturally suitable housing under the requirements of the Equality Act. Therefore the following policies applies to all Gypsies, Travellers, and Travelling Showpeople.

11.8.2 New sites should be planned sensitively to take account of the needs of both the travelling and settled communities. Specific considerations include:

• The promotion of peaceful and integrated co-existence between the site and the local community;
• The wider benefits of easier access to Health Services;
• Access to local schools to enable Gypsy and Traveller children to attend school regularly;
• A settled base that reduces the need for long distance travelling, and the possible environmental damage caused by unauthorised encampments;
• Consideration of the effect of local environmental quality, such as noise or air quality, on the health and well being of any Gypsy and Travellers or others as a result of the development;
• Access to local shops; and
• Access to local employment opportunities.

11.8.3 In order to benefit from access to facilities and services such as health and education, first preference should be given to sites that are located closer to existing settlements. However, traditionally some Gypsy and Traveller families prefer to live in the countryside, on privately owned and managed sites. Such locations will be considered where they are constraint free, or where any constraints could be satisfactorily mitigated.

11.8.4 Applications will be considered on their merits in the context of site size and location, and the characteristics of the surrounding area. Planning permissions might restrict the size of sites and where appropriate recommend a "cap" on the number of people allowed to live on the site on a permanent basis or the number of caravans being stationed on a site.

11.9 Planning for Travelling Showpeople Sites

11.9.1 Travelling Showpeople's needs are distinct to the needs of the wider Gypsy and Traveller community:

• They do not share the same cultures or traditions as Gypsies and Travellers.
• Travelling Showpeople sites combine residential, storage and maintenance uses, and require secure permanent bases for the storage of their equipment.
• Applications for Travelling Showpeople sites will be assessed against the criteria in Policy H8, and the specific criteria in Policy H9 below.