FAQs – GNLP Gypsy and Traveller Sites Focused Consultation (Jan-March 2023)

Why are you running the Gypsy and Traveller Sites Focused Consultation?

Local councils have a responsibility to assess the accommodation needs of all people living in the area. This includes allocating sufficient Gypsy and Traveller sites with pitches for caravans in their local plans.

The guidance and rules for how councils should write their local plans is set out in the National Planning Policy Framework (NPPF) and in allied guidance specifically for Gypsies and Travellers in Planning Policy for Travellers Sites (PPTS) (2015). The PPTS requires local plans to have ‘specific deliverable sites sufficient to provide 5 years-worth of sites against their locally set targets… [and] specific, developable sites, or broad locations for growth, for years 6 to 10 and, where possible, for years 11-15’.

The emerging local plan for this area, the Greater Norwich Local Plan (GNLP), was submitted to government for independent examination in July 2021. The plan is being produced by Broadland District, Norwich City and South Norfolk Councils together with Norfolk County Council, which are together called the Greater Norwich Development Partnership (GNDP).

The partnership is currently seeking land to allocate in the GNLP for Gypsies and Travellers. This Gypsy and Traveller Sites Focused Consultation is part of this process. The partnership has identified several sites and is holding the public consultation to understand which of them are suitable and can be included in the GNLP.

The consultation runs from 30 January to 20 March 2023 so that by the summer the comments can be considered, further assessments can be completed, and the preferred Gypsy and Traveller sites can be chosen and added to the GNLP.

How do I view the consultation documents?

You can access the consultation documents and supporting evidence on our website.

You can also view the consultation documents in libraries using their computers.

Hard copies of the consultation documents are available at the following locations. 

Please note that viewing the documents at Broadland and South Norfolk council offices and at Norfolk County Council offices is by appointment only. Please contact the GNLP team by email at gnlp@norfolk.gov.uk or by telephone at 01603 306603 to make an appointment.

  • Broadland District Council and South Norfolk Council offices, Thorpe Lodge, 1 Yarmouth Road, Norwich NR7 0DU (by appointment); 
  • Norwich City Council, City Hall, St Peters Street, Norwich NR2 1NH (main entrance – please ask to be directed.  Mon. – Fri. 08.45 – 13.00 & 14.00 – 17.00);
  • Norfolk County Council, County Hall, Martineau Lane, Norwich NR1 2DH (by appointment); and 
  • South Norfolk information point at The Octagon, Mere Street, Diss IP22 4AH (Mon. – Fri. 09.00 – 17.00).

How do I submit representations?

Anyone can comment on the proposed sites and/or supporting evidence. There are three ways you can respond.

1. Comment online using our online consultation system. This is the easiest and most efficient way to respond. Comment directly on the GNLP Gypsy and Traveller Site Policies, which outlines the proposed sites, and the supporting evidence by clicking on the blue speech bubble icon to the left of the paragraph, map or document you wish to address. 

2. Submit a response form by email. Download a response form. Fill it in electronically and send it to us as an attachment to an email to gnlp@norfolk.gov.uk. When commenting on a policy or site this way, please include the site reference(s) in your comments.

3. Contact the GNLP team by email or by telephone at 01603 306603 and request a paper response form by post. Complete the form and send it to:

Greater Norwich Local Plan Team

Room 428
City Hall
St Peter's Street
Norwich
NR2 1NH

When commenting on a policy or site this way, please include the site reference(s) in your comments.

You may comment on as many or as few of the sites, policies, paragraphs and maps as you wish to.  All comments must be submitted in writing as they will become part of the formal examination process for the GNLP and therefore must be available for the independent Inspectors to consider. Therefore, we cannot accept representations by telephone.


The local councils are committed to making sure that everyone who wants to have their say about site allocations has the opportunity to make their views heard. However, representations that are deemed to contain offensive comments will not be published. 
 

Can I make an anonymous representation and what do you do with my personal data?

All comments made will be passed on to the independent Inspectors as part of the local plan examination process and therefore cannot be anonymous.

You may either submit a representation under your own name or write to your district councillor who may submit a representation on your behalf using our online consultation system  or by downloading a response form and returning it by email to gnlp@norfolk.gov.uk or by post to:

Greater Norwich Local Plan Team

Room 428
City Hall
St Peter's Street
Norwich
NR2 1NH

The name of the respondent will be published publicly alongside all representations on our website. Contact details will not be published and we will redact personal data from comments published online in line with our privacy notice. 

Read the GNLP Privacy Notice 

Access the Planning Inspectorate Privacy Notice

Who are Gypsies and Travellers and who is the GNLP allocating sites for?

The term ‘Gypsies and Travellers’ does not cover a single, homogenous group, but encompasses a range of groups with different histories, cultures and beliefs including Romany Gypsies, Welsh Gypsies, Scottish Gypsy Travellers and Irish Travellers. These are ethnic groups recognised by the courts and declared to be protected “races” under the Equality Act 2010. However, some groups like showpeople and New (or New Age) Travellers fall outside the Equality Act 2010 definition.

The most recent version of the Planning Policy for Traveller Sites (PPTS), published in 2015, changed the previous definition of Gypsies and Travellers for planning purposes by excluding those people who have permanently ceased to travel.

This change prompted a legal case which challenged the definition of Gypsies and Travellers for planning purposes as it excludes families that had stopped travelling permanently due to age, ill health, or disability.

In October 2022, the Court of Appeal ruled on the case saying that the objective of the PPTS 2015 in excluding households who have ceased to travel from needing a pitch could not be justified and ran counter to the stated aims of the PPTS and the NPPF.

How many Gypsy and Traveller pitches are needed in the Greater Norwich area?

Government guidance says councils must assess the accommodation needs of Gypsies and Travellers. The Greater Norwich Gypsy and Traveller Accommodation Assessment (GTAA), published in 2022, identifies a need for up to 50 new pitches between April 2022 and March 2038. However, since preparing the GTAA this figure has gone up to 53 pitches as 3 further pitches that had been anticipated through the redevelopment of an existing site are not now deliverable. Further details on the GTAA are below.

What is a Gypsy and Traveller pitch and how big is it?

The actual size of a pitch varies but is a space of land big enough to provide for one household. This may vary depending on the size of the household in a similar way to housing for the settled community, but generally means enough room for an amenity block consisting of a kitchen, bathroom and living room, plus space for 2 caravans and 2 vehicles. As a guideline a pitch will require approximately 300 square metres. 

How many pitches are there on a Gypsy and Traveller site?

There is no minimum or maximum number of pitches for a Gypsy and Traveller site. Smaller sites of 3-4 pitches can be suitable for one extended family. Sites of approximately 15 pitches can be successful but equally there are many successful larger sites that already exist.

How many sites have been identified to cover the need for pitches and is this the final list?

The consultation includes 10 favoured sites to deliver up to 62 pitches against the overall ethnic need of 53 pitches, and a further reasonable alternative site for 10 pitches at Ketteringham. 
This is not the final list. Landowners can submit their land to be considered for a site for Gypsy and Traveller accommodation through this consultation. If further sites are submitted, they will be assessed by officers for suitability  before being considered by councillors and being brought forward as a main modification to the plan, subject to further consultation.
 

Can I submit a site during the Gypsy and Traveller Sites Focused Consultation? How will it be considered for inclusion in the local plan?

Landowners can submit their land to be considered for a site for Gypsy and Traveller accommodation through this consultation. Download a site submission form and submit it by email or by post. We ask that site promoters include as much as possible to evidence the suitability of the site. Ideally, supporting evidence would include a Sustainability Appraisal. 

After the consultation closes newly submitted sites will be assessed by officers before being considered by councillors and possibly being brought forward as a main modification to the plan, subject to further consultation. 
 

When will the Gypsy and Traveller sites be chosen?

Once this consultation closes on 20 March 2023, all the responses will be analysed, and any new sites will be considered. Council reports will then identify the preferred sites for inclusion in the plan and the inspectors examining the GNLP will consider this issue during the summer.

After that, in autumn 2023, preferred sites are very likely to be included in the inspectors’ Schedule of Main Modifications to the GNLP. There will be a modifications consultation and, subject to the outcome of the consultation, Gypsy and Traveller sites are likely to be included in the GNLP once it is adopted in 2024.  

What is the difference between a privately owned and publicly owned site?

A privately owned site is one where a Gypsy and Traveller family owns the land. A publicly owned site is owned and managed by a council or housing association which rents pitches to Gypsy and Traveller families

In both cases, sites need to have planning permission and to be licensed by the council to allow people to live there all year round.

What is the difference between a residential site and a transit site?

A residential site is one where Gypsy and Traveller families live for most of the year and is their home. A transit site provides temporary accommodation.

The length of stay on a transit site can vary, but it is usually set at between 28 days and three months. A Gypsy and Traveller family may stay there before moving to a permanent pitch or perhaps if they are visiting – for example, to give care and support to a family member for a short period of time.

There are no current plans to provide extra transit sites in Greater Norwich as there is already one transit site which is in the process of being refurbished and is sufficient to meet needs.

Why do Gypsies and Travellers need sites if they have ceased to travel and why don’t they just live in bricks and mortar housing like other people?

Many people of Gypsy and Traveller heritage and ethnic background now live in settled accommodation and do not travel, or do not travel frequently. Nonetheless, many consider travelling to be part of their cultural identity and want to maintain a nomadic lifestyle. The law also recognises Romany Gypsies, Welsh Gypsies, Scottish Gypsy Travellers and Irish Travellers as defined ethnic groups, and this does not change with their nomadic lifestyle changing for reasons to do with old age, ill health, or living a settled lifestyle.

What is the Gypsy and Traveller Accommodation Assessment (GTAA)?

The government requires councils to have evidence on the needs of Gypsies and Travellers accommodation in their area. The partnership has regularly updated its evidence and its most recent Gypsy and Traveller Accommodation Assessment (GTAA) was completed in June 2022. The Greater Norwich GTAA was produced on behalf of the partnership by a company called RRR Consultancy.

The GTAA is a piece of primary research to understand how many Gypsy and Traveller pitches are required in the Greater Norwich area over the period of April 2022 to March 2038. It updates and supersedes the previous Gypsy and Traveller Accommodation Needs Assessment which was prepared in 2017.
 

What is the Site Assessment Information for?

The Site Assessment Information document is a piece of supporting evidence for this consultation and the GNLP as a whole. It explains how each of the sites performs against the criteria set for what would make a suitable Gypsy and Traveller site.

The Site Assessment process investigated each proposed site for its vehicular access, distance to local services and facilities, access to the main road network, adverse impacts on biodiversity and open space, land contamination and ground stability, flood risk, adverse impact on landscape and listed buildings, minimising impact on neighbouring communities, and the availability of electricity and water supplies to the site.

The Site Assessment Information document considers a total of 14 sites. 10 sites were identified favoured options, 1 site as a reasonable alternative, and 3 sites were rejected as unreasonable.

Respondents to the consultation can comment on the contents of the Site Assessment Information document between 30th January and 13th March. 
 

What is the Sustainability Appraisal of the Greater Norwich Local Plan Gypsy and Traveller Sites and Policies for?

Undertaking a Sustainability Appraisal (SA) is a legal requirement for all plans and programmes such as local plans. The job of the SA is to ensure economic, social, and environmental issues are integrated and addressed at the earliest opportunity. The Greater Norwich councils appointed a company called Lepus Consulting to prepare the SA for the GNLP, and Lepus has done further work to produce the Sustainability Appraisal of the Greater Norwich Local Plan Gypsy and Traveller Sites and Policies. The SA work prepared by Lepus has been used to prepare the Site Assessment Information document as well as informing the policy for each of the proposed Gypsy and Traveller sites.

Respondents can comment on the content of the Sustainability Appraisal of the Greater Norwich Local Plan Gypsy and Traveller Sites and Policies between 30 January and 20 March.  
 

What is the Habitats Regulations Assessment of published Proposed Submission Greater Norwich Local Plan – Gypsy and Traveller Sites Addendum for?

Undertaking a Habitats Regulations Assessment (HRA) is a legal requirement for ensuring the protection of special habitats and species of international importance – such as the River Wensum and The Broads - as well as several others that have designations as a Special Area of Conservation (SAC), Special Areas of Conservation (SPA), SSSIs (Sites of Special Scientific Interest), and wetlands designated under the RAMSAR convention.

The Greater Norwich councils appointed a company called The Landscape Partnership to prepare the HRA for the GNLP, and the Landscape Partnership has done further work to consider the proposed Gypsy and Traveller and produce the Habitats Regulations Assessment of published Proposed Submission Greater Norwich Local Plan – Gypsy and Traveller Sites Addendum.
 

Respondents can comment on the content of the HRA between 30 January and 20 March.

What about Travelling Showpeople and other residential caravans?

This consultation does not include sites for Travelling Showpeople who form a distinct community separate to Gypsies and Travellers. The partnership has signed a Statement of Common Ground with the Eastern Region branch of The Showmen's Guild of Great Britain which sets out how the community’s accommodation needs will be met.

The GNLP does not propose allocation of specific sites for people who live in a caravan but who are not of a Gypsy and Traveller ethnic background. Instead, the partnership is allowing a market-led approach on the basis that residential caravans are a tenure choice, often chosen for reasons of lifestyle.