NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.


Key objective of NPF4: To ensure that the current and future accommodation needs of Gypsy/Travellers are met so that they are provided with access to good quality, safe and appropriately located sites.

A relatively small number of respondents commented on Gypsy/Traveller accommodation. There was support for the proposed key objective of ensuring that current and future accommodation needs of Gypsy/Travellers are met so that they are provided with access to good quality, safe and appropriately located sites. It was reported that Gypsy/Travellers in Scotland experience low health outcomes which are often related to the siting and quality of the places where they live, and that they experience systemic barriers to engaging with planning.

It was suggested NPF4 should address this matter as a National Priority while also recognising the proactive work done by some local authorities to address these issues. One view was that the new framework should facilitate the creation of Gypsy/Traveller negotiated stopping sites and transit sites in every local authority area as a minimum. It was suggested that the framework should reference the work of PAS around Gypsy/Traveller communities.

However, a small number of local authority respondents reported there has been very limited or no demand in their area previously, and no recent evidence to support the provision of permanent sites. Further comments included that

  • They will continue to support Gypsies/Travellers on an ad hoc basis as any requests arise, being fully aware of the human rights and associated equalities issues.
  • Travelling Showpeople visit the Islands infrequently and visits are pre-arranged and of short duration, allowing appropriate ground to be designated as temporary show sites in line with local planning policy.
  • Any approach should be evidence based and allow a flexible policy approach which recognises that a site-based response may not be appropriate.

Other respondents also commented on the need to take an evidence-based approach, with comments including:

  • As recognised in the Early Engagement Policy Paper it has become clear that since 2014 the recording of the Gypsy/Traveller population has been inaccurate and that measurements appear to have underestimated the level of demand. Therefore, whilst the requirement may be clear, a lack of reporting of demand is a likely reason why there has been little delivery in providing new accommodation.
  • It will be important to identify those who have experienced challenges related to previous planning policy, such as Gypsy/Travellers, and to take steps to ensure that NPF4 meets their needs.
  • Consideration needs to be given to whether the current HNDA approach is fit for purpose in identifying the housing needs of Gypsy/Travellers across Scotland. A national co-ordinated approach within NPF4 to build an evidence base to understand travel patterns and the need for site provision across the country would be the most appropriate approach to meeting the needs of these communities. The nature of Gypsy/Traveller demand means that more investigative, qualitative and empirical methods are required. This work may therefore be more appropriate at a national level with collaboration with regional and local stakeholders.
  • Mapping could be used to ensure the identification of public sites that would meet the need of the Gypsy/Traveller community. It should allow for the identification of privately owned sites that would meet needs, even if these are in unexpected locations.
  • Mapping transit routes would be positive and would be useful information for the preparation of RSSs and LDPs. However, this would only help to ascertain demand for transit sites and the NPF should be more explicit in setting out the different types of Gypsy/Traveller demand, and subsequently the different types of provision and solutions that will be required to meet that demand.

It was noted that there are existing sources of information setting out standards and guidance, such as the guides provided by PAS and the policy work by COSLA, that local authorities have been able to feed into the preparation of LDP policy. However, it was reported that applications are still regularly being refused. It was suggested that while the formalisation of criteria through NPF4 will be helpful in setting out clear requirements and, perhaps more importantly, providing status, awareness raising and 'myth-busting' will also be required to ensure that the proposed objective is achieved.

Other suggestions included that:

  • Planning legislation already requires that LDPs address any identified need and it was suggested that NPF4 need only adopt this as a requirement to be shown in LDPs.
  • The PSED, specific duties, 'Fairer Scotland' duty and a participative approach should inform consideration of Scottish Gypsy Traveller sites in LDPs.
  • NPF4 should include guidance on the requirement for Gypsy/Traveller sites, based on available evidence of which planning authorities can make use.
  • Guidance must be informed by the Gypsy/Traveller community themselves. It must be flexible enough to take into account different needs and beliefs of different families and communities.
  • It may be best that guidance provides matters to consider rather than a set of criteria.
  • To accommodate any emerging need, NPF4 should include criteria to support proposals that come forward.

With regard to site identification and/or acquiring permissions, comments and suggestions included that:

  • Not all local authorities own sufficient land or land in the right places that can be used for public sites. NPF4 should account for LDPs that are unable to identify sufficient appropriate sites.
  • With a shortage of sites across Scotland it would be inappropriate to not allow for windfall sites. Policy criteria for these sites is essential to guide applicants when making applications and ensure pertinent matters are taken into account in planning decisions and help limit consideration of non-material matters.
  • Small sites (which should be defined) would still benefit from guidance to make the planning process straightforward for both applicants and decision-makers. Smaller site requirements should be proportionate to the scale of the site.
  • A criterion set at a national level could provide clarity to the Gypsy/Traveller community who require sites across multiple planning authority areas and would benefit from greater consistency in policy advice.
  • With regard to transit sites without planning permission and a licence, the planning system restricts the time and number of caravans on a site, regardless of how suitable it is. A change in regulation or legislation such as through permitted development rights would be required to make this easier.
  • It should be recognised that resources are required for acquisition and setting up of sites as well as for the consultation involved in assessing need and identifying the most appropriate sites.

There were also suggestions relating specifically to privately owned sites, including that:

  • There should not be an assumption that all need can and will be met through public sites. There needs to be a flexibility to have a policy criterion for privately owned sites to make up the shortfall.
  • Privately owned sites should not have to prove need as they are set up by the Gypsy/Traveller community and therefore control over issues such as operating times during the year may be unreasonable. However, this should apply only to sites set up by the Gypsy/Traveller community rather than a landowner looking to set up a site for a permanent residential caravan park.

Finally, there was specific reference to the issues Scottish Travelling Showpeople have faced over the last 30 or so years regarding forced relocations and the segmentation of Showmen's Yards in areas of multiple deprivation. It was reported that many Showmen's Yards are routinely denied permanent planning status despite the vast majority of Showpeople residing in permanent sites. Suggestions included working with the Scottish Showmen's Guild and other members of the community, including around:

  • Introducing special provisions for 'buffer' zones: This would be special planning status where Showpeople could own yards which straddle residential and business use.
  • The sale of individual plots and community owned sites.



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