Evidence base for a Gypsy and Traveller site application

Traveller site planning evidence is assessed against a separate national policy document, and that is the first thing to get right. Planning Policy for Traveller Sites sits alongside the National Planning Policy Framework rather than inside it, and it sets out its own tests on need, supply, location and the weight to be given to personal circumstances. An application prepared as though it were an ordinary rural housing scheme will be answering the wrong questions.

Three items decide most of these applications: whether the occupiers meet the planning definition, whether the authority can demonstrate a deliverable supply of pitches, and whether the site is in a flood zone.

The national policy for traveller sites

Planning Policy for Traveller Sites requires local planning authorities to identify pitch and plot targets from an assessment of need, to identify a supply of deliverable sites for the first five years, and to determine applications in accordance with the development plan unless material considerations indicate otherwise.

The policy also sets out what counts against a site: locations that are unsustainable, isolated sites in the open countryside, sites in the Green Belt, where traveller sites are inappropriate development, and sites that dominate the nearest settled community. And it sets out what counts in favour, including the availability of alternative accommodation, personal circumstances, and the contribution the site makes to meeting an identified need.

The definition of gypsies and travellers for planning purposes was amended in December 2023, following a Court of Appeal ruling that the previous wording discriminated against those who had ceased travelling permanently. Check the current wording of the annex rather than relying on an older copy, because the change matters directly to status evidence.

Set the policy out in the Planning Statement and work through each of its policies in turn. Officers write their reports in that order.

Evidence of status and personal circumstances

Status evidence is the foundation, and it is routinely too thin.

What works is documentary and specific: a statutory declaration or witness statement from each adult occupier setting out their travelling history with dates and destinations, evidence of the economic activity connected with travelling, school records showing periods of travel or traveller-specific education support, health records or letters from a general practitioner where health has caused travelling to cease or reduce, records of previous authorised or tolerated sites occupied, and family connection evidence to the local area.

Personal circumstances then sit alongside status. Where children are on the site, the best interests of the child are a material consideration of substantial weight, and school attendance and any special educational need should be evidenced rather than asserted. Where an occupier is elderly or unwell, a medical letter naming the condition and the practical consequence of having no settled base is more useful than a general statement about wellbeing.

Public sector equality duty considerations under the Equality Act 2010 apply to the authority's decision, since Romany Gypsies and Irish Travellers are recognised as racial groups. Say so in the statement, plainly and once.

Need assessment and the supply position

This is where a well-prepared application wins ground that the site itself cannot.

Get the authority's Gypsy and Traveller Accommodation Assessment and read the arithmetic rather than the conclusion. Check the base date, the definition it applied, whether it was completed before or after the December 2023 change to the planning definition, the pitch requirement it identified, how many pitches have been permitted since, and whether any of the identified sites have actually been delivered.

Then set out the five year supply position as you calculate it, with the assumptions shown. Where the authority cannot demonstrate a deliverable five year supply, that is a material consideration of real weight in favour of the application, and the policy says so.

Two practical points. Sites allocated in a plan but not delivered are not supply in any meaningful sense, and the difference between permissions granted and pitches occupied is worth tabulating. And where the assessment predates the definition change, the identified need is probably understated.

Access, visibility and internal layout

The highway case is ordinary, and it should be presented as such.

Show the access geometry with visibility splays measured to the recorded speed of traffic rather than the speed limit, the internal circulation with tracking for a touring caravan and a tow vehicle, turning provision so that no vehicle reverses onto the highway, parking for each pitch, and the surfacing and gradients. A Transport Statement is usually proportionate for a site of a few pitches.

Internally, the layout is judged on living conditions as much as appearance. Each pitch normally needs space for one static caravan and one touring caravan, parking, an amenity building with a WC, washing facilities and a kitchen area, refuse storage, and private amenity space with adequate separation between pitches for fire spread. Show the separation distances on the layout.

Utility provision has to be real. Water supply, electricity connection, foul drainage and refuse collection each need a stated arrangement, because a site without them is not a site.

Flood risk and the sequential approach

This is the constraint that most often defeats an otherwise arguable application, and it catches people out because the vulnerability classification is counter-intuitive.

Caravans, mobile homes and park homes intended for permanent residential use are classified as highly vulnerable development in the flood risk vulnerability classification in national guidance. Highly vulnerable development is not appropriate in Flood Zone 3, and in Flood Zone 2 it requires the exception test to be passed. A brick house on the same plot would be classified as more vulnerable and treated less strictly, which is why a site that looks developable is not.

So check the flood zone before anything else. Where the site is in Zone 2, a site-specific Flood Risk Assessment with the sequential and exception tests is unavoidable, and the safe access and escape argument for a caravan site needs to deal with the fact that occupiers cannot shelter upstairs.

An illustrative example. A four-pitch proposal on a paddock beside a brook sits with two pitches in Flood Zone 2 and two in Zone 3a on the published mapping. Moving all four pitches onto the Zone 1 part of the field, accepting a longer access track and losing the intended layout, converts an application that would fail on vulnerability into one that turns on need and landscape. The scenario is illustrative and the mapping for any real site should be checked directly.

Foul drainage, water and utilities

Most traveller sites are outside the mains sewer network, so the drainage case needs building properly.

A Foul Sewage Assessment should establish whether a mains connection is available and at what cost, and where it is not, set out the proposed package treatment plant with its capacity, the discharge route, and the consent position under the general binding rules or an environmental permit. Percolation testing to the relevant standard is needed for a drainage field, and the field needs space on the layout with the separation distances from watercourses, boreholes and buildings shown.

Water supply, whether mains or borehole, needs evidence of availability. And where the site is in a nutrient neutrality catchment, the foul discharge brings that requirement with it.

Landscape effects and boundary treatment

Landscape harm is the most common reason for refusal once flood risk and need are dealt with, because caravans, vehicles, hardstanding and utility buildings read as domestic and industrial at once in an open field.

The evidence that helps is a landscape and visual appraisal with viewpoints from public vantage points, a planting scheme using native species appropriate to the character area with a realistic establishment period, and a boundary treatment that is agricultural in character rather than suburban. On sensitive sites a full Landscape and Visual Impact Assessment may be needed, and the approach has much in common with other small-scale rural proposals such as the evidence base for a glamping site.

Be honest about screening. Planting takes years and a scheme that depends on a mature hedge to be acceptable is not acceptable in year one.

Temporary and personal permissions

Where the case on need is strong but the location is problematic, a temporary or personal permission is often the realistic outcome, and it is worth proposing rather than resisting.

A temporary permission suits a situation where the authority is about to allocate sites through a plan review, since it holds the position without prejudicing the plan. A personal permission tied to named occupiers suits a case decided substantially on personal circumstances. Both can be combined with conditions on the number of caravans, the prohibition of commercial activity, external lighting, and the removal of hardstanding on cessation.

One honest uncertainty. Whether personal circumstances outweigh landscape or Green Belt harm is a judgement that varies between decision-makers on similar facts, and appeal decisions are indicative of approach rather than binding. Present the personal case fully and do not rely on it alone.

Browse the full set of PlanScope report types to see which documents a traveller site application is likely to need.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.

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