Local Plan - Chapter 5

HOUSING
Chapter 5 (Word 402 kb)

Chapter 5 (PDF 104 kb)

	INTRODUCTION
5.1	Good communications, proximity to London and a relatively prosperous local economy are factors contributing to a high demand for housing in Spelthorne. Additionally, certain parts of the Borough near to the River Thames are particularly attractive and highly sought after. The strict application of Green Belt policy has meant that for a period of over 45 years it has not been possible to fully meet the wider demands for housing.
5.2	A large proportion of the existing housing stock was built between 1930 and 1970, corresponding with the growth in population at that time. The total dwelling stock now amounts to 38,276 (1st April 1998). The social housing element amounts to some 13.8% of all housing in the Borough and is one of the smallest proportions in Surrey. Details of existing stock and ownership at April 1998 are:-

Sector	Number of Units	Percentage

Private	32,999	86.2%
Registered Social Landlords	5,028	13.1%
Other Public	218	0.6%
Spelthorne Borough Council	31	0.1%
TOTAL	38,276

	HOUSING PROVISION IN THE PLAN PERIOD
5.3	Good communications, proximity to London and a relatively prosperous local economy are factors contributing to a high demand for housing in Spelthorne. Additionally, certain parts of the Borough near to the River Thames are particularly attractive and highly sought after. The strict application of Green Belt policy has meant that for a period of over 45 years it has not been possible to fully meet the wider demands for housing.
5.4	The distribution of the total allocation between districts within Surrey was derived having regard to a number of factors which took account of:-
	(a) previous Structure Plan allocations (b) existing commitments (c) provision already made for the post 1991 period (d) the need to avoid town cramming (e) the need to achieve a balance of distribution having regard to the role of greenfield sites and an allowance for larger windfall sites in some districts.
	The availability of land remains the crucial factor and the agreed allocation is based on the principle that the Green Belt defined in local plans will not be altered and that priority will be given to the re-cycling of urban land.
5.5	Within the context of the Structure Plan housing figures, the aim of this Plan on housing is:-
	'To provide additional housing to the extent consistent with Structure Plan requirements and protection of the character of urban areas, and to seek to encourage choice in terms of size, type and tenure by those needing housing in the Borough'.
5.6	In accordance with Policy DP4 of the Structure Plan the housing requirement in Spelthorne for the period 1st April, 1991 - 31st March, 2006 is 2400 dwellings. Of this total 1800 dwellings are to be provided in the period up to 2001 with a further 600 in the period to 2006. Taking account of net completions in the 7 years up to 31st March 1998 the remaining requirement to 31st March 2006 is 998 dwellings.
	POLICY H1
	The Borough Council will ensure that sufficient land is made available within the plan period from 1st April 1998 to 31st March 2006 for 998 dwellings.
5.7	The requirement for 998 dwellings, as set out in Policy H1 above, will be met by a combination of the following:-
	(a) potential of unimplemented planning permissions (b) identification of specific sites without planning permission (c) small and large sites not specifically identified.
	Should circumstances arise whereby the above requirements could not be met within the context of other policies and proposals of the plan alternative options would be considered in a formal review of the plan, but Green Belt land would not be released.
5.8	As all housing land during the Plan period will come from within the urban area, many of the sites are likely to arise as a result of redevelopment, including mixed use schemes. This makes the process of specific identification of sites more difficult. There are particular difficulties in identifying small sites which in this Plan are taken as those less than 0.4 hectares. Sites below 0.4 hectares are not specifically identified for housing in this Plan. However, a detailed analysis of the past performance of small sites has been undertaken and an estimate of future supply, based on annual average completions over seven years (1991-1998), has been made. (Details of these estimates are included in the Council's annual Planning Monitoring Report). Because of the nature of the supply of housing land in the Borough a relatively high proportion of the total provision of housing sites is derived from estimates of completions from sites smaller than 0.4 hectares.
5.9	Past experience has shown that for sites over 0.4 hectares, in addition to specific sites that may be identified, other previously unidentified sites may come forward. The number of completions likely to arise during the Plan period from these larger unidentified sites has been carefully assessed having regard to evidence of such sites coming forward after the base date (March 1989) of the previously adopted Local Plan.
5.10	Having regard to completions of 1402 dwellings between 1st April 1991 and 31st March 1998, existing planning permissions (which it is considered will all be implemented during the Plan period), the estimates of sites of less than 0.4 hectares and above 0.4 hectares, and proposal sites, it is considered the Structure Plan requirement for 2400 dwellings between April 1991 and March 2006 will be met in the following way:

Net completions 1st April, 1991 - 31st March, 1998	=	1402
Outstanding planning permissions on all sites of 0.4 ha and above	=	139
Estimate of sites of less than 0.4 ha	=	416
Estimate of unidentified sites of 0.4 ha and above	=	214
Identified sites without planning permission of0.4 ha and above (shown as proposals in the Plan)	=	229
TOTAL	=	2400

5.11	It is clear, that the high densities achieved on many sites during the 1980's, particularly through one bedroom housing will not be sustained in the future. The Council has incorporated in this Plan, previous non-statutory guidance on infill development which seeks to ensure that 'town cramming' is avoided and that sites are developed at densities appropriate to the character of the area. Further advice is provided in Supplementary Planning Guidance "The Design of New Residential Development and Extensions". The estimates for sites of less than 0.4 hectares therefore allow for lower average densities and also recognise that the number of sites coming forward toward the end of the plan period may well decline. The Council will continue to monitor actual completions during the Plan period to ensure that it will be able to meet its Structure Plan housing allocation to 2006.
	SUMMARY OF HOUSING PROPOSALS
5.12	The specific housing proposals in this Plan are set out in schedule form in Chapter 12 with relevant additional background information. The proposals are summarised below:

Proposal No.	Site	Net New Dwellings (approx.no)
P8	582-604 London Rd, Ashford	30
P9	46-56 Station Crescent, Ashford	18
P10	Council Depot, Commercial Rd, Staines	60
P11	Former Staines West Station Goods Yard, and Timber yard, Wraysbury Rd, Staines	60
P12	Depot 28-44 Feltham Road, Ashford	23
P13	White House Garage, Kingston Rd, Staines	18
P14	Land at Ashford Hospital, Ashford	20
		229

5.13	PPG3 "Housing" requires that a five year supply of housing land be maintained at all times and for there to be a two year supply of land on which development can start straight away. Since 1980 joint studies have been regularly undertaken by the Borough Council, the County Council and the House Builders Federation to assess the availability of housing land in Spelthorne. On each occasion the studies have shown the supply in the Borough overall to be in excess of five years. Where an adequate supply is found but development is otherwise being delayed, local planning authorities are required to consider taking appropriate action which may include expediting planning applications, securing the provision of infrastructure for particular sites, or submitting an order for the compulsory purchase of a site which may be urgently needed either for development or to facilitate the development of other land. Where necessary the Council will use these measures as appropriate, but only in circumstances where a 5 year housing land supply study indicates a significant shortfall in available land to meet the requirement desired from Policy H1.
	POLICY H2 The Borough Council will seek to ensure the provision of housing by encouraging the development of all land appropriate for this purpose, especially sites with outstanding planning permission and those identified as proposals in this Plan, at densities consistent with the character and proper planning of the areas concerned. In circumstances where a 5 year housing land supply study indicates a significant shortfall in available land to meet the requirement derived from Policy H1, the Borough Council will use its enabling powers (which may include compulsory purchase) to bring the development of land forward.
5.14	In order to secure the required addition to the dwelling stock it will be important to resist the loss of dwellings by change of use or redevelopment of sites otherwise suitable for residential use. This is recognised in the Structure Plan (Policy DP7). Exceptions may be made where it is considered that such use is incongruous in a particular setting, where it cannot be occupied separately from attached commercial uses, or where it is otherwise clearly substandard to an extent which cannot be realistically overcome. In many town and local centre areas, however, there is scope for bringing empty and under used floorspace above shops and other commercial premises back into residential use. The Council will through its enabling role therefore seek to bring sites back into housing as well as resisting further losses.
	POLICY H3 The Borough Council will not permit the loss of existing or proposed residential land and buildings, including flats over shops and commercial premises, to alternative uses other than in exceptional circumstances. It will use its enabling powers to encourage the change of use of existing empty and under used floorspace above shops and commercial premises back into residential use, where appropriate, and in accordance with other relevant policies of this Plan the Borough Council will also encourage the change of use of suitable non-residential premises to residential use.
5.15	Within the town and local centres of the Borough there may be sites where for environmental reasons wholly residential development is not appropriate. In such cases non-residential commercial development may be permitted on that part of the site to the extent compatible with the main residential use. Similarly there may be circumstances where, by reason of the existing use value, wholly residential development is not economically viable. In these circumstances non-residential development may be permitted to the extent necessary to ensure the economic viability of the scheme as a whole but again, only in a form consistent with other policies of the Plan. When dealing with proposals for such sites, in addition to the housing Policy H4 which follows, reference should also be made to employment Policy EM6.
	POLICY H4 Where it is demonstrated to the satisfaction of the Borough Council that wholly residential development in town and local centres is not appropriate, proposals combining residential and non-residential uses will be permitted, the extent of each element being decided on the merits of each particular case, but with due regard to the employment and housing policies and proposals of this Plan.
	Paragraphs 5.16 to 5.29c and Policies H5 and H6 which follow are formal ‘alterations’ adopted by the Council in December 2004. There are some gaps in the paragraph number sequence of the altered text to reflect deleted paragraphs. Alphabetic characters are used to reflect additional paragraphs.
	ALTERED POLICIES AND SUPPORTING TEXT
	SIZE AND TYPE OF DWELLINGS REQUIRED (POLICY H5)
5.16	Providing the right mix of housing to meet local needs is an important and material planning consideration. (PPG3 “Housing” refers). Government projections show that nationally much of the growth in the number of households will be in one-person households. Policy DN10 of the Surrey Structure Plan Deposit Draft – December 2002 requires new housing provision to incorporate a mix of dwelling sizes and types to contribute towards meeting the needs of all sections of the community. Target 12 of that plan seeks to encourage the provision of smaller dwellings.
5.17	In November 2001 Spelthorne undertook a Borough-wide Housing Needs Assessment. This showed a significant requirement for one and two bedroom accommodation and which exceeds the proportion of such dwellings in the existing housing stock. In order to ensure that the housing stock of the Borough reflects the need for smaller units, it is important that new building is mainly concentrated in providing small dwellings to ensure a better balance. Encouraging the conversion of larger properties into flats where appropriate will also make a positive contribution.
5.18	The Council consider that the need for smaller dwellings in the Borough would best be met by some 80% of all new housing and conversions providing 1 and 2 bedroom dwellings. Very small infill developments generally provide a disproportionate number of 3 and 4 bedroom dwellings, therefore, on all developments of 3 or more dwellings a minimum of 80% 1 and 2 bedroom dwellings will be required. The Council’s research suggests that about two thirds should be 2 bedroom dwellings. Of the remaining 20% of dwellings the greatest need is for 3 bedroom dwellings because much of the demand in the Borough for 4 bedroom dwellings and larger is met by the extensions to existing properties. It is important that the mix of dwellings in any individual development contributes to the needs identified above. The only exceptions will be where the provision of small units would cause clear harm to the character of an area, the features of which should otherwise be protected, or the requirements for affordable housing dictate a greater mix of larger dwellings.
5.18a	Planning Policy Guidance Note 3 “Housing” requires local planning authorities to avoid development which makes an inefficient use of land ( ie densities of less than 30 dwellings per hectare) and instead encourage housing development which makes a more efficient use of land – between 30 and 50 dwellings per hectare. Authorities are encouraged to seek a greater intensity of development at places with good public transport accessibility. The Council will refuse developments of less than 30 dwellings per hectare unless there are good planning reasons to allow a lower density and generally encourage higher density housing development to ensure an efficient use of land so long as this is consistent with the environmental policies of the Plan.
	POLICY H5 The Borough Council will require the density of proposed housing developments to be at a minimum of 30 dwellings per hectare. Developments that propose 3 or more dwellings, including conversions, will be required to provide, at minimum, 80% of their dwellings as 1 or 2 bedroom dwellings. Developments should be designed to ensure that no material harm results to the character of any area where its features merit protection.
5.18b	When calculating the required 80% provision of Policy H5, the requirement should be rounded down. For example, if the proposed development was for 14 dwellings, the requirement of 80% calculates to 11.2 dwellings and the requirement should be set at 11 dwellings. Further explanation of how Policy H5 applies to affordable housing schemes is set out in the Council’s Supplementary Planning Guidance on Affordable Housing.
	AFFORDABLE HOUSING (POLICY H6)
5.20	Government policy guidance on affordable housing is set out in PPG3 and Circular 6/98 “Planning and Affordable Housing”. It explains that a community’s need for affordable housing is a material planning consideration and that authorities are encouraged to ensure they have up to date assessments of need which are rigorous, make clear the assumption on which they are based and can withstand detailed scrutiny. Where a need is demonstrated authorities should set out in their development plans how many dwellings should be built to meet that need and set out appropriate policies. Policies should seek an element of affordable housing on all suitable development sites as well as seek to bring vacant housing back into use and encourage the conversion of larger houses and other buildings into smaller units. Full and effective use should be made of land within existing urban areas, particularly vacant and derelict land. Account must be taken of criteria in Circular 6/98 on site size, suitability and economics of provision. This expects, an application of affordable housing policy to sites of 25 or more dwellings or of 1 hectare or more in areas such as Spelthorne. Where exceptional local constraints are demonstrated, a lower threshold of 15 or more dwellings or 0.5 hectares irrespective of the number of dwellings may be applied. Policy H6 in the adopted Local Plan – April 2001 had this lower threshold and which was agreed by the Inspector through the Local Plan Inquiry. Where on a particular site provision would be inappropriate, a financial contribution in lieu may be made. It is expected that the future availability of affordable housing provided through the planning process for those in need will be sustained on a permanent basis and it is recognised that the involvement of a registered social landlord is an effective way of achieving this.
5.23a	The Surrey Structure Plan – Deposit Draft – December 2002 requires in its Policy DN 11 that at least 40% of all new housing provision should be affordable, including provision for key workers. It recognises that enabling people to live in a home which is suited to their needs and which they can afford is fundamental to the achievement of sustainable development, the maintenance of the economy and critical to the development of mixed and balanced communities.
5.25	In November 2001 the Council commissioned a joint Housing Needs and Stock Condition Survey by David Couttie Associates (DCA). The survey work and analysis of housing needs were undertaken in line with the then DTLR guidance “Local Housing Needs Assessment: A Guide to Good Practice”. The survey involved 750 face-to-face interviews with households and a postal questionnaire to 8,400 households of which 41.9% were completed and returned. The survey was rigorous, thorough and considered local market house prices and rents, incomes of those in need, the supply and suitability of existing local affordable housing, the size and type of local households, the types of housing best suited to meeting local needs and the existing stock of affordable housing.
5.25a	The cost of housing in Spelthorne is high and the study found that as at November 2001 the average price for flats/maisonettes was £113,617 and terraced property £155,816. These were considered by the consultants to be the “access level” for first time buyers. The average price for a flat would require an income of £35,000 to meet the mortgage costs and an income of £50,000 for a terraced property. Even to rent the smallest flat a minimum rent of £500 a month was required necessitating an income of £25,000.
5.25b	The study used the DTLR’s recommended model to assess the number of units required to meet the needs of those unable to afford “market” property. This included both those already on the joint Spelthorne Housing Register as well as others with a housing need. It identified an annual requirement of 981 affordable dwellings of which some 256 could be met by relets from the existing social housing stock. This still leaves a balance of 725 dwellings required each year to meet unmet need for affordable housing.
5.25c	The Council’s monitoring work suggests that over the remaining 3 years of the Local Plan total housing completions will be in the order of 865 dwellings or 288 per year. It is therefore not possible to fully meet the balance of affordable housing need of 725 per annum solely through new building. The extent of need does make it important that securing affordable housing via planning negotiations is maximised. To meet the Structure Plan requirement of 40% would require some 345 dwellings over the next 3 years or 115 a year. The extent of housing need justifies the continual use of the lower threshold of 15 dwellings or 0.5 hectares irrespective of the number of dwellings which is the lowest permitted in PPG3 “Housing” for urban areas. Over recent years some 58% of all housing in Spelthorne has been built on sites at or above this site size threshold. To meet the Structure Plan target of 40% affordable housing from all house building in the Borough would require some 68% of housing on sites above the threshold to be affordable.
5.25d	Such a high percentage is considered an unrealistic requirement. The Council over recent years has sought to negotiate for 50% of housing on individual development sites above the site size threshold to be affordable, and considers this to be a realistic figure for negotiations, having regard to the extent of need. Whilst this will not of itself deliver the 40% required by Structure Plan policy, the Council intend in addition to continue encouraging affordable housing provision on sites below the threshold, particularly by RSLs and also as a part of mixed used developments in town centre sites.
5.29	Planning permissions will be subject to appropriate agreements to secure the units provided are held in perpetuity for those in housing need. This will not apply to units provided for shared ownership. Affordable housing should be provided on the site subject to the housing proposals. Where the Council and developer both consider that off-site provision is preferable, this should be provided on an alternative site in the area. Such off-site provision must be equivalent to the affordable housing provision that would otherwise have been required on that other site. Only where it is satisfactorily demonstrated that no alternative sites are or can be made available will a financial contribution in lieu of provision be considered. Such provision must then be sufficient to secure the number of affordable housing units that would otherwise have been expected to have been provided on the original site in that locality. The Council has close contacts with registered social landlords operating in the Borough and will be pleased to advise on any matter relating to finance, legal agreement and long-term availability of units.
5.29a	The Council’s objective is to secure, by negotiation, 50% affordable housing in all private housing developments. However, such negotiations need to take into account the size of site, its suitability, the economics of provision including the costs of development, levels of likely public subsidy, cost of bringing sites to the market and competing land uses and ensure that schemes are not only viable but attractive to lenders of finance. There are no urban areas of the Borough where the lack of local services or access to public transport, or other planning objectives, would justify affordable housing not being provided. Where developers suggest a 50% contribution is not viable or reasonable the Council will expect them to demonstrate why affordable housing in accordance with the policy cannot be provided. The Council will encourage the use of ‘open book’ negotiations and will also obtain its own valuation advice to check issues of viability and evidence produced by developers. Where evidence demonstrates a 50% level is not viable, a lower percentage will be considered. If a site is subject to contamination or other impediments, making it more costly to develop, it will expect such costs to be reflected in a lower land value.
5.29b	Where a proposed development site is subdivided or not developed to its full potential so as to be below the site size threshold and affordable housing is not provided, planning permission will be refused.
	POLICY H6 The Council will seek to secure the completion of 345 affordable dwellings (net) in the period 1st April 2003 to 31st March 2006 by new build, or conversion of existing residential and non-residential buildings. This will be achieved by: (a) negotiating for 50% of housing on sites to be affordable where the development comprises 15 or more dwellings or the site is 0.5 hectares or larger irrespective of the number of dwellings; (b) encouraging affordable housing provision on sites below the size threshold referred to in (a) above and in particular schemes undertaken by RSLs; and (c) encouraging affordable housing provision in mixed use schemes on town centre sites where wholly residential development would not otherwise be feasible or appropriate Where affordable housing is provided on any site the Council will seek to ensure that, where appropriate, it is maintained in perpetuity, normally by means of a legal agreement, for the benefit of those groups requiring access to such housing. Where the Council considers a site is suitable for affordable housing and a reasonable provision could be made, planning permission may be refused if an applicant is unwilling to make such provision. A financial contribution in lieu of provision will only be acceptable where on-site provision is not achievable and where equivalent provision cannot be readily provided by the developer on an alternative site. Where, as a means of avoiding the requirement to provide affordable housing, a proposed development site is subdivided so as to be below the site size threshold, or is not developed to its full potential so as to be below the number of dwellings threshold, planning permission will be refused.
5.29c	Further guidance on the way Policy H6 will be applied is set out in the Council’s Supplementary Planning Guidance on Affordable Housing.
	ACCESSIBLE HOUSING
5.30	Within the community there are those who for reason of disabilities and/or movement difficulties need housing which is suitable for their particular circumstances. The Borough Council will, in accordance with Policy H5 and Structure Plan Policy DP2, encourage the house building industry to respond to this local need. More accessible housing will make it easier for disabled people to find suitable housing to live in and make it more likely they will be able to visit their friends houses. It will also benefit those with young families using pushchairs and the increasing number of elderly people who experience movement difficulties. The Council seeks to promote housing suitable for all in their different stages of life, and secondly to increase the stock of dwellings suitable for conversion for occupancy by disabled people. This approach will assist the government's 'Care in the Community' initiatives which seek to allow elderly and disabled people to remain in their own homes. It also accords with government guidance in PPG3 (paragraph 13) and RPG9 (paragraph 8.8) as revised in 2000 and 2001 respectively.
5.31	Much work has been done in recent years to define suitable standards for the design of accessible housing. In 1992 the Access Committee for England launched its "Criteria for Accessible General Housing". In April 1993 the Access Committee together with the Royal Town Planning Institute published "Access Policies for Local Plans" which included two detailed housing policies. More recently, "Lifetime Homes" has been published by the Joseph Rowntree Foundation and the lifetime homes criteria is receiving increasing recognition. The Council is very supportive of these initiatives.
5.32	In the context of Policy H7 which follows, the Borough Council will encourage applicants to meet the needs of people with disabilities, by seeking the following features for all new houses with a ground floor living room or those accessible by lifts:
	(a) level or gently sloping approaches (b) easy access to parking space (c) lifts to upper storey flats to be wheelchair accessible (d) level thresholds through entrance doors (as required by Part M of the Building Regulations 1991) (e) sufficient door-widths and circulation space in the hall to allow easy passage for disabled people (f) an entrance level accessible toilet
	5.33.The above approach seeks to ensure the provision of most new housing to a 'visitable' standard for wheelchair users. In addition, the Borough Council will encourage a 10% provision of all new housing to be suitable for conversion for occupancy by disabled people, in order to meet local need. Since half the total new housing provision in Spelthorne within the Plan period is forecast to be from small sites, in order to achieve this 10% provision overall the Council will look for the provision of 20% of units on housing sites of 15 or more dwellings, to be potentially suitable for disabled persons occupancy. In addition to features (a) to (f) set out above, the following additional criteria will be sought for these units: (g) a staircase suitable for installing a platform or chair lift, or reserved space for the installation of a through-floor lift. Where there is already an entrance level living room, bedroom and accessible bathroom proposed, this will not apply.
	POLICY H7 In considering applications for residential development, the Borough Council will encourage applicants to provide housing to meet the needs of people with disabilities, both as occupants and visitors.
	SHELTERED HOUSING
5.34	During the Plan period the number of elderly persons will increase significantly and they may require sheltered accommodation. The Borough Council has undertaken a number of schemes in recent years but recent policy changes toward the care of elderly people, such as community alarm schemes, have affected the demand for such accommodation. However, where it can be demonstrated that there is a demand for private sheltered housing schemes, the Council will support such proposals on sites suitable for housing. The contribution of private nursing homes for elderly people and other types of residential homes is referred to in Policy SC6 in Chapter 10.
	POLICY H8 The Borough Council will encourage the provision of sheltered housing to meet the full range of needs of elderly people on suitable sites where such development is consistent with the other policies of this Plan.
	MOBILE HOMES
5.35	There are a number of sites within the Borough which are used for mobile homes on a permanent basis. Such sites widen the range of housing available and to a limited extent provide a form of affordable housing. For this reason it is desirable to retain the existing sites in their current use. Nevertheless, in view of the particular demands for housing in the Borough and the need to make the best use of urban land (because the option of using Green Belt land has been precluded) permanent traditional housing is preferred. For this reason it will be necessary to demonstrate the particular reasons why planning permission for new sites for mobile homes should be granted. As with all proposals for development, schemes must be compatible with the character of the area in which they are situated and there must be no significant adverse impact on the highway network created by the access arrangements. Consistent with the advice of DOE Circular 12/78 "Report of the Mobile Homes Review" any permission granted will be on a permanent basis.
	POLICY H9 Planning permission for mobile homes or residential caravans will only be permitted: (a) in areas suitable for residential development (b) where the opportunity for an appropriate higher density of development by traditional housing is not prejudiced (c) the proposal is compatible with the character of the area (d) there is no significant adverse impact on the highway network (e) there is no conflict with the other policies of this Plan.
	GYPSIES
5.36	National planning guidance on the planning aspects of sites for caravans which provide accommodation for gypsies is set out in Circular 1/94 "Gypsy Sites and Planning". There are currently gypsy caravan sites at Littleton Lane, Shepperton and Leylands Lane, Stanwell Moor. From the information currently available it is considered that there is adequate provision within the Borough and it is not therefore proposed to identify further sites in the Plan. The Borough Council will however keep the situation under review and will liaise with representative bodies or local groups on appropriate accommodation needs. The Council will welcome applications from gypsies to provide additional accommodation on suitable sites in accordance with identified and proven needs, but locations within the Green Belt will not be considered appropriate for such development. In addition the criteria set in Policy H10 below will be applied.
	POLICY H10 The Borough Council will, in liaison with gypsy representative bodies, keep under review the general provision of gypsy sites within the Borough. The Borough Council will expect a proposal for a gypsy site to demonstrate that:- (a) the development is not in the Green Belt and it will not have an adverse impact on the environment or adjoining uses (b) appropriate standards of amenity and working space are included (c) adequate landscaping and boundary fencing is provided (d) suitable highway access arrangements and adequate on-site parking are provided.
	TRAVELLING SHOWPEOPLE
5.37	Travelling showpeople who tour the Country during summer months require permanent accommodation for residential purposes and storage of vehicles and equipment primarily in the winter. Circular 22/91 "Travelling Showpeople" gives advice to local planning authorities about planning considerations to be taken into account in relation to travelling show people. There are already two permanent sites in the Borough at Poplar Road, Ashford and Grays Lane, Ashford. These are considered adequate to meet current requirements. The Borough Council will however, in consultation with the Showman's Guild of Great Britain, keep under review the need for further accommodation in the Borough. Sites within the Green Belt will not be considered appropriate for such use and in addition the criteria set out in Policy H11 below will be applied.
	POLICY H11 The Borough Council will seek to safeguard its two existing sites for travelling showpeople from alternative uses and will normally permit additional sites where a need has been identified provided:- (a) the development is not in the Green Belt and would not have an adverse impact on adjoining properties (b) the site has safe and convenient access to the highway network (c) the development would not be visually intrusive or detrimental to the appearance or character of the area.