We wish to highlight the findings of the Office of the Planning Regulator’s Case Study Paper, ‘ Traveller Accommodation and the Local Development Plan’. This paper set out a checklist to ensure that the needs of Travellers are identified and met during the lifespan of the Plan, which should inform the how Traveller accommodation is planned for in the Development Plan:
Checklist for the development plan: Does the development plan…
- Include objectives to ensure that the housing strategy and HNDA prioritise a satisfactory standard of suitable, sustainable accommodation that meet the specific needs of the Travelling Community.
- Include mapping of known and proposed Traveller accommodation.
- Ensure clear linkages between development plans and TAPs to ensure actionable outcomes and adequate funding to implement policy.
- Provide recognition of the cultural requirements of members of the Travelling community in regards to accommodation.
- Prioritise community integration, access to services and supporting cultural infrastructure associated with Traveller culture.
- Reflect from the TAP, fair and effective policies for the management of existing Traveller-specific accommodation subject to demand for accommodation from extended families, taking into account suitability of locations, health and safety considerations and the overall pattern of development in the area.
- Have consistency in terms of the use of language and definitions used by local authorities to describe Traveller accommodation to ensure uniformity.
- Build upon the TAP process and demonstrate that the development plan has been appropriately guided and informed in relation to matters such as site selection and suitability, to enable the provision of adequate facilities and services for Traveller accommodation. The reflection of a properly informed and consultatively developed TAP into statutory development plans will ultimately ensure clear and agreed development plan policies and an effective and robust context for decision making on specific accommodation proposals
Further Recommendations for County Development Plan
National-level planning guidelines for Development Plans set out the relationship between the Traveller Accommodation Programme (TAP), the Housing (Traveller Accommodation) Act, 1998 and the statutory Development Plan. They require that the range and type of housing required and the land use aspects of the TAP are incorporated into the Development Plan. The Guidelines also state that this should take the form of ‘... objectives that clearly set out the approach of the Development Plan in addressing the accommodation needs of the Traveller community and an indication of the specific locations of known Traveller accommodation projects. To support the identification of additional locations for such projects, zoning policies should also be drawn up in a flexible manner to reflect the urgent need to secure additional Traveller accommodation over the lifetime of the plan.' ( Section 4.56 of Development Plans: Planning Guidelines for Planning Authorities, 2007).
Therefore, projects committed to under the 2019-2024 Traveller Accommodation Programme should be listed as objectives in the Development Plan with clear timelines as per the Housing (Traveller Accommodation) Act 1998 PART III (27) (10), and
Sites should be identified and zoning of land for Traveller specific accommodation, including transient accommodation, should be mapped and illustrated in the plan, in line with the Planning and Development Act, (2000) as amended, particularly s10(2)(i). The legislation requires that a Development Plan shall include objectives for: ‘The provision of accommodation for Travellers, and the use of particular areas for that purpose.'
Given the lifespan of the development plan beyond the current Traveller Accommodation Plan, consideration should also be given for how sites will be identified for Traveller Specific Accommodation in the next Traveller Accommodation Programme, including transient sites and how the assessment of preferred accommodation type will be made.
● A system of monitoring and reviewing at regular intervals the provisions outlined in the Development Plans as they relate to Traveller accommodation should be included in the Development Plan. These and the provisions of the current Traveller Accommodation Programme should be reviewed every six months with a presentation on progress to the Local Traveller Accommodation Consultative Committee. The inclusion of an ethnic identifier would improve the quality of data collection and monitoring of provision of accommodation for Travellers.
● Section 94 (2) of the Planning and Development Act, 2000, as amended, sets out that Development Plans should ensure that they counteract undue segregation. With this in mind, sites identified for Traveller specific accommodation should be well located, close to key amenities, and chosen in consultation with the community. Plans should include sufficient green areas and children’s play areas.
● All developments should be carried out with consultation at every stage of the process, with prospective residents, local Traveller organisations and with the Local Traveller Accommodation Consultative Committee.
● The Development Plan should identify Travellers as a priority group in its plans to address homelessness and identify what tangible steps will be taken to reduce the overrepresentation of Travellers in homeless figures. The County Development Plan should also take into account the high level of hidden homelessness, where families are living in chronic overcrowding, or without basic facilities of their own, or security of tenure, with plans to alleviate this clearly outlined.
● The Development Plan should reference the Council’s strategy to implement the relevant recommendations of the recent Irish Human Rights & Equality Commission Equality Review on the provision of Traveller accommodation in the area.
Eliminating Energy Poverty in Traveller Specific Accommodation
Providing clean affordable energy, and energy efficient homes in Traveller specific accommodation.
● A recent study by National Traveller MABS found that Travellers living in mobile homes and trailers experience high levels of energy poverty. The study found that on average, families spend 26% of their income on energy compared with a 4.6% spend in the general population. This study also found that Travellers use a wide variety of fuels to heat their homes while simultaneously experiencing damp, condensation in their homes which gives rise to numerous related health issues. The problem of energy poverty among Travellers arises out of a combination of factors, including the means by which energy is provided as well as the energy efficiency of both the mobile and the day unit/house provided on site. Household income is also a factor in energy poverty.
● In light of this, the Council should plan to review existing Traveller specific accommodation with a view to bringing it up to the current regulatory standards in terms of energy efficiency of the dwellings and in terms of access to sustainable energy sources. It should be ensured that there is access to the competitive energy provision market for Travellers living in Traveller-specific accommodation and that Travellers in Traveller specific accommodation have access to accurate, individual energy bills in order to monitor and control their own energy costs.
● All planned Traveller specific accommodation should seek to ensure that homes built have the highest level of building airtightness combined with effective ventilation systems. In addition, the Council must meet near zero energy building (NZEB) requirements under current regulatory requirements and demonstrate that energy used by the NZEB must be from renewable sources "to a very significant extent", including energy from renewable sources produced on site or nearby. Under current regulations all planned new residential dwellings are expected to be 70% more energy efficient when compared to 2005 performance requirements.