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RTPI Scotland's response to 'Local Development Plan Evidence Report- Defining Gypsies and Travellers' Consultation'

1 a). Scottish Government (Planning and Architecture Division) are considering the following statement to define the Gypsy/Traveller community for planning purposes.

“ For the purposes of section 16B(14) of the Town and Country Planning (Scotland) Act 1997 (evidence report for preparation of local development plan), “Gypsies and Travellers” means-

a) Persons of or from a nomadic habit of life, whatever their race or origin, including-

i. persons who have ceased to travel temporarily or permanently as a result of their own or their family’s (including dependants) educational needs, health needs, or old age,

ii. members of an organised group of travelling show people or circus people (whether or not travelling together as such),

iii. persons who require the provision of land for temporary or permanent living (including the use of caravans as defined in section 16 of the Caravan Sites Act 1968),

b) persons with a cultural tradition of nomadism.”

Do you agree with this statement?


  • Yes

  • No

  • Don’t Know


1 b). If no, what changes would you seek?

Please let us know what changes you would seek:




2. What do you think councils should do to better involve the Gypsy/Traveller community in planning consultations and processes?

Please provide your views:


RTPI Scotland supports the fuller involvement of the Gypsy/Traveller community in the planning consultations and processes. As with many underrepresented and ‘hard to reach’ groups in the planning system tailored approaches may be needed but also reflecting the fact that a one size fits all approach will unlikely be the solution. In order to better support planners in their work the impending publication of guidance relating to community engagement could provide the opportunity to set out best practice. RTPI Scotland notes with interest the research conducted by Planning Aid Scotland on behalf of NHS Scotland looking at the suitability of using the Place Standard tool to assess the quality of Gypsy/Traveller sites[1] offering a number of suggestions at areas for adaption.


Undertaking quality community engagement is costly for planning authorities and moreover targeted engagement for hard to reach groups may have specific additional costs associated with it. In work previously published by RTPI Scotland[2] we estimated costs of the new statutory requirement to produce evidence on Local Development Plan (LDP) engagement with Gypsy/Traveller communities to be as follows:


“Considering that engagement with Gypsy/Traveller communities can pose specific challenges

beyond typical engagement exercises, the estimated cost of £1,000 per workshop has been

increased to £3,000. This would account for venue hire, facilitation, catering, travel and write up,

over multiple days. There are currently 54 Gypsy/Traveller sites across Scotland with an estimated

748 pitches, with an average of 13.9 pitches per site[3]


Using an average occupancy of 2.39 persons per caravan[4] an estimated number of travellers of 1,787 are on registered sites. Organisations that work with Gypsy/Travellers believe Scotland's community comprises 15,000 to20,000 people[5]. This makes an upper estimate of 8368 for the number of pitches across Scotland and 602 sites.


Therefore a maximum estimation, in which every community is consulted would be:

602 x £3000 = £1,806,000


However not all Gypsy/Travellers live on authorised encampments. Therefore, planning authorities

will likely need to reach out to those who may be using unauthorised encampments or settled

housing, as well as those using formal sites.


To calculate a lower estimate one consultation would be carried out per LDP, therefore, the

minimum estimate would be:


34 x £3000 = £102,000”


Additional costs from this statutory requirement need to be considered in the broader context of resourcing issues in planning authorities, with recently published RTPI research[6] showing that:


  • The planning service is the one of the most severely affected of all local government services in terms of budgets with a reduction of 38% since 2010;
  • A quarter of planning department staff have been cut since 2009;
  • Planning application fees do not cover the costs of processing planning applications;
  • The new Planning Act has introduced 49 unfunded duties to local authorities which could cost between £12.1m and £59.1m over 10 years to implement;
  • It is estimated that over the next 10 to 15 years the planning sector will have demand for an additional 680 - 730 entrants into the sector; and
  • The planning workforce has both demographic and succession challenges in the short, medium and long term


Given issues around resourcing, aspirations to better involve the Gypsy/Traveller community in planning consultations and processes need to be grounded in an open and transparent discussion over resourcing requirements. There may be opportunities to bring efficiencies into the consultation process and improve efficacy through more joined-up and collaborative means of engaging Gypsy/Traveller communities across local government departments.


3 a). Do you believe that this (or any) definition will have an impact on businesses?

  • Yes
  • No
  • Don’t Know


3 b). If so, do you imagine this to be positive or negative and why?

  • Positive
  • Negative


Please tell us why:


4 a). Do you believe that this (or any) definition will have an impact on certain groups of protected characteristics?

These are the characteristics protect by law and include:

  • Age
  • Disability
  • Gender Reassignment
  • Marriage and Civil Partnership
  • Pregnancy and Maternity
  • Race
  • Religion and Belief
  • Sex/Gender
  • Sexual Orientation


Please provide your views:

  • Yes
  • No
  • Don’t Know


4 b). If so, do you imagine this to be positive or negative and why?

Please state whether you imagine the impact to be positive or negative and give your reasons:






[3] Scottish Government (2019) Gypsy/Traveller Sites in Scotland. April. Available at:

[4] South Cambridgeshire District Council (2014) Gypsy and Traveller Development Plan Document Frequently Asked Questions. March. Available at:



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