Guidance for undertaking Gypsy and Traveller accommodation assessments - Chapter 2: carrying out the assessment

It is essential the assessment process has credibility and acceptance within the Gypsy and Traveller community. If not, it may be difficult to engage community members, which will undermine the accuracy of the survey. It is recommended that local authorities secure the involvement of Gypsy and Traveller communities at the initial planning stage of the GTAA process, who will be able to ensure the procedure to be followed reflects their diverse backgrounds and needs.

The local authority is responsible for deciding who should lead the GTAA process. This would normally be a local authority department, either Housing or Planning. Whoever is appointed should ensure the Housing and Planning departments work closely together, have suitable seniority to take ownership of the outcome, and ensure that due regard is had to the relevant Welsh Government Gypsy and Traveller guidance documents across the local authority.

Local authorities have the flexibility to decide to undertake individual GTAAs or regional GTAAs. While the responsibility to carry out the GTAA rests with individual local authorities, who must identify all outstanding accommodation needs for their own area, it may be possible to work in partnership with other authorities when deciding how best to meet those needs. The potential benefits of such an approach may be particularly relevant in relation to the Gypsy and Traveller community because of their mobility and travelling patterns, which are liable to cross local authority boundaries, and which in particular must be understood if appropriate transit provision is to be made. Working in regional partnerships may ultimately save costs and improve the data source and delivery of adequate accommodation.

Partnership working must aim to deliver:

• a better engagement with Gypsy and Traveller communities
• a better understanding of the accommodation need across the administrative boundaries
• a better understanding of travelling patterns to help inform the need for transit provision
• a common approach and consistency across the partnership area
• economies of scale
• reduced risks of double counting
• opportunities to work together to devise a concerted and strategic approach to Gypsy and Traveller mobile home site shortages

If local authorities wish to produce regional GTAAs, early discussions must take place with other local authorities in the region to identify the scope for partnership working. Welsh Government should also be informed. Any delays in the process of undertaking a regional GTAA will put local authorities at risk of breaching their statutory duty to submit the GTAA to Welsh Ministers within specified time limits in the 2014 Act. Therefore, early agreement of the process for commissioning joint GTAAs is essential in any regional partnership.

When assessing which local authority areas may wish to cooperate to understand regional needs, local authorities should consider the knowledge and experience of their officers and any views from members of the local Gypsy and Traveller communities. The area to be covered will largely depend on typical travel and movement patterns within the region or where existing sites are situated close to administrative boundaries. Community members should be able to explain the wider areas they consider to be relevant to authorities. The involvement of individuals from Gypsy and Traveller communities at an early stage in these discussions is vital to inform the partnership area and should produce the most effective results.

It is essential the data arising from jointly conducted assessments remains capable of disaggregation to each individual local authority level, to ensure each partner retains ownership of and accountability for their own information base. Individual authorities may need to produce their own stand-alone information if required, say in circumstances involving Development Plan hearings, a planning inquiry or appeal specific to the situation within each individual local authority.

Where national park authorities exist within the local authority area, the data must be capable of disaggregation within and outside the national park authority boundary. This is because the national park authorities are also required to produce Development Plans and the GTAA will provide evidence to underpin each plan.

Appointing a steering group for the GTAA will help to ensure the process is informed by all available expertise to produce the most effective assessment possible. It is important key stakeholders are aware of the appointment of the steering group and given the opportunity to be involved at an early stage. The group should include those who have established networks within Gypsy and Traveller communities and who hold accountability for meeting their accommodation needs. These may include representatives from:

• local authority Housing and Planning departments
• local Gypsy and Traveller community members
• organisations working to support Gypsy and Traveller communities, Annex 2
• other relevant services such as Traveller education services, Gypsy and Traveller liaison officers or health board officers who work closely with Gypsy and Traveller communities and who may have knowledge of communities in the area
• local authority councillors, for example, the Equality or Planning portfolio holder

It is also recommended, where practicable, to include a person with detailed knowledge of the assessment processes and outcomes in adjoining local authority areas.

The involvement of members of the local Gypsy and Traveller communities is a critical part of the steering group composition and should not be overlooked or delayed. Their contribution is key to help counter any perception that the assessment is being done ‘to’ Gypsy and Traveller communities, rather than ‘with’ them. Their involvement may also provide a crucial perspective on the travelling patterns of communities and the need (or otherwise) to work on a regional basis. They will also assist with ensuring the needs of the entirety of the Gypsy and Traveller community are included in the GTAA. It will also strengthen opportunities for the study to be well publicised amongst community members and explore the best way of engaging community members to gather the required information.

It should be noted that where any Gypsy and Traveller community members do not want to engage with the GTAA process, or they are not comfortable in talking to the local authority, it should not be presumed that they have no need for pitches. If this is the case, the steering group must consider other methods to capture their housing need. This could include use of Gypsy or Traveller stakeholder organisations or liaising with other community members who may be able to facilitate participation in the GTAA process on their behalf.

When inviting community members to participate in the steering group, community members themselves should be given an opportunity to nominate their chosen individuals. Organisations who work closely with these communities could also nominate those who they believe would be able to support the steering group’s aims. Although the views of individual community members may not be representative of everyone, they may offer a different perspective as members of the community whose accommodation needs are being assessed.

Community members may also be able to provide some advice on the appropriateness of proposed engagement techniques and likely questions from the community. Gypsy and Traveller representation on the steering group is likely to form a minority in terms of numbers. However, the local authority must ensure their views are given due weight as they are likely to be best placed to advise on the needs of their own communities.

The steering group will need to fulfil a range of responsibilities, including:

• recommending the geographical survey area
• designing the study aims and outcomes
• appointing researchers (in-house or external)
• publicising the study to stakeholders
• providing local knowledge to the researchers
• providing feedback to consultation participants and stakeholders
• overseeing a robust GTAA assessment of needs and plans to address needs

Once the extent of the survey area and any collaboration with other local authorities has been decided, the steering group will need to identify the aims and outcomes for the GTAA. Key outcomes must align with delivery of the local authority’s duties under Part 3 of the 2014 Act, including establishing a clear understanding of the accommodation needs of Gypsies and Travellers and an accurate assessment of the number of mobile home pitches which have been identified as required within the area. Key outcomes should also include a plan to address that need.

The local authority are advised to use the Welsh Government questionnaire at Annex 3 to ensure key data is identified and analysed. However, the steering group may wish to consider adding additional questions to the questionnaire to capture any locally specific data and to achieve any other outcomes which may be required for any particular area. It is recommended any longer questionnaire is piloted with community members to ensure the length of the interview does not adversely affect participation.

Establishing clear outcomes will support the steering group in appointing researchers to undertake the evidence gathering and data analysis sections of the accommodation assessment. The appointed researchers can be in-house staff or external consultants.

Once the survey area and aims have been decided, including plans to how feedback will be given to those involved, researchers will need to be appointed to conduct the accommodation assessment study. Options include the use of:

• in-house staff: ideally from within the Gypsy and Traveller section or the housing department of the local authority
• specialist consultants, ideally with lived experiences

In reaching a decision on who will carry out the survey, local authorities will need to consider:

• the capacity and expertise of in-house staff
• the qualifications and track record of consultants, including evidence interviewers have undertaken cultural awareness training
• how effective each option might be in reaching the target group (e.g. previous relationship with Gypsy and Traveller communities or whether working with Gypsies and Travellers themselves may be useful to obtain better access to the community and secure the trust of those being assessed)
• the ability to analyse primary and secondary data to assess accommodation needs
• the robustness of the process, which will be vital for securing acceptance of the results
• the credibility of each option with both Gypsies and Travellers and the settled community
• resources and costs

Local authorities should be mindful that where researchers already have personal knowledge of the target communities, some community members may be hesitant to divulge personal and private information to them.

Each of these factors are important considerations when assessing commissioning options. Local authorities should consider making use of organisations and individuals who are trusted by the local Gypsy and Traveller communities as this is likely to yield a higher rate of participation and more engaged responses to the questionnaire. It may be possible to contract a trusted organisation to undertake the survey interviews, whilst maintaining local authority responsibility for analysing the survey responses.

The steering group must ensure those appointed to carry out the survey have both sufficient knowledge of the local Gypsy and Traveller community and suitable research skills to address the aims and objectives of the GTAA.

It is also essential that those carrying out the survey possess the research skills required to develop, administer and analyse the data received under the survey.

After identifying who will be carrying out the survey, the steering group should focus on providing support to the appointed researchers. It is recommended they utilise their networks within relevant local authority departments and Gypsy and Traveller communities to ensure the GTAA and survey is well publicised and that all interested community members know how they can participate.

The steering group may also provide relevant local knowledge where appropriate to those carrying out the survey, including a list of key contacts to assist them in producing a comprehensive study in a sensitive and engaging way that reflects the specific nuances of the communities they are working with. As part of this local authorities will need to consider and comply with data protection legislation and any restrictions on sharing data. Data security requirements should be always followed by both the local authority and the appointed researchers, with all personal data received in connection with the survey being processed and stored lawfully.

After the survey has been completed and submitted to the steering group, they should ensure feedback is provided to all participants and stakeholders (in compliance with data protection restrictions). Without accessible feedback, the participation of community members risks being viewed as tokenistic rather than meaningful, as individuals are not able to see how their involvement has influenced local policy. Worse still, a lack of feedback can be counterproductive as the same individuals may decline to participate in subsequent consultation processes because of a perception that “nothing ever changes.

Local authorities need to be aware the level of direct engagement with the Gypsy and Traveller community and the robustness of the analysis of the survey results will be scrutinised by Welsh Ministers as part of the assessment approval process.

A properly conducted assessment process and a clear plan to address the identified needs will help to ensure the local authority’s actions and to implement the assessment are as robust as possible.

As GTAAs may be considered during the planning process, it is important for local authorities to ensure the GTAA process is comprehensive, fair and transparent, ensuring the data reflects diverse backgrounds and needs. Local authorities should also be mindful that their approved assessments will be relied on as evidence to support and be incorporated within the Local Development Plan.

Key stakeholders, including third sector organisations, should already be included in the GTAA process as part of the project steering group. Nevertheless, wider consultation on the design and conduct of the assessment should also be undertaken with local agencies and the local Gypsy and Traveller communities. This process will involve mapping the local Gypsy and Traveller communities to ensure the researchers engage as many members as possible. It will also require testing of the survey methodology, including proposals regarding who will attend to ask questions, when interviews will be scheduled to take place, the appropriateness of questions, and the most effective phrasing to support maximum understanding and participation. The recommended GTAA questionnaire can be found at Annex 3.

It is crucial the purpose of the work is fully explained to the Gypsy and Traveller communities before the survey begins. Local authorities should allocate sufficient time to clearly explain what the GTAA is, set out each stage of the assessment process, and detail how the information collected will be used, ensuring accessible language to help all community members understand what will happen and when.

The intention is to help to secure support and buy-in for the process. The purpose of the data gathering must be made clear and it should be emphasised any data provided will be used only for the purposes of assessing and meeting accommodation needs. Where households seek to move between local authority boundaries, individuals should be asked to consent for their data to be shared for the specific purpose of discussing their accommodation needs with other authorities, as appropriate.

Local authorities will need to issue all those who provide personal data as part of the GTAA with a privacy notice outlining how their data will be held and processed and what their information rights are under data protection legislation.

It should also be made clear that while the information provided by individuals will be properly considered before any decisions are made on the need for site provision, the local authority is unable to commit to meet any specific requests which may be made as part of the survey, for example, a request for a new site at a particular location.

It is important stakeholders are regularly informed of the progress and outcome of the assessment. This feedback will ensure community members understand how their views have been considered and will add accountability to the process.

The GTAA methodology and testing process should comprise of 4 main components:

1. An analysis of existing data sources.
2. Conducting a specialist survey.
3. Assessing accommodation needs.
4. Developing a plan to address the need.

Some relevant information may already be held by local authorities or other agencies, and whilst this can be used to inform the assessment, given the small population size, care will need to be taken to ensure no individuals are identified or identifiable.

Secondary data sources

Local authorities may wish to access some of the following secondary data sources, where they are considered to be sufficiently reliable and up to date:

Census 2021:

• This data has been disaggregated to the local authority level by the Office for National Statistics. Some data is also available to show how many households live in each area and in which type of accommodation.

Housing records:

• In areas with local authority sites, information should be available from site management records. These may provide useful information regarding pitch turnover, pitch waiting lists and pitch assignment applications.
• Registered Social Landlords may also have data relating to Gypsy and Traveller residents or those on waiting lists.
• Supporting People may have access to information which may help to identify community members to be interviewed.
• As with other local authority housing records and waiting lists, this data may be out of date or incomplete and the households recorded may not be representative of the Gypsy and Traveller community.

Local authority planning records:

• Information relating to private sites will be available to the Local Planning Authority through the planning application process. This should include the number of caravans/pitches permitted on each site, whether the planning permission was granted on a permanent or temporary basis, and whether it restricted occupancy to named individuals.
• Local authorities should also have data on private sites without planning permission in their area, including the number of caravans or pitches on each site and details of any planning applications, appeals and/or enforcement action over the previous 5 years.

Again, some of this data may be out of date or incomplete. Nevertheless, it can be used with other information as a starting point to identify community members and help indicate the adequacy of current site provision and the extent of need for additional sites. Any use and interpretation of these figures should clearly note any limitations of the data.

An up-to-date and accurate GTAA may be useful evidence to demonstrate that there is an identified need for additional mobile home sites within a local authority area.

Caravan count:

• The caravan count will include the number of caravans on all types of sites: including local authority sites, unauthorised encampments, temporary/ negotiated stopping places and private sites with/without planning permission. The count, however, does not provide information on any additional household needs.
• In addition, it does not include any Gypsy or Travellers who are living in bricks and mortar and who wish to move to a mobile home site.

Again, whilst this data has limitations, it can help to provide a starting point for mapping these communities.

Traveller education records:

• Local authorities may, subject to data protection requirements, also have access to additional sources of data regarding local Gypsy and Traveller populations from their service providers, such as the health service or the Traveller Education Service (TES). The TES may have information on Gypsy and Traveller pupil numbers via the Pupil Level Annual School Census (PLASC) and other records. This data may record a higher level of Gypsy and Traveller population than the Census 2021.

Liaison officers / support organisations:

• Gypsy and Traveller Liaison Officers or organisations supporting these communities may well have much more detailed personal knowledge of the community, and local authorities or partnerships should where practicable draw on this when designing and carrying out their assessment (Annex 2)

Unauthorised encampment initial and welfare checks:

• Local authorities may also use information obtained when carrying out welfare checks on unauthorised encampments to help understand the need for permanent, transit or temporary/negotiated stopping places within their area and any preferred locations for these.

Departments with regular contact with Gypsies and Travellers should consider obtaining consent for any data they collect to be shared with other local authority departments for the purposes of accommodation assessments. As with all personal data, any processing will need to comply with the data protection legislation relating to the access and use of personal data.

There is likely to be relatively little secondary data available recording the number of Gypsies and Travellers living in bricks and mortar. Local housing records are unlikely to identify who or where they are. Ethnic monitoring categories often do not identify Gypsies and Travellers separately, and where they do, Gypsies and Travellers in settled housing may be reluctant to identify themselves as such as part of any census.

Local authority housing waiting lists may not fully reflect the accommodation needs of the Gypsy and Traveller community, particularly as many Gypsies and Travellers may not be looking for bricks and mortar housing. Useful data may be available if local authorities operate waiting lists which allow households to specify a need for mobile home pitches. If local authorities do not currently operate such waiting lists, they are recommended to start doing so (see the engagement checklist).

The records held by other service providers may also be incomplete, as they will record only those accessing the relevant services. The Race Equality Foundation / Zoe Matthews, The Health of Gypsies and Travellers in the UK (2008) gives further information about this.

Relying on existing secondary data alone will not therefore be sufficient when carrying out a GTAA. As such, assessments produced utilising only existing data are highly unlikely to be comprehensive or detailed enough for approval by Welsh Ministers. This data will give only approximations of need and will not provide the specific and up-to-date information required to undertake a robust and accurate GTAA.

The GTAA survey is conducted to collect data on the current and future accommodation requirements of Gypsy and Traveller communities. Based on this data, local authorities are expected to formulate actionable plans to ensure that these needs are met effectively. This approach ensures that the accommodation needs identified in the GTAA survey are translated into practical solutions and provisions. A GTAA is not just about identifying the accommodation needs of the community. It is intended to be a comprehensive process aimed at developing a strategic plan to address these needs.

To achieve the most accurate data and supported conclusions, local authorities or partnerships will need to undertake a census-like complete population coverage of GTAA survey responses, where reasonable attempts are made to contact and receive a response from all Gypsy and Traveller households in a local authority and a response or refusal-to-respond reason is recorded for each.

It is crucial those undertaking the assessment endeavour to contact all known Gypsies and Travellers residing in or resorting to the area to ensure the assessment is seen as legitimate by all participants and provides the most accurate assessment of unmet need.

When designing the survey, local authorities must consider how they can identify Gypsy and Traveller communities living in various types of accommodation.

Those undertaking surveys should aim to interview at least one representative from each household and avoid relying on a single response from only one person from each site. This will help ensure the information obtained is more representative of individual needs and that one person does not become a gatekeeper for the whole community or inadvertently misrepresent the accommodation needs of others. Relying solely on views conveyed by a single interviewee on behalf of an entire site is unlikely to properly represent the distinct voices of the whole community.

Local authorities will have quality data of Gypsies and Travellers on existing local authority sites. It is important the accommodation needs of concealed (or ‘doubled up’) households sharing local authority pitches are recorded and considered. The needs of the concealed household must be assessed separately to the needs of households who are agreed tenants of the pitch.

Local authorities are less likely to have complete knowledge of community members living in bricks and mortar housing. Some local authorities may have established Gypsy and Traveller specific pitch waiting lists or may record ethnicity on their wider social housing waiting lists. However, even this data is likely to be incomplete. Authorities should work with specialist professionals (such as Traveller Education Services, specialist health visitors or Gypsy and Traveller liaison officers) and community support organisations, Annex 2, where applicable, to better identify and involve these community members in their assessments.

Gypsies and Travellers on unauthorised encampments or private sites without planning permission also need to be identified, for example, via the Caravan Count or through monitoring undertaken by the local authority, or by proceedings relating to possession.

Some residing or resorting on unauthorised encampments may be well known to the local authority, whereas others may be less well known and less easy to identify. It will be especially important to explain to any unauthorised occupiers the GTAA survey seeks to understand the need for both residential and transit pitches.

Even where occupiers of unauthorised encampments have declined to participate in the survey, the reason for their encampment should have already been recorded through the unauthorised encampment log component of the Caravan Count and can be included in the GTAA through the analysis of existing data sources. Undertaking ongoing conversations about the need for permanent or transit provision within unauthorised encampment processes is important to capture the needs of community members who may not be resident in the local authority during the period of GTAA work.

Achieving responses from occupiers of private sites without planning permission may well be very difficult. This is because occupiers may suspect information is being collected to take enforcement action against the site, rather than to genuinely understand their needs. To help address this issue, it would be beneficial for local authorities to provide clear reassurance of their intentions and to stress this is not the purpose of the survey. Gypsy and Traveller members of the steering group are likely to know where unauthorised encampments exist within the area and may have some useful suggestions for how best to engage these households.

Researchers must maintain a log of appointments and interviews with community members to evidence the consultation undertaken. If unsuccessful on a first attempt, researchers should attempt to engage with households on at least 2 other occasions. They should record the date and time of each attempt on the interview log and the approach taken to try to engage the household (e.g. advance notice of appointment, unannounced visit, introduction by trusted intermediary etc).

The example interview log is at Annex 4. Local authorities may decide to amend the interview log template for use in their area. However, any personal data which may identify any individual must be removed from the version which is submitted to the Welsh Government.

Local authorities or appointed researchers must always seek to engage as many households as possible in the specialist survey.

Local authorities must be able demonstrate they have sought to reach as many households as possible through the GTAA process, the ‘engagement checklist’ below can help do this. Welsh Ministers will specifically examine engagement levels when assessing whether to approve any submitted GTAA.

1. Include Gypsies and Travellers on the GTAA project steering group. Reimbursing community members for their time can support their participation in the GTAA process and help ensure accurate and representative survey outcomes.
2. Visit every Gypsy and Traveller household identified through the data analysis process a minimum of 3 times, if necessary. Visits should be made at different times of the day to ensure the most likely opportunity to fit around work or caring responsibilities. This may involve visiting a household to agree a convenient time to revisit.
3. Publish details of the GTAA process, including contact details, to allow community members to request an interview, for example, on the local authority website, Travellers’ Times website and World’s Fair publication. Post details in a central place in local authority sites and in any relevant community centres etc.
4. Consult relevant community support organisations, such as those in Annex 2
5. If it is not possible to engage directly with community members on a site, local authorities may consider working through a trusted contact on the site to support and facilitate effective communication with all residents.
6. Develop a local authority waiting list for both pitches and bricks and mortar housing, which is made known to community members.
7. Ensure contact details of any other community members which may be provided to the local authority through the survey process are followed up and that their needs are also assessed.
8. To increase visibility and participation, consider holding on-site (or nearby) GTAA information community events to explain why community members should participate and encourage site residents to bring others who may not be known to the local authority.

Even where local Gypsy and Traveller communities have been fully identified, persuading everyone to undertake the accommodation assessment survey may not be straightforward. There may be a reluctance to provide information or a suspicion regarding the purposes for which the information will be used. Officers or support organisations who have the trust of the community, along with Gypsy and Traveller representatives, can play an important role in preparing the ground, explaining the purpose of the survey and introducing researchers.

Community members could also be invited to play a part in mapping the community within the local authority or partnership area.

Local authorities should consider holding community involvement events to ensure the purpose and nature of the GTAAs is well understood and publicised. These events should be held in locations which are accessible for most local community members. This may involve the use of any community facilities on local authority sites or nearby community facilities. Community members should be encouraged to bring along relatives or friends living off site who may need a pitch within the local authority area.

Local authorities may wish to consider share best practice on how they have engaged with community members and to work closely together to more effectively support Gypsies and Traveller s who travel across borders. It is important community members understand that the up-to-date need for any additional sites in the area is unlikely to be identified without the participation of as many Gypsies and Travellers as possible and that local authorities want to work with the community to deliver those pitches and sites. If local authorities can evidence that they have undertaken a thorough mapping of Gypsy and Traveller communities in their area and used their reasonable efforts to engage with the community, they will be more likely to be able to demonstrate the robustness of their GTAA.

In conducting the survey, it must be explained to those taking part that this exercise is designed to gain a clearer understanding of the scale of Gypsy and Traveller pitch needs, which the local authority is required to address, and to help it develop a strategy to meet those needs. However, this does not mean that the local authority will be able to meet the specific accommodation requests of all of those who have been interviewed as part of the study.

The duty following the assessment relates to providing mobile home pitches to meet the identified need. The local authority will not always be able to meet all preferences for pitches or sites at specific locations, but they should work with the community to see what realistically is able to be achieved. The allocation of available local authority site pitches is also a matter for local authorities to decide in conjunction with their other housing functions.

The universal questionnaire at Annex 3 includes a question which allows individuals to request to be included on the local waiting list for a mobile home pitch or bricks and mortar housing.

Cultural sensitivities must be carefully researched and considered during the design of the survey. Any changes to the wording of the template questionnaire need to be carefully assessed to ensure they do not offend any cultural sensitivities and should be explained when submitting the GTAA to the Welsh Government.

There will be important cultural sensitivities to consider when deciding how to carry out the survey. For example, the gender of the interviewer, the time of the interview or location of the interview might be considerations which should be discussed with the communities themselves.

Cultural sensitivities may affect the willingness of some individuals to participate. For example, some women may not be comfortable being interviewed alone in their mobile homes by male researchers. Where extended families are interviewed together, individuals should still be given the opportunity to respond separately and in confidence if they wish.

It is important for local authorities to consider the potential for genuine offence to be caused if interviewers have little understanding of the communities they are working with. It is recommended that local authorities ensure all interviewers are carried out by culturally competent people, who have undertaken Gypsy and Traveller cultural-awareness training prior to undertaking any interviews. Using known and trusted interviewers will help build confidence in the process and encourage people to share information more openly.

It is important to recognise the survey may involve interviewing members of several different communities with different cultural norms and practices.

Researchers need to be able to engage with members of each different community and with the most relevant community support organisations.

It is also recommended local authorities consider providing training for Elected Members prior to undertaking the GTAA, particularly any Councillors involved in the steering group, Planning Committee or Committee which will scrutinise the GTAA.

Consideration must be given to the appropriate timing for the survey. Seasonal changes should always be considered when deciding the timing of the survey. The local authority or partnership will need some knowledge of travelling patterns of the local Gypsy and Traveller population before a considered decision can be made as to when the GTAA survey will be carried out.

Account should also be taken of the fact some Gypsies and Travellers normally resident in the area may be away travelling themselves during summer months. Gypsies and Travellers and support organisations represented on the project steering group and those who administer the Caravan Count may be well-placed to provide advice.

Where neighboring local authorities are aware their Gypsy and Traveller populations regularly move across administrative borders it is recommended, they consider undertaking their GTAAs regionally or at a mutually agreed time to avoid the potential for double-counting and to determine the most suitable location for new sites. This may also include determining the most environmentally sustainable site across the region.

Traditional survey techniques, such as sending a mailshot to addresses, are very unlikely to deliver sound results. Gypsies and Travellers may be even less likely to respond to such a survey than other groups. Reasons for this include:

• high or seasonal mobility
• cultural differences may mean questions are regarded as intrusive or there is distrust of the process
• potentially lower levels of literacy within certain communities

Given the need to build trust and to ensure high levels of participation, face-to- face interview surveys are more appropriate as they tend to yield much higher response rates and more reliable data from these communities.

Where possible it is useful to achieve equal gender representation among interviewees. Flexibility and creativity in designing the times for visits to be undertaken including evenings and weekends should be considered carefully. The use of community involvement days at accessible facilities or trying to arrange set appointments for interviews may be helpful, as may arranging to return to the site during the evening. However, early evening appointments may be just as inconvenient if the family has young children and a bedtime routine. Agreeing appointment times with community members between late morning and early afternoon is likely to be most effective. However, this is likely to change on a case-by-case basis.

Local authorities must consider the right of children and young people to have their voices heard on decisions which affect them as required by Article 12 of the United Nations Convention on the Rights of the Child (UNCRC). Children and young people should therefore be given the opportunity to freely participate in the GTAA process in a way which is accessible and proportionate to their maturity and ability, and subject to parental consent and accompaniment as appropriate.

Children and young people should not only be recognised in the context of future housing provision, but also as individuals with current lived experiences. Including their views and giving them an opportunity to influence their living environments must be central to the GTAA process.

Local authorities have a duty to ensure these rights are upheld by actively involving children and young people in shaping the outcomes of accommodation assessments, in line with the principles of Article 12 of the UNCRC.Section D of the questionnaire addresses family growth. To identify any future growth, researchers should aim to interview the young people who may need their own accommodation during the GTAA review period.

Local authorities must ensure that appropriate checks have been undertaken through the Disclosure and Barring Service (DBS) for any interviewers that are likely to come into contact with children, young people or vulnerable adults as part of the survey. In addition, informed consent must be obtained before commencing the specialist survey.

The Welsh Government template questionnaire, based upon previous GTAAs, is at Annex 3. The questionnaire is comprised of 5 parts and seeks to ensure all the relevant data required to assist local authorities to properly assess needs is obtained.

It is recommended interviewers complete the questionnaire during a face-to-face conversation with each household in the local authority area. This process should avoid the risk of any literacy issues impeding participation and ensure a higher response rate than a mailshot, as well as providing the opportunity for community members to ask questions where necessary.

Section A of the questionnaire asks community members about their current accommodation arrangements. Analysis of this section will provide local authorities with the information required to understand the nature of the current accommodation supply. Whilst the analysis of existing secondary data may inform local authorities of how many local authority or private pitches are provided in the area, the answers to Section A will also identify how satisfied community members are with their current circumstances. This can help local authorities to recognise where site refurbishment or household adaptations are required. Grants, such as the Sites Capital Grant and the Disabled Facilities Grant, may be able to help in this process. It may also be possible to identify if site management arrangements need to be reconsidered.

Section B seeks to establish the structure of the household, including age, gender, ethnicity and any additional needs individuals may have.

The ethnicity column is not intended to capture any pre-set or legal definitions of ‘Gypsy’ or ‘Irish Traveller’ etc. Instead, this column should be used for interviewees to be able to self-ascribe how they see their identity. The purpose of this is to inform the local authority of the various cultural or ethnic groupings which may exist within their Gypsy and Traveller population, which may have some bearing on the eventual size and configuration of any new sites required.

The final column of the Section B table provides a broad opportunity for households to register anything which they believe local authorities need to know about their current accommodation. This may include a cultural aversion to a particular type of accommodation or other issues they feel should be considered.

Questions B2 and B3 should also help local authorities to understand whether there is likely to be overcrowding within the accommodation. More information on overcrowding on mobile home sites can be found in the Overcrowding section below.

Question B4 provides an opportunity for community members to request an application pack to join the local authority waiting list for mobile home pitches or bricks and mortar housing.

Section C enquires about accommodation aspirations and plans. Information gathered under this section will support local authorities to consider the viability of working with individuals to develop private sites and explore the accommodation aspirations of households who want to move.

Questions C3, C4 and C6 are designed to help local authorities consider what type of accommodation is likely to be required to meet the needs of each household.

Questions C2 and C7 (in addition to some questions in Section D) will help local authorities to assess whether any identified mobile home pitch needs may be met in the specific local authority where the household is currently residing or whether they could be provided in another local authority. If answers to these questions suggest the need could be met in other authorities, the local authority

undertaking the survey may discuss the potential for transferring the need with the other local authority. However, the unmet need would remain with the authority where the household currently resides if the other authority refuses to accept the transfer of unmet need.

Question C5 provides an opportunity for community members to make a note of any intention to develop a private site in the area. The question allows community members to request a discussion with the local authority, where the authority may assess the feasibility of their plans to develop a private site and provide general advice on the process to be followed. If the community member does not wish to provide their contact details, it would be helpful for the interviewer to signpost them to where they may seek advice about pursuing planning applications.

Section D will help local authorities to plan for anticipated family growth and the needs which are likely to arise from new households during the review period. Questions D1 to D3 will help the local authority to understand future demand for residential accommodation arising from existing households.

Questions D4 and D5 provide an opportunity for community members to inform the local authority of households living in other local authorities who want to move to enable them to reside in the same local authority as their family. If community members provide details of family members living elsewhere, the local authority should consider contacting them to assess whether they should form part of their GTAA.

Where a request for pitches arises from outside the local authority, the authority undertaking the GTAA may wish to discuss the circumstances and accept a transfer of needs from the local authority where the household currently resides. The household should be asked to consent for these discussions to take place and each local authority should consider issuing them with a privacy notice.

Under the 2014 Act, local authorities have a duty to assess the needs of those who reside or resort to their area. Questions D4 and D5 help assess the needs of those who resort to the area.

Care should be taken to ensure the GTAA captures not just those who may be resorting within the local authority area at the time the survey is taken, but also those who are known to resort to the area at other times of the year.

Finally, Section E addresses the issue of the need for transit or temporary/ negotiated stopping provision in the area and other local authority areas.

Analysis of this section will support the local authority to understand where the need for transit provision is required.

Sections A to D of the questionnaire relate to residential pitch needs arising in the specific local authority undertaking the survey. However, Section E asks for information on a wider geographic basis. This is because transit sites needs may best be met on a regional basis. Furthermore, most households interviewed by the local authority are likely to be local residents, so they are more likely to be travelling in (and therefore more interested in transit sites in) other local authority areas. Information gained from those who use unauthorised encampments is also vital to understand local need for transit or temporary/negotiated stopping places and should be factored into the GTAA to fully assess needs for temporary pitches in each local authority.

The answers to questions in Section E should be shared with the local authorities named by community members to ensure transit site needs are properly assessed in those areas. The answers to questions E2, E3 and E5 are likely to be of use to other authorities. The data shared does not need to include any personal or sensitive information or be attributable to any individual household.

If local authorities, through the steering group, decide they wish to include other questions relating to accommodation needs, they should include them as Section F of the questionnaire. To be most effective, additional questions should be developed in consultation with representatives of the local Gypsy and Traveller communities. Additional questions may include a mix of tick-box closed questions and more open questions where respondents are encouraged to expand their answers. Any additional questions should be included when submitting the GTAA to the Welsh Government.