Interim Gypsy/Traveller site design guide

5. Permanent Sites – Accommodation

The majority of sites in Scotland are permanent. On many of them, the residents stay all year round, with the option of retaining their pitch and being able to travel for a certain number of weeks of the year. Other permanent sites also provide accommodation for families who do not stay on the site on a long term basis.

5.1 Seasonal Sites

In general, provision on pitches for seasonal sites should be the same as provision on a permanent site as people are living in the accommodation for months at a time. .

5.2 Pitch Size and Hardstanding

Gypsy/Travellers have told us that current pitch sizes are often too small and that there is a need for accommodation that will meet the changing needs of a family over time. Families may grow or an individual may require a carer, resulting in the need for an additional caravan.

"Some people have big families that don't want to live in the same caravan so would need more space for separate caravans." Respondent to Online Survey, January – March, 2021

Pitches should be clearly marked.

"People want to be responsible for their own pitch and look after their own area." Gypsy/Traveller, Consultation Event, July 2021

Pitches should:

• be of a suitable size for the planned use.
• allow adequate distances to be maintained between units to ensure fire safety is not compromised – see fire safety section (6.1) on distances between units.
• ensure a level of privacy and security for each household.

While single pitches may still be appropriate in some circumstances, the clear preference is for larger pitches that can meet the needs of a wider range of families and give them flexibility to have visitors and meet changing needs over time. No site should contain only single pitches.

Gypsy/Travellers told us that people want enough space for:

• family to come to stay.
• older children or other relatives to be able to live alongside, either on the same pitch or another pitch on the site.
• separate accommodation for boys and girls.
• to be able to park their vehicles on the pitch.
• to be able to put mobile homes, which are larger than caravans, on to pitches.

Some Gypsy/Travellers have told us that they would like a washing line/laundry drying area on their pitch.

It should be clear to residents what the capacity of a pitch is in terms of caravans and vehicles. For the purposes of this Site Design Guide, we would define pitches as:

Single pitch and amenity - enable at least one caravan and car or van/light commercial vehicle to fit on the pitch (current minimum standard) or;

Double pitch and amenity or larger - enable two caravans and two cars or vans/light commercial vehicles to fit on the pitch (Gypsy/Travellers have told us that this should be the standard size of a pitch) or;

Pitch and residential mobile home - be suitable for a residential mobile home plus a car and/or light commercial vehicle or;

Extended pitch and residential mobile home - including amenity and/or space for additional caravans and vehicles (more space is required for larger families, who for example, may need space for 3 caravans and 3 cars).

Every pitch must provide hard-standing or a solid base which is capable of tolerating the weight of the number of caravans/mobile homes (and their contents) and vehicles outlined in the capacity of the pitch. For residential mobile homes the base must extend over the whole area occupied by the mobile home and must allow enough space for residents to enter and leave and move around the pitch safely. The orientation of residential mobile homes or buildings on the pitch should also take in to account how they will be used and safety in coming and going.

The vast majority of Gypsy/Travellers who responded to the online survey told us that they would like space to be provided beside the residential mobile home for a caravan to enable them to still go travelling or to provide additional sleeping accommodation if required.

"Having a tour trailer would be really important for my family so that we can still shift. Furthermore, we would want to have the space for a small caravan for our older girls/boys to stay in once they get too old to stay in the main chalet." Respondent to Online Survey, January – March 2021

The hardstandings must be constructed to the industry guidance^[1] current at the time of construction and kept in a suitable condition with any necessary maintenance. Paved areas and hardstandings larger than 50m² are subject to building standards.

Where possible electrical hook-up points for caravans should be detached from the main utility building and located as close as possible to the caravans to avoid long or trailing leads. Suitable anchor points should be provided, if necessary.

5.3 Amenity Block

The amenity block should feel like an extension to the residents' home and should therefore provide accommodation that is warm, comfortable and meets the needs of the occupant. Requirements may depend on other provision on the sites, for example amenity blocks are likely to be smaller or may not be required if a residential mobile home is provided on the pitch.

Many of the Gypsy/Travellers we spoke to told us that living space in the amenity block is now a priority. This is partly to accommodate family life and partly so that they can spend time there in the day, heating one space rather than moving between the caravan and the kitchen.

"Bigger amenity blocks are needed for sitting in and having visitors. A kitchen diner would work well. We like the layout in other sites where family have space for a TV, sofa and table and chairs in the living area. So that the children can play while someone is busy in the kitchen. Families are large and eat together." Gypsy/Travellers, Consultation Event, August 2021

Subject to the views of residents and space available, amenity blocks should include the following facilities:

• Kitchen
• Bathroom
• Flexible living space, for example an area for dining
• Storage space

Some feedback suggests that if living space is provided, this may be used for sleeping overnight on occasion. If this is considered likely then the amenity block should be designed and specified accordingly. Sleeping in the amenity blocks has implications for fire safety requirements and therefore the requirements for living space should be discussed with residents at the start of the design process. If the views of residents indicate that they would like some living space and that it may be used for sleeping then the amenity block should be designed with that intent built in. This should be continually monitored and reviewed as part of the fire safety risk assessment process to ensure any changes to initial designs can be considered appropriately.

Gypsy/Travellers have told us that it is inappropriate for a bathroom to open directly into the kitchen/living space area.

5.4 Residential Mobile Home (Chalet)

In some cases, residents and local authorities may decide that residential mobile homes are the best option. As a minimum, these should be constructed to meet BS 3632: 2015 Residential Park Homes: Specification. Mobile homes provided must be residential, suitable for occupation as a permanent home all year round, not a caravan holiday home constructed to meet BS EN 1647.

BS 3632 sets the minimum requirements and not the targets, therefore, in order to future proof residential mobile homes and meet the intention of Housing to 2040 or to prolong their useful life, there may be some elements of BS 3632: 2015 that should have the minimum requirements exceeded.

Ideally residential mobile homes provided should be capable of achieving an EPC rating of B or C, - see section on fuel poverty (5.8), however an EPC rating can only be provided for a residential mobile home once it has been situated on the site as some of the elements of the calculation are site dependent.

It may be helpful to look for a guarantee of compliance with BS 3632. For example, National Caravan Council (NCC) member manufacturer's homes carry an Approval Badge and Certificate. This signifies that the home has been inspected and approved through the NCC Manufacturer Approval Scheme as complying with BS 3632. If compliance with BS 3632 cannot be verified then the home may not be suitable for residential use.

The NCC also operate an energy efficiency rating scheme which helps to gauge the energy efficiency of a residential mobile home built by a NCC member manufacturer. A rating label is attached to the home (in the front window and placed in the user's handbook) and is a visible indicator of the degree of efficiency achieved by a particular model.

The NCC Energy Rating Scheme is designed to give purchasers of a residential mobile home built to BS 3632 an indication of the likely energy consumption and Carbon Dioxide emissions of the home they are considering purchasing. The NCC have produced a leaflet with more details of the scheme. A rating for a home will typically be between 250 and 120, the lower the number the better the rating. If a residential mobile home only met the very minimum requirements in BS 3632 and had less efficient energy systems installed, then it would likely have an energy rating of somewhere between 400 and 300. Energy efficiency is clearly an area where BS 3632 should be exceeded for residential mobile homes purchased by local authorities for Gypsy/Traveller sites. We would like to explore through the demonstration projects what the minimum energy efficiency rating should be.

In terms of u-values, the British Standard is set at a lower value than building standards, due in part to limitations on the thickness of the walls while ensuring that the home remains movable. For this reason, ensuring the highest possible specification for insulation is important. BS 3632 is currently under review and increases in u-value requirements and the improvement of vapour control requirements to manage condensation are likely as a result.

Residential mobile homes purchased by local authorities should not be larger than the maximum size of a caravan permitted by the Caravan Sites Act 1968 (Amendment of Definition of Caravan) (Scotland) Order 2019.

Architecture and Design Scotland's report, Using Offsite Construction for Housing Delivery in Scotland provides a case study on developing a residential mobile home using offsite construction. Using offsite construction may have potential to reduce the amount of time that residents need to vacate the site.

Some Gypsy/Travellers may want to buy or rent a residential mobile home to put on their pitch. Where practical, local authorities should support this.

5.5 Permanent Housing Designed for Gypsy/Travellers

South Ayrshire Council has built permanent housing configured to meet the needs of Gypsy/Travellers. This type of development will be required to meet standards for new build social housing as set out in sections 1.4 and 1.5 of this guidance note on the Affordable Housing Supply Programme.

5.6 Building Standards

Amenity blocks are not currently classed as domestic properties for building standards purposes. This is because they are not considered to be dwellings as they are not designed to provide sleeping accommodation. However, the amenity block is seen as an extension of the resident's home and should be built to the same standards as mainstream social housing in terms of fixtures and fittings. The intention is that amenity block provides accommodation that has the look and feel of a domestic property. As the final design of amenity blocks will be subject to the views of residents and may include living space in them, the classification of the amenity block for building standards purposes should be considered as part of the design and development process.

Energy efficiency of amenity blocks needs particular consideration due to the risk of fuel poverty for residents. The standard applied for energy efficiency in new domestic dwellings under building standards is higher than that for non-domestic buildings. Fire safety requirements are also different depending on the intended use of the building, for example, if sleeping is permitted then different building standards apply with regard to communication requirements to alert residents in the event of a fire. When submitting an application for building warrant under building standards, specification to a higher standard than building regulations on specific topics such as energy efficiency should be considered where identified as relevant to the delivery of the level of amenity or safety sought.

Local authorities are appointed by Scottish Ministers as verifiers to administer the building standards system for their own geographic area and are responsible for the interpretation of building regulations. Where the building regulations apply to proposed work, a building warrant is required before work can start on site. The relevant local authority verifier should be consulted to discuss the specific details of each project. The building standards website contains all relevant building standards, legislation and guidance.

Under the Heat Networks (Scotland) Act 2021 persons with an interest in non-domestic building will be required to carry out a building assessment report which looks at the potential for buildings to be supplied with thermal energy by means of a heat network and an assessment of the period any heating system will operate effectively and efficiently for. The Scottish Government is currently considering regulations and guidance for this requirement.

The Site Design Guide references the building standards in place at the time of publication, these will be subject to updates and projects should comply with the relevant building standards in place at the time a project takes place.

5.7 Decarbonisation

In keeping with the pathway to net zero set out in the Heat in Buildings Strategy, new buildings and heating systems for Gypsy/Traveller sites will be required to use zero direct emissions heating, and also feature high levels of fabric energy efficiency to reduce overall heat demand so that they do not need to be retrofitted in the future. There is no single technology that will deliver zero emissions heating in Scotland; the most cost-effective pathway will require several different approaches. The key low and zero emissions heating solutions available today are heat pumps and heat networks where the energy or heat source is low or zero emission. Under the Heat Networks (Scotland) Act 2021 applications for a heat network licence will need to show how the applicant will operate a network in a manner that minimises greenhouse gas emissions and contributes to meeting fuel poverty targets, amongst other things. The Scottish Government is currently considering regulations and guidance for this requirement.

The New Build Heat Standard will require any new building that applies for a building warrant from 2024 to use a zero direct emission heating system. A scoping consultation on this policy was carried out in early 2020, and an analysis report of the responses to this consultation has now been published. This work will help to inform the development of the Standard - which will continue throughout 2021-22.

Site designs should consider the 8 principles of a carbon conscious place as outlined in the Designing for a Changing Place Report by Architecture and Design Scotland.

5.8 Energy Efficiency and Fuel Poverty

Feedback suggests that some existing amenity blocks are cold, difficult to heat and prone to condensation. The energy efficiency and heating method for amenity blocks or residential mobile homes will impact on affordability of heating and on the risk of fuel poverty for residents. Gypsy/Travellers have told us that low cost heating is a priority.

"At the moment the amenity block is impossible to heat because you are in and out between it and the caravan all the time, letting heat out. There are 2 spaces to heat – amenity block – gas, electric or infrared and the caravan – gas. So double the costs. If the amenity block had living space, people would be in it through the day and it would warm up." Gypsy/Travellers, Consultation Event, August 2021

In deciding on heating for amenity blocks and residential mobile homes, consideration should be given to the potential impact on running costs and therefore the affordability for residents. Where action is being taken to decarbonise the heat supply, the approach taken should ensure that running costs are not unaffordable for households in or at risk of fuel poverty.

The Gypsy/Traveller Action Plan includes a commitment on fuel poverty and lived experience research with community members. Due to the impact of COVID-19 restrictions, we have had to delay this work and we will aim to carry this research out in 2022. The outcomes of this research will feed into the first review of the Fuel Poverty Strategy in 2024.

As set out in our Heat in Buildings Strategy, we want our homes to be as energy efficient as possible, meeting a minimum standard equivalent to EPC C at least, where technically feasible and cost-effective, by 2033.

Through our national and area-based delivery schemes, we want to see the homes of those in fuel poverty improved so that they reach an energy efficiency rating equivalent to EPC C by 2030 and equivalent to EPC B by 2040

For a number of reasons the RdSAP methodology used for calculating dwelling EPC ratings is not appropriate for amenity blocks so there is no current method for setting an energy efficiency standard for these buildings. We are considering whether the RdSAP methodology could be modified or whether a heat loss calculation should be developed to do this in future. In the meantime, attention should be paid to the specification of materials to deliver low levels of heat loss, consistent with or better than that required in social housing.

Residential mobile homes can be assessed for an EPC as a dwelling using RdSAP. When procuring residential mobile homes, site providers should bear in mind the future targets for EPC ratings. We would like to test how achievable this is through the demonstration projects i.e. by seeking to provide residential mobile homes with an EPC rating of B or C.

The issues around measurement and standards for energy efficiency will be considered further through the demonstration projects.

5.9 Accessibility

Housing for Varying Needs - The aim is to provide equivalent provision for those with varying needs living on Gypsy/Traveller sites to that in the settled community. Housing for Varying Needs is a detailed, technical design guide, which comes in two parts. Part 1 of the guide covers self-contained houses and flats and includes for the provision of property for general needs, older people, ambulant disabled people, wheelchair users and other specific needs. Part 2 of the guide covers housing with integrated support, including the provision of communal facilities such as staff accommodation, guest bedrooms and rooms for special services where required.

As a minimum, newly designed pitches and amenity blocks will be expected to meet the relevant basic requirements of the Design Criteria for dwellings in general to suit varying needs specified in Housing for Varying Needs. This will exceed provisions set in building standards on some topics.

This includes the applicable criteria for: access to individual dwellings; entrance doors to individual accommodation; circulation spaces and internal door; living space; storage; kitchen; bathroom; windows; heating and water services; and power and communications.

In order to meet the needs of a range of residents over time, a proportion of new or refurbished accommodation should be configured to meet the needs of older and ambulant disabled people.

Gypsy/Travellers have told us that accommodation should be "designed to suit different needs such as disabled, elderly." (Respondents to Online Survey, January – March 2021)

Like mainstream social housing, local authorities should assess the needs for their area. The most common target for this type of provision is 10%, however, given that the 2011 census reported that Gypsy/Travellers are more likely to have a long-term health problem or disability, the level of provision may need to be higher than for the settled community.

Providing accommodation with full wheelchair accessibility should be considered in accordance with identified need for a specific tenant. The pitch and amenity block should be designed for full wheelchair accessibility, meeting the relevant design criteria within Housing for Varying Needs.

The Scottish Government are leading a review of Housing for Varying Needs, with completion due by March 2023. The updated guide aims to provide advice to promote improved design, accessibility and adaptability to better meet peoples' needs, at minimal additional cost to the public purse.

Adaptations - Residential mobile homes can be built to provide for accessibility needs e.g. wider doors or re-enforced roof trusses for hoists, without significant additional cost if these are specified in advance. Retrofit can be more costly. As set out in Housing to 2040, the Scottish Government is looking to streamline and accelerate the adaptations system to take action to reduce the time it takes to apply for and receive support and maximise the available resources. This will review terminology and definitions which currently mean that the caravans and mobile homes are not considered as a house and as such are prevented from receiving scheme of assistance to help pay for adaptations.

Other Considerations - As with settled accommodation, it is also important to consider other issues facing Gypsy/Travellers in the design of accommodation. For example, with an increasingly elderly population, the needs of those with dementia should be taken into account. The Royal Town Planning Institute have produced an advice note for creating better environments for people living with dementia which includes a section on housing design. Consideration should also be given to any requirements for accommodation for someone with autism.