Draft guidance for managing Gypsy and Traveller sites - Chapter 10: services and utilities on site

Previous experience of discussions between local authorities and residents has shown that mobile home occupiers prefer to have a direct relationship between themselves and an electricity supplier. However, such direct customer relationships are currently rare on local authority sites. It is strongly recommended that local authorities consult residents on their preferred method of electrical supply and seek to achieve this through liaison with the electricity provider.

To alleviate the potential financial and practical challenges faced by residents on local authority sites it is recommended that local authorities ensure these sites are connected to direct mains services where practicable. This can help avoid the higher costs associated with utilities being charged at commercial rates, such as expensive gas bottles and higher costs through prepayment meters.

The Welsh Government believes that direct customer relationships are likely to be the best way to ensure that Gypsies and Travellers are able to achieve equal access to fair billing. This system would reflect the system used in the social housing market, where tenants would not normally be required to pay their bills through a local authority intermediary.

Some local authorities are being charged commercial rates for gas and electricity on sites because they are not classed a domestic premises or eligible for domestic fuel rate. Where local authorities are responsible for arranging the provision of utilities for all those on the site, they should use their best endeavours to secure competitive tariffs and consider moving across to domestic rates for their electricity usage where possible.

Where electricity suppliers consent to direct customer relationships, residents would be billed for their actual electricity usage, rather than an equal share of usage across the whole site. It may also be the case that residents are only eligible for energy saving grant schemes if they can demonstrate that their bills relate to their actual usage costs.

Where direct customer relationships are not possible, site managers should fully explain the reasons for this to residents and liaise with suppliers to help ensure that residents are receiving competitive rates.

Direct customer relationships would not be appropriate for transit sites, where occupiers are only permitted to stay for up to 3 months.

Where payment cards/tokens/keys are in use for electric supplies, these should be available from the site manager and at least one other outlet, such as a local shop. It is important that residents are not prevented from buying electricity cards/tokens due to the unavailability of site managers. Local authorities and contracted managers must not make a profit from the sale of electricity cards/tokens to residents.

In cases where electricity cannot be billed directly to the residents it is acceptable for local authorities to collect payment along with the pitch fees. However, these costs should not form part of the pitch fee itself. If requested by the resident, the local authority must provide documentary evidence of the electrical costs free of charge.

Gas bottles/containers may be used on site. Residents should be made to understand that they are responsible for the safe storage and use of these containers and the removal of empty containers from pitches to either a collection point or storage facilities on site. Site managers must ensure that appropriate gas safety procedures are followed at all times to prevent empty containers becoming a fire hazard.

Local authorities may make storage facilities available on site but should ensure that residents remain responsible for storage, use and removal from their individual pitches.

Direct customer relationships between site residents and water suppliers are recommended where possible to ensure that residents can achieve equal access to fair billing. To achieve this, any site water and sewerage infrastructure must meet the requirements of the relevant water company and comply with relevant legislative standards.

Where a site’s infrastructure does not comply with the water company’s required standards, local authorities should consider asking the water company to provide meters for individual pitches instead, subject to consultation with residents.

Water meters ensure actual usage can be recorded which will enable residents to take responsibility for paying for what they use. Residents without a direct customer relationship with the water provider will not be eligible for any water company social tariffs. In these circumstances, any families who may be experiencing poverty could be disadvantaged.

Communal water supplies must also be metered and the cost of this can be recouped through pitch fees, subject to agreement.

Local authorities are expected to monitor and manage the water efficiency at sites in order to ensure wastage through leakage or inefficient practices are minimised, allowing water and sewerage charges to sites to be kept to a minimum.

Where local authorities decide to collect water and sewerage costs at the same time as the pitch fee, residents should be made aware of how much of the fee is made up of these costs. If requested by the resident, the local authority must provide documentary evidence of the charges free of charge.

Where residents on sites who are experiencing high poverty levels are unable to achieve direct customer relationships, local authorities are not expected to subsidise the cost of pitch water and sewerage supplies. It is important residents take responsibility for their usage and contribute towards the costs of supply and drainage.

Direct customer relationships would not be appropriate for transit sites, where occupiers are only permitted to stay for up to three months. In those circumstances, the local authority will be the customer of the water company.

Local authorities must, in accordance with section 45 of the Environmental Protection Act 1990, provide a waste collection service. This should ideally be from individual pitches on a weekly or fortnightly basis, depending on the local authority policy on refuse collection. The site manager should work with the relevant local authority departments to ensure that waste collection and any additional containers required are supplied to the site.

Ideally, refuse collection lorries should be able to enter the site. However, the infrastructure of some existing sites may prevent this.

Where site barriers are in operation, the site manager is responsible for ensuring these are opened in time for collection services to gain access. In addition, the site manager must ensure that obstructions do not prevent access to or around the site.

Poor waste management by either the residents or the collection services can lead to serious health hazards.

Recycling facilities on site should be provided. Site managers should liaise with Environmental Health to arrange for the provision of appropriate and adequate facilities for recycling. These facilities should reflect the needs of the site including normal domestic recycling in line with what is provided to other housing provision within the local authority.

Residents should also be encouraged to utilise existing facilities within the wider community, such as Civic Amenity Sites, for more bulky collections. However, where commercial activities are permitted on site and residents are likely to require many trips to the Civic Amenity Site during the week, site managers may want to consider arranging specialist provision or collection. residents may be asked to pay for this service.

It should be clear in the mobile home agreement that while the site manager is responsible for arranging routine waste collection, it is the responsibility of residents to ensure refuse is appropriately stored and available for collection.

Local authorities and residents may be able to receive advice on ways to save on energy, water and waste through Resource Efficient Wales. For advice and support with identifying ways to improve efficiency, visit Resource Efficiency Wales.

Site managers should ensure any social care providers who monitor the welfare of residents are able to access the site. Part of the role of the site manager is to ensure that site conditions do not hinder access to services and that those who need access to the site are able to do so. The site manager should also help residents to arrange appointments or visits where necessary.

Community liaison with Traveller Education Services and other appropriate agencies is fundamental to ensuring inclusion and equal opportunities for Gypsy and Traveller children. Relationships between these services and the site manager should be developed and maintained on and off site and the site manager should again ensure that the appropriate departments are informed of the arrival of children to the site and work to ensure the children on site have access to the services they require.

Community midwives and health visitors may wish to use any site office for on-site consultations and vaccinations clinics. Where on-site facilities exist, site managers may wish to notify local health boards of these to ensure that services can be delivered on site.

Other services, such as Flying Start, may wish to use communal buildings on-site to deliver services to eligible members of the community. This might include ‘Language and Play’, adult literacy, health eating, mother and baby, or other sessions. The Period Dignity Lead within the local authority may also wish to use communal buildings to provide period products or training.

Relations between Gypsies and Travellers and the police can be difficult at times. However, residents on Gypsy and Traveller sites are equally entitled to police services as the settled community. The site manager should work towards building a good relationship between residents and the local police, in particular, encouraging residents to report incidents of crime on the site, as well as any hate crime and racist behaviour/abuse directed towards them off-site.

Hostility or prejudice targeted at Gypsies and Travellers can be frequent and may include low level but persistent targeting. Significant tensions may arise as a result of proposals for the development of new sites locally. The site manager should advise and encourage residents of ways in which they may report hate crimes or incidents through the Police or to the National Hate Crime Report and Support Centre run by Victim Support Cymru through a free independent helpline 0300 30 31 982 (Free 24/7) or online. Save the Children are also operating a national reporting centre for children and young people from Gypsy and Traveller communities to report cases of harassment or hate crime.

A good relationship with the police can help to protect site residents, in particular, from external threats, while also helping to protect staff working on site.

Police should be granted the same access to a local authority site as to any other residential community and rules concerning warrants etc. apply equally.

The site manager should seek to facilitate good relations between residents and the police by engaging the local Police Community Support Officer and, where necessary, the force Diversity Officer to help foster respect between residents and the police, provide useful cultural awareness for any required police actions on site and give police an opportunity to work with these communities in a non-enforcement context.

Site managers must ensure that emergency vehicles can access the site when required. If an entrance barrier is in operation, the site manager must ensure that all services have the current code or key access. Failure to do this may endanger lives and/or property. Residents should be made aware that they must not prevent access to emergency vehicles and that this will constitute a serious breach of their pitch agreement.

Emergency services should be made familiar with the layout of the site and be provided with a site plan. This should include details of water hoses or hydrants. They should also be provided with relevant contact details.

Local fire services should be permitted access to inspect the site in order to ensure that the mobile homes or any other aspect of the site do not breach fire regulations as well as to assess the level and condition of firefighting equipment on site. It is the responsibility of the site manager to liaise with the fire service to arrange these visits and to ensure that fire safety standards are met. Residents should be informed prior to site inspections taking place.

Residents should be made aware that fire hoses are for emergency purposes only and their misuse may constitute a serious breach of their pitch agreement.

Local authorities should consult with their local fire service to assess the need for fire hoses and possible solutions if vandalism is a particular problem on a site.

Residents of local authority sites are entitled to the same level of postal services as people living in any other types of housing. The site manager should liaise with the Royal Mail to ensure that the site is recognised as a residential area.

It is not acceptable for all mail to be delivered to one pitch on site as this may lead to a security risk or a breach of a resident’s right to confidentiality.

Each pitch should have its own address, which should not identify the site as a Gypsy and Traveller site.

Some postal workers have refused in the past to deliver directly to pitches for a number of reasons, for example dogs that are not properly controlled. Where this is the case the site manager should identify the issue and attempt to address this with site residents and the post office in order to re-instate service to the pitches.

It is important for site managers to be aware of the movements of Gypsies and Travellers in the local authority area and notify the local authority if any unauthorised encampments move onto the site by referring to The Managing Unauthorised Encampment guidance. Where a Gypsy and Traveller Liaison Officer is in place, there will need to be close liaison between them and the site manager.

The local authority should also inform the site manager and operational manager where any unauthorised encampments have occurred off-site by those visiting residents on the site.

The site manager is responsible for dealing with unauthorised encampments on site and notifying the operational manager of any such encampments.

Consultation has shown that typically site residents do not want CCTV installed on site. However, CCTV is sometimes necessary to counter crime on site. Where a local authority installs CCTV, this should be done following consultation with all residents.

The privacy of residents must be respected at all times. Any CCTV cameras must not be directed into any occupied pitches and must not prevent residents’ enjoyment of their pitch. If CCTV is to be installed, the site manager should demonstrate how the system works and what it will capture to residents. Where CCTV is installed the site manager will be responsible for ensuring this is in good working order.

CCTV images which show identifiable individuals are subject to the Data Protection Act 2018 and UK GDPR and must be processed lawfully in the same way as any other personal data.

The local authority must install signage telling residents and visitors that CCTV is in operation, who controls the system and why. Local authorities will also need to decide how long footage will be kept for and how to deal with any subject access requests made by residents and visitors. Finally, the local authority must ensure the CCTV monitors are secure and cannot be viewed by unauthorised personnel.