Ref SDC Reg 18 consultation (Q1 2014) point 9, potential sites need consideration with respect to "previously developed, untidy or derelict land". GT04 and GT02 do not qualify in these respects.

Assessment of site suitability should be consistent with other planning requests. Note that domestic planning applications within GT04 has been recently rejected by council planning authorities, referencing rural policy on the grounds that the proposal would have an "impact to character of the area".

The needs assessment has falsely identified a "required" number of permanent pitches, as clarified in the two key points below (and respective sub points):

Point 1 - WDC utilised the findings in the Salford GTAA report in order to establish need, however there is no evidence of WDC's due diligence in validating the accuracy and relevance of the established need.

* WDC consultation does not consider existing capacity in current sites within Warwickshire county and adjacent districts.
* WDC's 2011 report "Evidence of local needs and historic demand for G&T sites in Warwick District" identifies the need for 15 transit pitches and "demand for permanent site-based accommodation was low and transitory in nature" (para 1.3).
These figures are in stark contrast to the 2012 Salford findings, identifying need for 180 individuals to be housed in permanent sites.
* WDC have not identified the requirements or classification for G&T community that need to be housed on permanent traveller sites, for example:
a) The population already in brick & mortar housing;
b) The transitory travelling population;
c) The old/infirm who no longer wish to travel.

Point 2 - The Salford GTAA report has a number of flaws, which suggests the findings lack credibility.
* Salford research was conducted by Gypsies, and the interviewees were Gypsies. Ref page 64 "of Romany Gypsy background"; Ref Hansard report 4th Feb Gavin Williamson.
* The Salford report does not contain any impartial external references; For example, there is no comparison with existing government data (ie bi-annual caravan counts, 2011 census, gov stats for cost per pitch).
* Salford report findings do not consider existing capacity in current sites within Warwickshire county and adjacent districts. The report states that this capacity should be considered when interpreting the findings.
* Paragraph 3.5 of GTAA report states there are 124 individuals in 33 households in the study area.
The majority (18/33 households) of Salford report G&T interviewees are currently living in brick & morter housing. Of these, only one family stated they are on the waiting list for a permanent site.
The Salford report finding identifies a need for 25 pitches = 47 caravans (1.9 per pitch), which at 4 people per caravan approximates to 180 individuals.
=> The Salford report suggests new pitch provision to re-house the entire Warwickshire G&T population.