Object

Representation ID: 64864

Received: 06/06/2014

Respondent: King Henry VIII Endowed Trust (Warwick)

Agent: AMEC

The site should be re-classified as a red site that is not suitable for development as a gypsy and traveller site.

Unclear why some sites were originally identified if there are now key reasons why they are not suitable.

The consultation document should clarify the difference between the capacity (potential number of pitches) and recommended maximum number of pitches for each site. It will avoid confusion that the potential number of pitches for a site corresponds with WDC's longer term aim for the number of pitches which can be accommodated on a site.

There's also inconsistency in how sites perform against certain criterion, e.g. noise impact. This site is adjacent to A46 and therefore noise impact will be a key factor which cannot be adequately mitigated. This is sufficient to rule out this site from consideration. Several other sites identified by the Council as red sites (GT07, GT17, GT18, GT20 and GTalt13) include noise as one of the reasons why they are unsuitable. For site GT17 it is noted that noise would be intolerable from the A46.

There are potential health issues (e.g. noise) being so close to a busy dual carriageway. Caravans/mobile homes noise insulation properties are poor. Double and triple glazing mitigation measures will not be appropriate to caravans/mobile homes.

The National Planning Policy for traveller sites (CLG, March 2012) paragraph 11e, states policies should: "provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there...".

'Designing Gypsy and Traveller Sites' Good Practice Guide, CLG, 2008 Paragraph 3.18 states that when considering sites adjacent to main roads careful regard must be given to the health and safety of children and others who will live on the site and the greater noise transference through the walls of trailers and caravans than through the walls of conventional housing.

Noise would be a key issue in determining any planning application for residential development on a site adjacent to a main road. The Council recognise this is their Planning Application Validation Checklist. The National Planning Policy Framework (NPPF) Planning Practice Guidance identifies noise needs to be considered when new developments would be sensitive to the prevailing acoustic environment.

The Noise Policy Statement for England (DEFRA, March 2010) states there is emerging evidence that long term exposure to some types of transport noise can cause an increased risk of direct health effects.

Although the site has been reduced to avoid the flood plain, caravans and mobile homes are more vulnerable to flooding than traditional houses. Also flood mitigation measures for traditional housing, are unlikely to be financially viable for development of a gypsy and traveller site.

The National Planning Policy for traveller sites (CLG, March 2012) paragraph 11g, states that sites should not be located "in areas at high risk of flooding, including functional floodplains, given the particular vulnerability of caravans." The National Planning Policy Framework (NPPF) Planning Practice Guidance identifies caravans, mobile homes and park homes intended for permanent residential use as highly vulnerable in the flood risk vulnerability classification.

Development here needs to be a very high standard to ensure that it does not negatively impact on the character of the local area, the setting of Warwick, the amenity of local residents, visitors and tourists. The necessary standards of development would not be secured with a gypsy and traveller site.

The Submission Draft Warwick District Local Plan notes that, camping and caravan sites can seriously harm the landscape if they are insensitively located and although Gypsy and Traveller sites are not 'caravan sites', the physical characterises are clearly very similar and therefore the nature and quality of the development proposed could be harmful to the landscape in this location.

Site is visible from public areas, including the golf course, public rights of way around the racecourse and the racecourse itself. It is likely that it would be visible when races are televised. The suitability of development of this nature in such a sensitive location where visual impact is particularly important must be questioned.

It's essential that development in the immediate vicinity of the racecourse does not negatively impact on the racecourse and in turn the local economy. A gypsy and traveller site will not achieve an appropriate standard of design and is incompatible with the racecourse as an adjacent land use.

The site sits outside of the boundaries of Warwick Racecourse/St Mary's Lands but in very close proximity to it. It is an important recreation, leisure, heritage and entertainment area of the town and the wider impact of developing the site and need for sensitive development should not be forgotten.

There are concerns about animals being kept in close proximity to the racecourse, with a potential risk of diseases being transferred from non-vaccinated animals to thoroughbred racehorses.

The site is close to the Gog Brook (part of the River Avon Local Wildlife Site). Development of the site must not harm any priority habitats or species that may be present in the vicinity of the LWS.

The site is not considered to be 'developable' in the definition set out in Planning Policy for Traveller Sites, CLG, March 2012 (paragraph 9c) as the site is not available now and is principally in the ownership of the King Henry VIII Endowed Trust. Compulsory purchase powers would be required with significant financial and time considerations for the Council. The site is not available or deliverable without compulsory purchase.

The site is also in close proximity to an existing residential property, Budbrooke Lodge. At paragraph 6.2 of the WDC Sites for Gypsies and Travellers Preferred Options document, point 11 notes proximity to other residential properties as a criterion to be considered in the suitability of sites. It is not evident that in this case the amenity of residents at Budbrooke Farm or those in the wider area have been appropriately considered.

County Highways believe access to the site can best be addressed via Budbrooke Lodge. As Budbrooke Lodge is in the ownership of the King Henry VIII Endowed Trust and it is not available, there clearly remain concerns over the suitability of the site based on access considerations.