Response: Consultation - Gypsy and Traveller Preferred Option Sites - Consultation

Ref: GT02 Fosse Way-Junction B425 and GT04 Harbury Lane-Fosse Way

>>>>>>>>>>>>>>>>>>>>>> Objection.

Dear Sir,
As a family, we have lived in Harbury for some 32-years and as a long standing resident, write to object to your proposals for a site GT04 and an alternative option site GT02
Your required consultations with neighbouring planning authorities, as required by government guidance has not occurred; your Chief Planning Officer admitted:
Between February 2012 and January 2013 there had been just 3-meetings with Stratford District Council, apparently only one of which had any minutes taken.
Quote: Chief Planning Officer WDC , "Although the council continue to hold dialogue with other councils and in particular Coventry City Council, Rugby Borough Council and Stratford District Council, sites within Warwick District have not been discussed at length."
Government guidance notes
P5: Point 4:2 "to ensure that local planning authorities, working collaboratively, develop fair and effective strategies to meet need through the identification of land for sites"

P5: Point 9c: "consider production of joint development plans that set targets on a cross-authority basis, to provide more flexibility in identifying sites, particularly if a local planning authority has special or strict planning constraints across its area (local planning authorities have a duty to cooperate on planning issues that cross administrative boundaries)
1. I can confirm community groups prior to the decision on the sites were not consulted. Although a meeting was held in Harbury AFTER GT02 and 04 were put forward as preferred sites, This was after the event as against the government's guidelines which state:
When assessing the suitability of sites in rural or semi-rural settings, local planning authorities should ensure that the scale of such sites does not dominate the nearest settled community."
2. The surgery and the school in Harbury were not consulted to identify if there was spare capacity.
3. This lack of consultation seems to have ignored government guidance 4.11: "to enable provision of suitable accommodation from which travellers can access education, health, welfare and employment infrastructure"
Of special concern was Warwick District Councils failure to carry out due diligence in respect of the Salford University GTAA report, which unfortunately has formed the basis of its decision-making.

In 2011, the WDC's report identified the need for just 15 TRANSIT pitches and that "demand for permanent site-based accommodation was low and transitory in nature". Yet now we are led to believe that in addition to 15 transit pitches, there is now a need (according to Salford) of 15 PERMANENT pitches. Who has questioned this discrepancy?

Your officers have advised these sites may require the use of compulsory purchase powers if necessary. However, it is an important oversight that no associated costings have been presented either for the purchase or loss of livelihood of those displaced by the compulsory purchase.
There is also further advice, of which your officers until recently have not been aware;
current guidance from Minister Eric Pickles Department of Communities and Local Government saying such powers of CPOs should NOT be used in relation to G&T sites.

This is confirmed in the following report from Hansard


Perhaps it would be prudent if your officers further investigate this, as there appears to be contradiction and use of invalid assumptions that render the Salford report flawed. (?)

There also appears to have been positive discrimination favour of gypsies and travellers, and insufficient publicity to advise local communities of proposals, many of the settled community in the local area are still unaware of the proposals, implications and consequences.
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The following objections were previously made during the consultation phase:

a) Both GT02 and GT04 are located next to a busy commuter route. It is also a known that the Fosse Way is a high-risk accident black spot.

Specifically, GT04 Harbury Lane is busy, with a 50mph speed limit on vehicles traveling to the M40, Gaydon industrial areas, Leamington Spa and Warwick.
The Fosse Way has a 60mph speed limit. There is a continual stream of traffic and is particularly heavy at the peak commuting times when traveling to and from work locations.

The stretch of road between the A425 and the B4100 is an accident black spot with a high casualty rate = 68 casualties in last 5-years
The junction with Harbury Lane Fosse Way crossroad is particularly dangerous due to the speed and volume of traffic = 10 casualties in last 3-years.

An increase in vans, lorries, trailers and caravans as travellers enter, exit the sites and by their nature, will be slow traveling vehicle that will increase the hazard for road users.
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The proximity to the local community: GT04 and GT02 do not meet the NPPF or PPFTS guidelines recommendation for sites to be on at least the edge of a community to encourage integration

The sites are remote from the facilities, and the bus service infrequent should the gypsies and travelers be inclined to use then. This would be doubtful when, like most others, they have modern vehicles that they would simply use.

Site users would in general, not use buses, even if running at a convenient time for schooling or the doctor's surgery. In cases of emergencies cars would be used; for these reasons alone, the sites are unsuitably located.
Distances and lack of safe footpaths make the possibility of walking unlikely / impossible; it would be unrealistic to expect walking to happen, making the site locations once again unsuitable.
This appears also to be against government guidelines for sites 4.11 states "which travellers can access education,"
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Accessibility to shops and local services: Clearly, these sites do not meet the NPPF guidelines nor those of Department for Communities and Local Government (CLG) Planning Policy for Travellers sites (PPFTS) (March 2012) which recommends a 5-10mins walk on a pavement

The sites do not meet the NPPF and PPFTS guidelines and recommendations for availability of good infrastructure. This includes roads, pavement, street lighting, and broadband, cell phone reception. There are no pavements, no street lighting along the roads adjacent to both sites.
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The Harbury schooling and medical facilities are already oversubscribed and is likely to remain so given the current village demographic. If 'cross border' liaison, as the government required, between Warwick DC and Stratford DC had happened, then this would have immediately been apparent.
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Among other site requirements, your selected locations should not have a high risk of flooding.
However, site GT04 (+GT02 to a lesser extent) does have regular flooding. Flooding is not unusual along Harbury Lane and some serious flooding after heavy rains also has happened. Together with bad smells from the chicken farm, noises from the breakers yard, this site overall, makes a bad choice and any would be residents would soon realise this.

Aesthetically, site GT04 will directly impact on the views from the well-known Chesterton Windmill, which is an important heritage and tourist site given the historic nature and landscape of the surrounding area. Views toward GT02 from both the Radford Semele and Ufton escarpments would be also blighted with this location should it be developed

In Summary

I object to GT04 and GT02 sites on the basis that that there are more appropriate sites which satisfy the criteria

* These sites are not sustainable (a key requirement of NPPF and PPFTS)

* Gt02+GT04 do not meet any of the basic requirements of NPPF or PPFTS


* There is excess Gypsy and Traveller site capacity in Warwickshire, consequently, the need for these sites is based on a grossly flawed GTAA as there actual need is very much smaller than Salford have calculated the need to be.

* WDC have not properly consulted with neighbouring planning authorities as required


* The basis for the proposal around GT04 and GT02 is clearly positively discriminating against the settled community

* The local community of the area has not been properly consulted. The Warwick DC have advertised as they normally do, also latterly conducted (generally) poorly attended 'open days'

They can claim to have provided 'due notice to the public', yet the settled communities, in the main, remain uninformed; the communications exercise actually failed to convey the councils intentions and consultation process messages adequately.