Object

Representation ID: 65606

Received: 02/06/2014

Respondent: Bishop's Tachbrook Parish Council

[Report by Link Support Services (UK) Ltd on behalf of Bishop's Tachbrook Parish Council.

Commentary on WDC's Site Assessment

1-Landscape Character

This is a woodland area and is classed by WDC as 'not previously developed' (email response to questions dated 3rd of April 2014).

GT15 does not [therefore] correlate with Policy H of the Planning Policy for Traveller Sites Paragraph 24 encourages local planning authorities to attach weight to 'The effective use of previously developed (brownfield), untidy or derelict land'. [and] may conflict with the 'preferred' status of the site given that it cannot be accorded such weight in its favour

2-Nature conservation designation

Tach Brook (G2) flows through the plantation and is a tributary of the River Avon which is a Local Wildlife Site (LWS SP15Li8f). The Tach Brook is part of the arterial network of tributaries and wildlife corridors which are an intrinsic feature of the River Avon itself and is part of the Avon LWS designated area. ('l' Warwick District Gypsy and Traveller Sites Habitat Assessment page 15)'

The site is designated as part of the non-statutory Ecosite 08/36, Marsh Along Tach Brook and the Tach Brook forms part of the River Avon LWS, as one of its tributaries (Swift ecology assessment - see Appendix A [of this submission])

The site therefore has an important role within the wider ecological and biodiversity setting of the area. This factor weighs against the site in terms of any strategic sustainability appraisal as required at draft submission stage.

3-Historical designation

None that are aware of although the archaeological significance of the site is unknown which in turn may affect its historical designation.

4-Infrastructure requirements

WDC's site assessment flags up key 'negatives' regarding infrastructure requirements (sewerage, potential surface water pollution, and electricity supply viability) which carry significant weight against the proposals

5-Ecology

Notwithstanding the importance of the ecology points raised [elsewhere] it is clear that there is merit in preserving the site as undisturbed woodland and protecting the site from the potentially negative effects of development:

WDC states that the
'Nearest waterbody for discharge of treated sewage is Tach Brook. Tach Brook is failing in its objectives under Water Framework Directive due to high levels of phosphates and therefore the site is not suitable in terms of potential impact on water environment'

'Given the mix of habitats in the area, including the broad-leaved woodland, mixed grassland and the watercourse makes this a site that should be maintained as part of the wider area for its wildlife interest. (Warwick District Gypsy and Traveller Sites Habitat Assessment page 15)'


The development will impact on the non-statutory designated ecosite, Marsh Along Tach Brook, and is also likely to impact on the non-statutory designated Local Wildlife Site, Tach Brook. The woodland ecosite area is of local ecological importance, but the Tach Brook is of county importance given its status as part of the River Avon system. The level of impact on both these sites will depend on the extent of ground relevelling works required and the location and design of the proposed pitches and access arrangements; precautions will be required to prevent significant damage to this site, in particular the watercourse

The Tach Brook runs alongside the site and is of 'county wide importance given its status as part of the River Avon system'

'The site also has the potential to support reptiles and great crested newt and the presence of dormouse and white-clawed crayfish cannot be ruled out'

'The site is likely to be used by foraging or commuting bats'.
'Trees, hedges and scrub are potentially suitable for use by nesting birds and the steep earth banks of the stream could also be used by breeding kingfisher'.

'Wildlife interest' on site
'Evidence of badger activity and nesting birds was found on the site, and there is a high likelihood that roosting bats are present in some of the more mature trees. Possible water vole burrows were found along the banks of Tach Brook, but this would need to be confirmed through further dedicated survey work. It is also possible, although unlikely, that the stream is used occasionally by otter. The site also has the potential to support reptiles and great crested newt and the presence of dormouse and white-clawed crayfish cannot be ruled out'.


(refers to Swift Ecology Report Appendix A [to this representation]attached)

This [evidence] weighs significantly against the site

Wider ecological significance

'The River Avon lies approximately 1.8 km to the west of the site, which is hydrologically linked to the site via the Tach Brook tributary. (refers to Swift Ecology Report Appendix A attached)

The site [therefore] has intrinsic ecological value and also possesses a wider ecological significance. The potential effects of development at this site constitute a major negative significantly outweigh potential benefits

6-Flooding

WDC states that the site area has been reduced to take account of flooding (SFG&T page 21)

Given that this site could house vulnerable structures (potentially occupied by vulnerable people) we would recommend that a full flood risk assessment is carried out prior to its further consideration. This will either eliminate the site from further consideration or else provide greater confidence to WDC, an Inspector at Examination in Public or a prospective developer.

Given that the site is being assessed as part of a shortlisting process this key issue should not be left to the Planning Application stage.

7-Contamination and other constraints

WDC should provide a clear information as to the design prospects of this site which is constrained by a steeply sloping embankment, difficulties regarding connections for waste and power, natural constraints (to impact on the fauna, flora and river - both at the construction stage and during occupation e.g. access onto the site by emergency vehicles).


* Access' issues into and around the site (for large towed vehicles, emergency vehicles) may be adversely affected given the relatively steep slope down to the site and the costs of levelling/ terracing required to achieve suitable access gradients and to level terrain to level terrain to accommodate site trailers.

* The impact of the generally sloping terrain on occupants with mobility difficulties and whether this topographical issue would permit easy use of wheelchairs, mobility scooters, pushchairs etc.


* General lack of space for visitors, overnight guests, play area, parking, paddock for horses etc.

* The cost and technical requirements involved in providing for waste disposal

* Unresolved issues of potential air, light and noise pollution, archaeological significance, flood risk (assessment, management and mitigation)


* Potential effect on the visual amenity of residents
Comment: Design guidance.

Planning Policy for Traveller Sites - Department for Communities and Local Government 2012 (PPfTS) states that when assessing sites in a rural or semi-rural setting, site development must accord with the design principals and specific issues contained in Designing Gypsy and Traveller Sites, Good Practice Guide, DCLG May 2008 (

Recommend that WDC provide a clear statement/ assessment as to the design prospects of this site.

This will either eliminate the site from further consideration or else provide greater confidence to WDC, an Inspector at Examination in Public or a prospective developer. Given that the site is being assessed as part of a shortlisting process we feel that this key issue should not be left to the Planning Application stage.

* [Noise]

Effect on noise levels emanating from altered ground levels and creation of vehicular access. It is possible that this may give rise to increased levels of noise nuisance. The effects of noise nuisance on occupants sleeping in vulnerable structures at this site is unknown and should be investigated further (as part of a design statement) if the site is to remain a 'preferred' site.

The issue of potential noise nuisance associated with the close proximity of the site has already been noted (above - site assessment comments) and concur that an appropriate survey should be undertaken prior to the site being consideration for further consideration as a draft submission stage site.

The (Enfusion) sustainability assessment ('1') notes that:
'The site is adjacent to the Warwick by-pass A452 (noise effects on sensitive residential development) and..... In addition, it is recommended that a noise assessment is carried out to identify possible noise impacts and suggest appropriate mitigation.

* Archaeological significance.

It is noted that the 'Warwickshire County Council archaeology officer comments are awaited and will contribute to the evidence base when available'. No assessment is therefore currently available as to this facet of the site.

* Agricultural land quality
In practical terms this is undeveloped woodland (Grade 3 agricultural)


* How visible and open in character is the site?


The land slopes away from the road and is less visible because of this' (WDC comments)

Comment: Site prominence may change as re-levelling will be required to ensure access to the site. This should be clarified via an outline design statement/ assessment against best practice guidelines as referenced above.


* Can the site be visually screened adequately?

Site visibility may change if re-levelling is required to ensure access to the site - this in turn may affect landscaping. This should be clarified via an outline design brief/ assessment against best practice guidelines as referenced above.


* Is the site close to other residential property?
There are other residential properties fairly close to the site. The properties can be seen from the site and (dependent on screening provision) this factor has the potential to affect the visual amenity of these residents and the occupants of this site

* How far away is the primary road network?
The site adjoins the primary network

* Distance to GP surgeries, schools, dentists, hospitals, shops, community facilities?

Local bus services are infrequent and that distances to nearest bus stops are not within acceptable

There are no formalised pedestrian walkways or cycle-ways along this busy stretch of road. The site offers a lack of choice of modes of transport for occupants and/or visitors.

The site would therefore - most likely - be car dependent.

This weighs against the site in terms of its choice or sustainability.

This point was born out by the earlier interim assessment report commissioned by WDC (1 Sustainability Assessment).


* [Sports provision]

A 4-5 pitch site could generate in the region of 25 plus trips per day (business, personal, school) with little or no opportunity to offset this through use of local bus services.

* General availability of school places.

WDC has stated that 'school places are available' whereas local opinion tends to disagree and feels that 'local schools are full'. It may be appropriate for BTPC to discuss with Governors and others the actual picture with perhaps the provision of accurate/ transparent statistical data to be fed into the consultation process to demonstrate availability of places.

Information should also be made available as to when new schools will be built and new places available as this also may affect the viability of the site from a site shortlisting perspective.

* Is the potential site on previously developed land?
No. See comments above

* Access issues

'Access and visibility splays are achievable if some roadside vegetation is removed' (WDC comments)

Whilst this may be accepted, WDC to comment on the issue of large slow moving vehicles (towed caravans, trailers etc.) seeking to access the site by way of a right turn across the carriageway.

During various site visits traffic has been observed to be fast moving and the relatively narrow carriage-way currently offers no prospect of 'hatching' to filter right turning vehicles into a separate lane (allowing other vehicles to pass by safely). This factor may militate against road safety and impact on traffic flow and would need to be assessed in detail prior to its continued inclusion as a preferred site.

Note: Policy DP6 of the Warwick District Local Plan 1996 - 2011 states that development will only be permitted which provides safe and convenient access and where development can demonstrate that does not cause harm to highway safety.

* [Steep Access to site]

Key concern relates to access (down) a steep slope and onto an un-level site.

Members of the travelling community suffer disproportionately with ill health. Information as to how occupants with limited mobility needs would cope in such circumstances (uneven/sloping/ or re-levelled terrain) is not available or referred to as part of the early accessibility or sustainability equation. This should form part of an early design statement relating to the site.

* Level site?
No .Our key concern relates to access (down) a steep slope and onto and un-level site.

* Suitable size

See remarks above regarding the need for a design statement which would address (a) whether the site was suitable and (b) what would be the appropriate size of the site.


* Availability

The land is available/ in public ownership and available for transfer to from WCC to WDC (and thereafter for sale) on request.

* Deliverability [and Conclusions]
In terms of timescale 'In theory, it should be possible to deliver
this site ahead of others as the land can be transferred easily' ( WDC comment)

8-Conclusion:

(a) there are key factors which indicate that the site is unacceptable (national policy, ecological, topographical, service availability, sustainability)

(b) there are key elements of information missing which mitigates against the sites further inclusion as a preferred site (flooding, design potential, archaeological significance) and

(c) that this site (with or without further information) presents itself as unattractive to a potential developer and should be removed from consideration as a 'preferred' site by WDC.