1. Introduction

Firstly may I apologise for not submitting an online consultation form. The process took longer than expected with multiple problems online hence the version by letter.

Part A

The information required in addition to my address is:
Telephone number: 01926 624455 / 07802 470896
Email: mark.griffin@expom.co.uk
Would you like to be made aware of future consultations on Gypsy Traveller sites - YES
Gender: Male
Ethinic origin: White British
Age: 45 - 54
Method of learning about consultation: newspaper

Part B

Commenting on the Gypsy and Traveller Site Options.

I would like to refer my comments specifically to the following sites:
GT05, GT06, GT09, GT10, GT12, GT15, GT16, GT17, GT18, GT20.

I would like to OBJECT to the proposal of all these sites for the reasons stated below. I have based my objections on the suitability and sustainability criteria used in the WDC consultation document.

* Site 16 - is actually the flood compensation area from the Barford bypass build and contains a permanent central pond and is unsuitable for any form of development. No one from WDC can have surveyed this possible location ahead of consultation.

* Sites 6 and 9 - sit immediately approximate to the Asps which Warwick District Council decided, after further research regarding the landscape and transport impact of development, that site should remain open due its value as a backdrop to the historic Warwick Castle Park. The Revised Development Strategy, therefore, excludes the Asps and should also exclude the adjoining sites 6 and 9 for the same reasons.

* Sites 5, 6, 9, 10, 12, 15, 16, 17, 18 and 20 - the sites are not sustainable in terms of multi modal accessibility. None of the sites offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycle routes, or by bus. The only means of accessibility is by car which would place further pressure on the local highway network infrastructure and is unsustainable.

* Sites 12 and 16 - sit within (part) and otherwise immediately adjacent to areas identified by the Environment Agency as having significant flood risk. Extensive flooding has taken place in both sites earlier this year.


* Sites 6 and 9 - These sites are situated on historic landfills which though closed may still have the potential to release greenhouse gases and are unsuitable for any form of permanent habitation and occupation.

* Sites 10 and 20 - These sites are situated adjacent to historic landfills which though closed may still have the potential to release greenhouse gases are unsuitable for any form of permanent habitation and occupation.

* Sites 5, 6, 9, 10, 12 and 16 - development would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and it's likely requirement to provide 70-90 new dwellings during the Plan period.

* Sites 12 and 16 - a number of residents have reported the existence of water voles in and immediately adjacent to these sites. Water voles are, of course, now a legally protected species.

* Sites 6 and 9 - there have been a number of reported wild deer sightings on this land and there is a population of deer that roam freely across the Castle grounds on to these 2 sites and beyond.

* Sites 12 and 16 - there is inadequate pedestrian crossing facilities for safe access into the village.

* Sites 5, 6, 9, 12, 16 and 20 - the development of all of these sites could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity of the sites.

* Sites 5, 6, 9, 12, 16 and 20 - WDC have disregarded their own Rural Area Policies, especially RAPs 1 (New Housing), 6 (New Employment), 10 (Safeguarding Rural Roads) and 15 (Camping and caravan Sites). In all respects the sites fail to meet the policy criteria to allow any form of development.

* Sites 5, 6, 9, 10, 12, 15, 16, 17, 18 and 20 - are not locations which allow peaceful and integrated co-existence with the local community.

* Sites 5, 6, 9, 12, 16 and 20 - development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (eg site 12) totally unviable.

* Sites 12 and 16 - vehicular access to these sites is from the A429 trunk road which was constructed as a bypass to Barford. It is a 60 mph speed limit road and there have been a significant number of accidents on it since its opening, including a fatality. The existing access into the sites is entirely inadequate.


* Sites 5, 6, 9, 10, 12, 15, 16, 17, 18 and 20 - vehicular access to these sites is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.

My general comments relating to ALL of the above sites are:

* WDC should have identified brownfield sites within the existing urban areas of Kenilworth, Warwick and Leamington for Gypsies and Travellers. These sites would be more suitable and sustainable, and would enable better integration in to the local community. Despite such sites existing, they are all being proposed for redevelopment for more valuable uses.

* WDC should consider allocating an area of land to the south of Warwick and Leamington including The Asps and Sites 5, 6, 9, 10 as Greenbelt to provide a 'buffer' to the proposed developments to the south of Warwick and Leamington and/or to extend the proposed Bishops Tachbrook Country Park as far as the Banbury Road near to Warwick Castle Park. This would ensure the villages in the south of the District retain their identity and are not 'swallowed up' by Warwick and Leamington over time.

* Availability - only 3 of the sites listed are available, namely sites 15, 17 and 18. By definition the remaining sites are not deliverable. A compulsory purchase order would be extremely lengthy, costly and unviable compared to other options.

* WDC should be requiring Gypsy and Traveller sites are delivered within the proposed major new housing developments in Kenilworth, Warwick and Leamington where 12,300 houses are proposed. This would ensure that the sites could be properly designed in a sustainable fashion and be fully integrated into a local community which will provide facilities such as a school, a doctors surgery and shops which are accessible on foot, on bike, by bus and by car.

* WDC should revisit its Greenbelt Policy and release sites to the north of Warwick and Leamington which would reduce the pressure to allocate land for all forms of development during the new Local Plan period to the south of the District.

* Ecology and Environment - all of the sites have some ecological value and environmental issues which does not appear to have been assessed.

The consultation document published by WDC June 2013 misrepresents proposed size and visual impact of a completed site! Pictures used on page 3 and page 4 are from holiday caravan sites. The proposal of each pitch being 500 sqm each in size is omitted from the document and is misleading. Approved, licenced Gypsy and Traveller sites do not look like that in WDC 's consultation document.

Can you pleased confirm receipt of this response for my records.

see-attached

I would expect a 'high level appraisal' to contain accurate facts. With regard to one of the sites mentioned, a neutral rating is given by Enfusion including an assertion that the site is close to a GP Surgery (within 1.5 miles). It is not. The closest GP surgery, is more than twice that distance away (3.3 miles), and a single phone call would confirm that that particular surgery is closed to new patients. The next closest is 4.7 miles away.
A 'high level appraisal' would compare like with like. One site is given a positive rating for travel and transport as there is access to a bus stop. Another site is also given a positive rating for having access to a bus stop. One of those bus stops however is in an overgrown grass verge in a rural location on a dangerous road, with no pavement or street lighting. The other is sited on a far safer road, with a pavement. On the surface they are comparable, but in reality they are far from it.
Having only been involved with looking in detail at one site, I cannot comment on any other inaccuracies that may be contained in the document, but I am not filled with confidence that there are not more basic errors in the report, or that comparisons are uniform across the different sites.

I do appreciate that at this stage the appraisal cannot be more detailed but I would expect 'like' to be compared with 'like' in order to make an informed comment with regard to relevant factors. And I would certainly expect basic facts to be correct.

In my particular area of interest alone, there has already been one lost house sale and a demonstrable loss of future business as a direct result of this small element of the Local Plan. There are also many of those most directly affected whose lives have been thrown into complete chaos by the proposals, and this effect will undoubtedly multiply out across the various proposed sites, whether they are Gypsy and Traveller related or simply with regard to proposed new housing.

Whilst this will always be a predictable consequence of any such report, I would have thought that, given the devastation that is currently being caused in the lives of many local residents, the Council and its chosen supplier(s) would at least have due regard for its effects by ensuring the highest possible level of accuracy.

However this, coupled with the council's blatantly misrepresentative brochure, would suggest that sadly that is not the case. The local taxpayer deserves better.