1. Background

we are against these sites in their entirety, and I would like to question some of those responses, and in particular, as to why the council haven't seen fit to provide a presentation for Warwick Gates? We do not live at Chase Meadow, as suggested, and this is not a suburb of Bishops Tachbrook.

The case you so eloquently make would suggest we should have a presentation?

I personally, and please don't take offence, do not understand why a senior council planner, who doesn't come from this area, presides over answering objections to a LOCAL plan? I will be contacting my local councillor, if only to ask that.

It is good to know that these sites will be owned by those residing there. They may just look after them better than the areas they camp on illegally.

The Council website, which you refer to, for preferred option 15 for gypsies and travellers suggested that these travellers could have access to future locally sited schools, a little presumptuous don't you think? Any build in this area is not, to my knowledge, a done deal, is it? So how safe is the information on this site? Given the current "LOCAL PLAN" situation, I feel a little more sensitivity, when responding to general local concerns, would go a long way (thanks for pointing out my numbering mistake in my first correspondence).

I believe you were correct, I don't think you should have responded to item 6. The fact that you are not from this area gives you no forum to air your views over our local concerns but I will take your, unsupported, comments on board.

I will be contacting my council representative to place my objections but funnily enough that is what I thought this process was for?

This Parish Council does not object to any of the proposed gipsy and traveller sites outlined in the current consultation but maintains that only areas which their owners wish to sell should be used and that no compulsory purchase arrangements should be employed.

We have studied the various proposals and we have listed our preferences in no specific order since it is clear that many other factors will have to be taken into account before a final decision is reached. However we disagree strongly that children of these people should be given priority over local children even if they come in from surrounding areas. To give this priority is tantamount to giving permission for long stay - or permanent stays - which we understand is not what these sites are for. I assume that users of these sites will pay an economic rent for their use and will not simply be a ' drain ' on the county's already stretched resources.
GT alt 01. GT 08. GT alt 03. GT 15. GT 17.

Thank you for the opportunity to provide feedback to the proposed consultation.

Network Rail is the "not for dividend" owner and operator of Britain's railway infrastructure, which includes the tracks, signals, tunnels, bridges, viaducts, level crossings and stations - the largest of which we also manage. All profits made by the company, including from commercial development, are reinvested directly back into the network.

Network Rail has no comments to make.

You say you have to provide these sites the evidence having been gathered by Salford University whose used gypsies to do the ground work. York City checked the evidence and rejected it.
Make sure you have your facts right as there is only a requirement to provide sites if there is a PROVEN need. You are affecting many more people by providing sites than not providing sites.
You say your suggested sites are because of the Green Belt and ask for alternatives. Ordinary people do not know the alternatives so why are you not telling us?
You are supposed to be our friends not our keepers. If there are no alternatives your preferred options enquiry is a PR exercise.
Support your residents.
Surely that is what you are there for.

I can't believe that this many sites are needed by travelers. These people choose to travel so why the need for a permanent site. They do nothing but cost US the tax payers money and now we have to have our money spent on making them happy . There are numerous sites like on the a45 and a46 like the old little chef sites where could be used for these free loading gypsies away from any tax paying communitys that will end up suffering. I think the council need to wake up and spend there budget on things the tax payers need !!!

Gypsies and travellers should not be given any sites. I'm fed up of subsidising these spongers who expect special treatment and rights because they can't be bothered to put anything into society but just take instead!
> I'm sure you're a hand wringing, limp wristed liberal who finds my opinion highly offensive and i'll be expecting a visit from the thought police soon, but this is my opinion and i'll stand by it.
> I'm sure you'll ignore my response, as i'm sure you will ignore the majority of responses that do not fit within the councils politically correct ideology. These pathetic response requests will make no difference to the outcome, the wonderful, law abiding travellers will get their nice green belt site like they always do.

I would like to formally object to the location of the Gypsy/Traveler site being located at "GT18 Service area east of A46 Old Budbrooke Way".

I have logged my reasons via the petition site.

Once again, and as you did during last years consultation, you have failed to organise a drop in session at chase meadow. There are a lot of people living here who you seem to want to avoid engaging I this process, yet one of your preferred sites is right next to chase meadow. I suggest you sort it out and arrange a suitable drop in session and add it to your list of sessions, you could perhaps try and arrange one at the community centre.

MPs decide that Councils should do something for these 'Travellers' but conveniently forget to consult those who will actually foot the bill - the Local Council tax payers.
The local Councillors also fail to ask the tax payers if they should meekly accept the demand. Instead they attempt to place ownership for these unacceptable proposals onto the local taxpayer, by asking them to pick what amounts to a fait accompli.
The council should provide a site only if the Gypsies (which many aren't) and travellers pay their council taxes; and site charges equivalent to those I have to pay for my touring caravan, on Caravan Club sites. Also, if they want health and welfare facilities, schools and hospitals then contribute by paying taxes as we all do.
Travellers expect all the benefits from society yet accept none of the responsibilities.
They have chosen to opt out of society. They have therefore opted out of any benefits that are associated with that society and ought not to receive any hand-outs, financial or otherwise, from those of us who pay our dues.
Why should I, as a house owner, have to subsidise their chosen lifestyle - especially as the majority are financially better off than most (check out their very expensive 4 x 4 vehicles, and equally expensive caravans).
Our Council should stand up for the local tax payers, and refuse to implement this dictat from central government, or risk the wholesale shedding of Councillors at the next electoral opportunity.

AIM- should make their own assessment - FAILED - clearly an outsourced, arms-length study - NOT OBJECTIVE.
AIM - authorities, working collaboratively, develop fair and effective strategies - FAILED - no realistic collaboration with settled communities - definitely NOT FAIR.
AIM - includes fair, realistic and inclusive policies - FAILED - the vast majority of proposals cannot be inclusive for multiple reasons.
AIM - reduce tensions between settled and traveller communities - FAILED - the amateur, superficial and lazy initial stages have merely stoked concerns on both sides.
AIM - provision of suitable accommodation - FAILED in many/most of the proposals

I wish to make representations specifically about proposed Traveller site GT12 and also generally about the manner in which this process has been carried out.

Firstly regarding GT12. I am a resident of Westham Lane. This previously idyllic rural location, which has no mains drainage or mains gas has been blighted over the last few years by the activities of the Council on the basis of the greater good for the many while damaging the lives of we few who live on the west of Barford. We have had our lifestyles permanently damaged, without compensation, by the building of the bypass. Our properties have been devalued by the noise, visual intrusion and increased traffic on the bypass. We do not have the benefit of the usual council road and other utility services, while still paying huge rates due to the alleged value of our properties. Numerous Road Traffic accidents have occurred on the bypass and it is dangerous to get out of the lane onto the bypass. Access to Westham Lane is dangerous for the few vehicles that currently use it. Access for slow-moving articulated and towing vehicles is simply not viable.

Now this latest unlooked-for intrusion of proposing to put permanent sites for "travellers" close to our homes has been dreamt up out of nowhere simply because we live in an isolated rural spot. Does nobody spot the contradiction in terms of "permanent" sites for "travellers"? All of the objections to the many proposed sites point out the increased crime statistics near such sites. It is against the human rights of the fixed community to inflict this intrusion on them.

As the whole site is bounded by the river Avon, containing extensive natural flood plains which do flood every year to a great extent, with concomitant greater danger to temporary homes and caravans, the only viable area which has a reduced chance of flooding is the higher "spine" of land which Westham Lane follows out to our properties. The land falls away on both sides down to the river. The livestock farm has just one field on the south side for the sheep to retreat to and the arable farm floods well up into the crops every year.

Any site will therefore be extremely visually intrusive from either direction on the bypass as it cannot be located far from Westham Lane. There is no vegetation at all providing any screening.

There is no drainage on the West side of Westham Lane. All of our properties have soakaway drainage or septic tanks. This would not be an option for the proposed site, with large numbers of people. The water table is (obviously) very high and this form of sewage/waste disposal would be hazardous to health and would pollute the river.

It would be an inappropriate and exorbitant cost to provide mains drainage to the site, with the bypass between the drainage system and the proposed site, and would not be considered at council expense for our dwellings.

Similarly, there is no mains gas provision for any dwellings on Westham Lane. The huge expense of providing this for the "Traveller" site, due to the bypass, should again be considered unacceptable.

I have previously raised the issue of the Bronze Age remains in many places on the proposed site but apparently this is irrelevant.

These are issues specific to GT12 but I wish to associate myself with most of the objections raised by other objectors about the other sites.

If provision must be found it should be in small, remote, well-screened sites away from other dwellings as far as possible, to prevent the "rights" of "travellers" from trumping the rights of local, settled home owners who have worked to pay for their homes and whose lives and financial futures must not be damaged by this proposal.

Generally, the way the Planning Department has gone about this process should be the subject of an inquiry in itself. Many comments refer to the scatter-gun approach. This lengthy farce has already blighted, and continues to blight, the lives of thousands of home owners. The sites which have been considered but now dropped demonstrate the inadequate work which had been carried out before their inclusion and many of those which remain, such as GT12 are, likewise, immediately identifiable as being unsuitable.

Please acknowledge receipt of this objection and confirm that it will be included in the consultation.

One of the key requirements of the Government's "Planning policy for traveller sites" is to co-operate with travellers, their representative bodies and local support groups and early and effective community engagement with both settled and traveller communities.
There is no evidence to suggest that any of the proposed allocations or reserve sites have been discussed with traveller communities.

This is particularly pertinent in light of the fact that the Council does not intend to own or manage Gypsy & Traveller sites itself but intends for the Gypsies and Travellers to purchase the sites themselves. The consultation document only states that this decision has been reached by observing the experience of other Local Authorities, as opposed to meaningful discussion with the Gypsies and Travellers themselves of even the other Local Authorities from whose experience they refer.

I would like to object to the plans for 2 gypsy/ traveller sites on the edge of Harbury.

1. Why are we expected to give land to certain people on which to put their caravans ? Can they not finance and provide for themselves as I do?

2. I strenuously object to land at Leamington Football Club being given away as this is going to end up causing massive extra expense for WDC in ultimately WDC having to provide new quarters for the Football Club.

3. I strenuously object to you targeting land at the Exhibition Centre on the Fosse Way. Do you not realise that this is going to interfere with a business that has been carefully developed over many years and which provides jobs and entertainment in the area ?

4. Both sites are traffic accident hotspots and not suitable for families possibly with young children, or teenagers on bicycles.

5. There are so many more suitable and worthy causes we would all like to see our council tax money spent on in these difficult financially lean times.

6. Which of the over-subscribed schools in the area do you intend to send their children to ?

7. Is there some reason you have chosen sites right on the extreme edge of Warwick District Council ? Is it so that Stratford District Council will have to pick up the costs of education and health-care ?

8. Providing such sites creates the possibility of attracting more travellers to the area and creating more and more expense. We should not have to finance people just because they choose an unconventional life-style.

I write in objection to ALL the proposed preferred option sites for Gypsys and Travellers.

1. The number of sites being proposed is in question and 31 is considered too high. This needs to be validated and agreed before any further steps are taken.

2.The sites proposed are "permanent" pitches and I do not believe this is what the public or travelling community require.

3.Maintaining permanent sites practically and financially will be virtually impossible if not completely impossible in respect of collecting council tax, rent etc.

4.A far better solution for to address the issue would be to provide "transition" sites funded by the council. These could be used on a continual basis rather than by a single family. These sites could be located away from existing and new housing developments which is most likely to the benefit of both the Travelling community and local residents.

5.Whatever is done it will not stop the ad hoc sites springing up regularly in our local roads. However transition sites would certainly have more impact on preventing this occurance.

Please review your strategy before going down an incorrect and costly path that cannot be maintained functionally or financially in a cost effective manner.
If Travellers want "permanent" sites then they should seek affordable accommodation.

Further to your below email and the Consultation on the Preferred Options Sites for Gypsy and Travellers deadline of Monday 5th May, I refer you to my below comments and objections.

2. History: How we got to this point

2.4 -OBJECT

the assessment from Salford University contains no adequate "demonstration of the need for 31 pitches", the public was not consulted in its production and as the sole basis of the Council's policy, it is unreliable and unsound.


2.7 -OBJECT

No adequate rationale has been given for the Council not owning or managing the sites. The Council is presenting conjecture as fact which is unsound.

There is no explanation, crucial at this stage, of who the Council would sell sites to. Will the sites be widely available? What guarantees are there that the Council will fulfil its obligations to achieve best value?

The Council needs to retain accountability for managing and controlling the sites and securing all relevant planning consents. This could possibly be achieved through a registered social landlord.


2.8 - OBJECT

The sentence "extending the number of pitches on a site would be subject to a planning application and sites would then be assessed for any constraints and restrictions" seems to leave open the possibility of adding the number of pitches at a later date through the planning process not only a possibility but also exposes this entire process to abuse and manipulation and offering local residents no certainty.


2.10 - COMMENT

The GTAA was actually published in November 2012, so this does not bode well for the professionalism or competence of the Council's approach.


2.13 - COMMENT

The public deserves more information on why conversations with neighbouring authorities over several years have not yielded any results.

3. Warwick District - Context


3.5 - OBJECT

The NPPF requires "exceptional" circumstances, not special. This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should not be promoting any green belt site above any non green belt site.

I was assured by you in your email of 30 July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need."

3.6 - OBJECT

The NPPF requires "exceptional" circumstances, not special. This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should not be promoting any green belt site above any non green belt site.

I was assured by you in your email of 30 July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need."

6. Criteria

6.3 - COMMENT

A fundamental flaw in this draft policy is that there is no explanation of why some 'green' sites are in Preferred Sites and others are Alternative Sites. You should be more transparent.

7. Sites Summary Table

GT19 - OBJECT

Against the Council's own criteria in section 6.1, GT19 fails on the following points.

1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.

Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.

7 Sites which can be integrated into the landscape without harming the character of the area. Site development will accord with national guidance on site design and facility provision FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.

8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
10 Reflects the extent to which traditional lifestyles (whereby some travellers live and work-from the same location thereby omitting many travel to work journeys) can contribute to sustainability


In addition, the commentary and treatment for this site is very one-sided. Firstly this is true as a standalone because factors mentioned in the full site assessment are omitted from the policy document. Secondly there is great inconsistency in the commentary on factors across different sites, which seriously undermines the soundness and confidence in the Council's approach.

For example (referring to the commentary on page 22):

"Site area reduced to avoid other existing uses and retain viability of remaining unit" There is no proof or even indication that this will be the case

"Possible use of existing access points" There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.

How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?

"Services available on site as currently used by Caravan and Camping Club" This is spun as a factor supporting GT19 as a Preferred Site. How does this compare with the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?

The following key points have not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:

1) The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this, why has GT19 therefore been proposed as a preferred site?
2) Possible flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly.
3) Part of the site is within high flood risk Zone 3. The proposed site is 0.3 acres in size. With part being within a high flood risk Zone- why does it therefore remain a preferred option?
4) Ecological factors being adjacent to the canal, and the Council's own plans show that this land has a high sensitivity to housing development.
5) Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
6). GT19 is adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
7) The Council recently rejected the proposed development of a similar site owned by Mr Arkwright further west along the Birmingham Road. The Council's reasoning's were sound and should be reiterated on this site.
8) Reference to the site being located within the Green Belt have been included - however the reference that it has been "previously developed land" is misleading. The previous use of the land was for agricultural purposes.

8. Preferred Options for Consultation

PO1: Meeting the Requirement for Permanent Pitches - OBJECT

A fundamental flaw in this draft policy is that there is no explanation of why some 'green' sites are in Preferred Sites and others are Alternative Sites.

There is also great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.

For example:

GT19 - "Services available on site as currently used by Caravan and Camping Club " has been presented as a positive factor.

By comparison:

GTalt22 - "As a Caravan and Camping Club site, this use would not be suitable"

GT19 - Within the Detailed Gypsy and Traveller Site Assessments it has been noted that "the site is adjacent to the Grand Union Canal Local Wildlife Site." This comment has not been included within Section 7 and the site remains a preferred option.

By comparison:

There are numerous other sites including GTalt20 and GTalt23 where the sites have proximity to a LWS in the form of a canal. This information has been included within the commentaries in Section 7.

You are not fully representing the situation by omitting this information.

GT19 - there is no mention that Mr Butler, the current owner of GT19, is not prepared to sell the land to the Council. A fact which he has told all Hatton Park Residents - and was confirmed by Clare Sawdon in the recent Hatton Park Action Group meeting of March 2014.

By comparison:

Sites GT02, GT05, GT06, GT08 and GTalt12, all in the alternative sites list, all say "the land owner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward."

You are not fully or fairly representing the situation by omitting this information.

GT19 - part of the site is within high flood risk Zone 3. The site is 0.3 acres in size - with part being within a high flood risk Zone- why does it therefore remain a preferred site?

By comparison:

Sites GTalt20 and GTalt23 have close proximity to a canal and are subject to flooding/surface flooding, but are not located within high flood risk zones - but are deemed inappropriate sites.

Many other sites are noted as being located within high flood risk zone 3 - but all are deemed inappropriate sites.

The above issues seriously undermine the soundness and confidence in the Council's approach to deeming a site their "preferred" option.


9. Summary of Preferred Option Sites

GT19 (p.42) - OBJECT

Against the Council's own criteria in section 6.1, GT19 fails on the following points.

1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.

Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.

7 Sites which can be integrated into the landscape without harming the character of the area. Site development will accord with national guidance on site design and facility provision FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.

8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
10 Reflects the extent to which traditional lifestyles (whereby some travellers live and work-from the same location thereby omitting many travel to work journeys) can contribute to sustainability

In addition, the commentary and treatment for this site is very one-sided. Firstly this is true as a standalone because factors mentioned in the full site assessment are omitted from the policy document. Secondly there is great inconsistency in the commentary on factors across different sites, which seriously undermines the soundness and confidence in the Council's approach.

For example (referring to the commentary on page 22):

"Site area reduced to avoid other existing uses and retain viability of remaining unit" There is no proof or even indication that this will be the case

"Possible use of existing access points" There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.

How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?

"Services available on site as currently used by Caravan and Camping Club" This is spun as a factor supporting GT19 as a Preferred Site. How does this compare with the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?
"Urban feel" This is subjective.
"A habitat buffer would be required"
Why it is not mentioned that the site is adjacent to Grand Union Canal Local Wildlife Site?
"Subject to agreement with the landowner, this site could be delivered within 5 years."
As the site is not readily available, why is this a Preferred Site?

The following key points have not been mentioned in the commentary within Section 9 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:

1) The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this, why has GT19 therefore been proposed as a preferred site?
2) Possible flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly.
3) Part of the site is within high flood risk Zone 3. The proposed site is 0.3 acres in size. With part being within a high flood risk Zone- why does it therefore remain a preferred option?
4) Ecological factors being adjacent to the canal, and the Council's own plans show that this land has a high sensitivity to housing development.
5) Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
6) GT19 is adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
7) The Council recently rejected the proposed development of a similar site owned by Mr Arkwright further west along the Birmingham Road. The Council's reasoning's were sound and should be reiterated on this site.
8) Reference to the site being located within the Green Belt have been included - however the reference that it has been "previously developed land" is misleading. The previous use of the land was for agricultural purposes.


10. Summary of Alternative Sites - COMMENT

Why are no photographs of these sites provided, unlike for the preferred sites in section 9? This is arguably prejudicial.

I look forward to receiving your comments on the above and confirmation that my above representation has been received and logged.

Yours faithfully
Dear Mr Smith
This is to confirm that your email has been received and retained as your representation to the consultation on the options for sites for Gypsies and Travellers.
You have made a couple of comments which you would like us to address. Firstly, the sites that are in the 'options' consultation booklet are all there because they have either been promoted to us by landowners, suggested to us by others or are 'areas of search' within which we think it may be possible to identify an area of land that would be suitable for this use. We have not identified which of these are in the green belt (although the map on pages 12/13 gives an overview) because at this stage of the work, we want to draw out comments from others before more work is carried out to assess sites in greater detail with a view to taking the most suitable sites forward into the next consultation. Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need.
Whilst adjacent local authorities have rejected the invitation to discuss this issue with them in the past, a dialogue has been re-established with Stratford District Council and Rugby Borough Council and we are more hopeful that we can co-operate with these authorities at least in coming to some agreement about sharing sites or council's providing sites within their boundaries for those who have no potential for sites or insufficient sites. Each district has its own need to address and provide for.
The sites that we are looking to establish are for permanent pitches i.e. in a similar way to the settled community in that a family will reside on a permanent basis on their pitch. They will only 'travel' to find work or to visit family, holiday etc.
Your site by site comments are noted.
Yours sincerely
Lorna Coldicott
Please find below my various representations with regard to the proposed site options.

In line with the report I wish to make representations on a number of points as detailed below.

1. Introduction

No comment

2. Background

No comment

3. Who are Gypsies and Travellers?

No comment

4. What are the Issues?

No comment

5. Policy Background

SUPPORT

National policy is correct in advocating that (1) local planning authorities work together to identify sites and (2) that decision-taking protects Green Belt from inappropriate development and makes enforcement more effective.

On Point (1) it is therefore extremely worrying that Warwick District Council (WDC) is no longer working with other authorities to consider plans on a cross-authority basis, which it has a duty to do under the 2011 Localism Act. On point (2) WDC makes no distinction between Green Belt and non-Green Belt sites in its policy criteria so again contradicts national policy.

6. Evidence Base

No comment

7. Local Plan Requirements

OBJECT

The policy criteria listed by WDC are sensible.

However they omit crucial aspects of national guidance including (1) that plan-making and decision-taking should protect Green Belt from inappropriate development and (2) sites must be in appropriate locations. Why?

There is also the fact that WDC is no longer working on a cross-authority basis to provide sites. Again, why when much of WDC is covered by Green Belt (80%)? Surely by definition travellers are nomadic and the requirement for pitches should not be restricted to Warwick District?

8. Identification of Potential Sites

OBJECT

Section 8.1 is inadequate. WDC should list all sites within it's ownership and explain why it considers each site to be unacceptable.

Section 8.3, in which WDC is seeking to identify sites itself is a total dereliction of its duty under the 2011 Localism Act. WDC contains a high proportion of Green Belt and the Council should be looking to share supply of sites in appropriate locations with other authorities.

Site listing criteria should distinguish first whether locations are appropriate according to national and local planning policy. This is a planning document and land ownership (and willingness to sell) should not be a concern due to CPO powers.

9. Sites for consideration and comment
10. Table of Sites

GT01 Land adjacent to the Colbalt Centre, Siskin Drive

No Comment

GT02 Land abutting the Fosse Way at its junction with the B425

No comment

GT03 Land at Barnwell Farm

No comment

GT04 Land at Harbury Lane, Fosse Way

No comment

GT05 Land at Tachbrook Hill Farm

No comment

GT06 Land at Park Farm, Spinney Farm

No comment

GT07 Land at Stoneleigh Road

No comment

GT08 Depot to the west side of Cubbington Hill Farm

No comment

GT09 Land to the north east of M40

No comment

GT10 Land at Tollgate House and Guide Dogs National Breeding Centre

No comment

GT11 Land at Budbrooke Lodge, Racecourse and Hampton Road

No comment

GT12 Land north and west of Westham Lane (area of search)

No comment

GT13 Kites Nest Lane, Beausale

OBJECT

Kites Nest Lane, Beausale is totally inappropriate as a site for this purpose because:

1. It is a greenfield site in the open countryside within the Green Belt and any use for this purpose (or residential etc) is inappropriate development. The National Planning Policy Framework protects the Green Belt from inappropriate development.

2. Adopting it as a possible site would legitimise the long-running unauthorised applications to impose this illegal use at this site. WDC has rightly objected to such applications (although achieved nothing in removing the illegal settlement) and allowing development through this process would set an extremely damaging precedent in this and other areas that will attract significant public disapproval. National policy supports effective enforcement against unauthorised developments.

3. Access to local services is limited.

4. Its rural location means that this use cannot be integrated in the landscape without harming the character and amenity of the area in terms of aesthetic appearance and noise.

GT14 Warwick Road, Norton Lindsey

No comment

GT15 Land east of Europa Way

No comment

GT16 Land to north of Westham Lane and west of Wellesbourne Road, Barford (small site)

No comment

GT17 Service area west of A46 Old Budbrooke Way

No comment

GT18 Service area east of A46 Old Budbrooke Way

No comment

GT19 Land off Birmingham Road, Budbrooke, Oaklands Farm

OBJECT

Land at Oaklands Farm, Birmingham Road is totally inappropriate as a site for this purpose because:

1. It is in the Green Belt and any use for this purpose (or residential etc) is inappropriate development. The National Planning Policy Framework protects the Green Belt from inappropriate development.

2. Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.

3. It is adjacent to the Grand Union Canal running locally between Warwick and Hatton offering views of Warwick Castle and St Nicholas Church.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

This is a very popular towpath for boaters, walkers, runners and cyclists alike whose amenity will be greatly impacted by the occupation/development of this site.

Its location will further impact on the visual amenity of the Grand Union Canal.

4. The site may be prone to flooding due to its location next to a water network.

GT20 Land at Junction 15 of M40

No comment

Do you have any other suggestions for land within this district that you think would be suitable for use as a Gypsy and Traveller site?

No comment

I look forward to receiving your comments and trust that the Council will make a well informed and well researched decision when it comes to sites to be considered in greater detail.

Yours faithfully


John Smith

I wish to OBJECT to the proposed Gypsy and Traveller preferred site GT04 Land at Harbury Lane, Fosse Way.


I have listed my comments and concerns below which are:


* 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 of the report and /or the relevance of the established need.
* The WDC consultation does not consider as required the existing capacity of current sites within Warwickshire county and adjacent districts.
* The GTAA ignores the impact of the planned Transit site near Southam which has been agreed since completion of the GTAA
* According to the Government's planning policy framework, adjacent DCs are required to collaborate, and yet Warwick DC and Stratford DC are very much out of phase with their consultations so logically they cannot collaborate. Further there is no evidence that WDC has collaborated or discussed with Stratford DC other than a reported "10 minute long but un-minuted meeting" or with Rugby DC
* There is no evidence in WDC's consultation report that as required by NPFF and CLG , that WDC have weighed up the cost to council of Compulsory purchase vs development of underutilised brownfield sites including those that the council already own.
* The WDC proposals will provide for more accommodation than there are G&T residents within WDC boundary the vast majority of whom already live in houses so the requirement is clearly seriously over-stated
* There is clear evidence via Hansard that MP's now want a fair planning policy that should result in the abolition of the G&T planning requirement
* There has been little (and passive) publicity of the Consultation process and key milestones. Had it not been for the local Community group I would not have known about it - it feels and looks like this is a deliberate underhanded approach. On this point I am particularly unimpressed by the council officer at the consultation meeting who considered that handing out leaflets to a member of the residents association for distribution then failing to follow up that the leaflets had been delivered. The excuse that the leaflet drop was to be completed by a volunteer does not constitute absolve the council or its officers from the responsibility of delivering the leaflets or for the need to manage the action. The statement by the officer that the council could not manage a volunteer shows an appalling lack of understanding and judgement. At the very least the officer should have telephoned the volunteer to check on progress and made appropriate plans based on the feedback. In my view this is negligence and deserves disciplinary action for the staff concerned!


Specific to Site GT04:
* The site does not meet the fundamental planning criteria laid out in the NPPF, guidance from Department of Communities and Local Government and WDC's own consultation documents for Gypsy & Traveller sites. GT04 does not comply with planning policy whereby sites should provide access to nearby services and quality of life.
Specifically:
o Accessibility to shops and local services: GT04 does not meet national planning framework guidelines recommended 5-10mins walk on a pavement. There are no pavements in the location of the proposed site!
o Proximity to local community: GT04 does not meet the national planning framework guidelines recommendation for sites to be on community periphery to encourage integration.
o Establishing 5-10 pitches at GT04 would be disproportionate to the local community (8 residential properties, with 16 adults and 4 children). This is contradictory to national planning framework guidelines recommendations.
o GT04 does not meet national planning framework guidelines recommendations for accessibility to good local transport.
o GT04 does not meet national planning framework guidelines recommendations for availability of good infrastructure (roads, pavement, street lighting, broadband, cellphone reception).The infrastructure at GT04 is poor and would require considerable investment to rectify. And this is an expense that WDC should not incur during times of cutbacks in public expenditure and services.
o The area is prone to flooding with Harbury Lane and surrounding fields are often under water. In accordance with planning and building regs, GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based and will require connection to mains sewerage which does not exist in Harbury Lane.
o Planning policy for G&T requires schools / GP surgeries to be a 5-10 minute walk away, GT04 is at least a 45 minute walk away.
o The nearest GP surgery is three miles away
o The nearest GP surgery is operating at its maximum at capacity.
o The nearest primary, junior and senior schools are already at capacity.
o GT04 is located on Harbury Lane and Fosse Way cross roads that is a high risk travel route with high volumes of traffic and an increasing number of accidents. Speed cameras and warning signs highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to school if indeed such transport exists
o According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This raises serious environmental and health concerns, and was a primary reason that the potential G&T site at Barnwell farm was previously rejected. Simply -Barnwell chicken farm can smell awful and GT04 would not be a good place to live
o GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and which would make GT04 an unpleasant place to live but also an unhealthy one.
o The NPFF requires that the assessment of site suitability should be consistent with other planning requests. However I understand that other residential planning applications within 200m of GT04 have been recently rejected by council planning authorities, referencing rural policy on the grounds that the proposal would have an adverse "impact on the character of the area".
o The costs to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's figures (£65k per pitch). In addition to this, GT04 site may require relocation of Football club. There is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that G&T can and will buy and develop it. Also WDC should not fund the relocation of the Football Club in the event of a compulsory purchase. This does not represent good taxpayer value.
o GT04 is an area of good quality farmland fully utilised for livestock and arable farming.
o GT04 will lack of Integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire
o The proposed site will have an adverse visual impact from Harbury and The Fosse Way (Roman Road).
o If GT04 were to be developed, the use of a vehicle or public transport to shops and schools is a necessity and not considered eco-friendly and is likely to overwhelm the available parking creating further road safety issues
o The site will have a detrimental impact on tourism and visitors to Warwickshire especially including Mallory Court Hotel and a consequential effect on local employment.
o The site will damage wildlife habitat.

I wish to object to the Gypsy and Traveller preferred site GT04 Land at Harbury Lane, Fosse Way.

My comments and some of my concerns are as follows:

- 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 of the report and /or the relevance of the
established need.
- The WDC consultation does not consider as required the existing capacity of current sites within
Warwickshire county and adjacent districts.
- The GTAA ignores the impact of the planned Transit site near Southam which has been agreed
since completion of the GTAA
- According to the Government's planning policy framework, adjacent DCs are required to
collaborate, and yet Warwick DC and Stratford DC are very much out of phase with their
consultations so logically they cannot collaborate. Further there is no evidence that WDC has
collaborated or discussed with Stratford DC other than a reported "10 minute long but un-minuted
meeting" or with Rugby DC
- there is no evidence in WDC's consultation report that as required by NPFF and CLG , that WDC
have weighed up the cost to council of Compulsory purchase vs development of underutilised
brownfield sites including those that the council already own.
. - The WDC proposals will provide for more accommodation than there are G&T residents within
WDC boundary the vast majority of whom already live in houses so the requirement is clearly
seriously over-stated
- There is clear evidence via Hansard that MP's now want a fair planning policy that should result
in the abolition of the G&T planning requirement
- There has been little (and passive) publicity of the Consultation process and key milestones. Had
it not been for the local Community group I would not have known about it - it feels and looks
like this is a deliberate underhanded approach.

Specific to Site GT04:

- The site does not meet the fundamental planning criteria laid out in the NPPF, guidance from
Department of Communities and Local Government and WDC's own consultation documents for
Gypsy & Traveller sites. GT04 does not comply with planning policy whereby sites should provide
access to nearby services and quality of life. Specifically:-
- Accessibility to shops and local services: GT04 does not meet national planning framework
guidelines recommended 5-10mins walk on a pavement.
-Proximity to local community: GT04 does not meet the national planning framework
guidelines recommendation for sites to be on community periphery to encourage integration.
-Establishing 5-10 pitches at GT04 would be disproportionate to the local community
(8 residential properties, with 16 adults and 4 children). This is contradictory to national
planning framework guidelines recommendations.
- GT04 does not meet national planning framework guidelines recommendations for
accessibility to good local transport.
- GT04 does meet national planning framework guidelines recommendations for availability
of good infrastructure (roads, pavement, street lighting, broadband, cellphone reception).The
infrastructure at GT04 is poor and would require considerable investment to rectify. And this is an
expense that WDC should not incur during times of cutbacks in public expenditure and services.
- The area is prone to flooding with Harbury Lane and surrounding fields are often under water.
In accordance with planning and building regs, GT04 would be unable to use soak away or runoff
based drainage systems since the soil is clay based and will require connection to mains sewerage
which does not exist in Harbury Lane.
-Planning policy for G&T requires schools / GP surgeries to be a 5-10 minute walk away, GT04 is at
least a 45 minute walk away.
- The nearest GP surgery is three miles away
- that GP surgery is at capacity.
- The nearest primary, junior and senior schools are already at capacity.
- GT04 is located on Harbury Lane and Fosse Way cross roads that is a high risk travel route with high
volumes of traffic and an increasing number of accidents. Speed cameras and warning signs
highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to
school if indeed such transport exists
- According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This
raises serious environmental and health concerns, and was a primary reason that the potential G&T
site at Barnwell farm was previously rejected. Simply -Barnwell chicken farm can smell awful and
GT04 would not be a good place to live
GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and
which would make GT04 an unpleasant place to live but also an unhealthy one.
- The NPFF requires that the assessment of site suitability should be consistent with other
planning requests. However I understand that other residential planning applications within
200m of GT04 have been recently rejected by council planning authorities, referencing rural
policy on the grounds that the proposal would have an adverse "impact on the character of the
area".

- the cost to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's
figures (£65k per pitch). In addition to this, G04 site may require relocation of Football club. There
is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an
alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that
G&T can and will buy and develop it
- GT04 is an area of good quality farmland fully utilised for livestock and arable farming.
- GT04 will lack of Integration into the landscape and would spoil the views from Chesterton
Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire
- The proposed site will have an adverse visual impact from Harbury and The Fosse Way (Roman
Road).
- If GT04 were to be developed, the use of a vehicle or public transport to shops and schools is a
necessity and not considered eco-friendly.
- The site will have a detrimental impact on tourism and visitors to Warwickshire especially including
Mallory Court Hotel and a consequential effect on local employment.
- The site will damage wildlife habitat.

I write to you on the 2nd April re the proposed Travellers' sight on Birmingham Road.

I have received no reply so I am resubmitting it by email. Your acknowledgement would be appreciated.

Proposed Traveller Site at Oaklands Farm, Birmingham Road, Hatton, Warwick ref GT19

I have looked at your Local Plan document dealing with sites for Gypsies and Travellers and am dismayed to see that the above sight is considered to be a Green site.

Along with many other people, dog walkers, runners, walkers, cyclists and visitors generally I use the canal towpath for exercise and enjoyment. To consider putting a travellers' site right next door to the canal seems to me to be totally inappropriate. The Hatton Flight of locks is a very well known local landmark and tourist attraction and you are considering ruining it by placing such a site next to it.

Many users of the towpath use it in the evening and failing light to avoid having to use the dangerous Birmingham Road with its heavy traffic. I cannot believe that those users will feel comfortable using the towpath when there is such an encampment there. For one thing the Travellers tend to have out of control animals (dogs) which could easily attack a lone walker.

The other difficulty is that it would be nearly impossible to screen the site either from the canal or from the road so that it would be an eyesore on the busiest road into the town of Warwick. What a start for tourists!

Finally as a daily user of the junction of Ugly Bridge Road and the Birmingham Road I can assure you that it is a dice with death already as it is difficult to tell whether outward bound traffic is signalling to turn into Ugly Bridge Road or the Shell Garage and the rest of the traffic travels at speed in a fairly continuous stream. Turning back into Ugly Bridge Road from Birmingham Road is also something of a trial but would be very much worse with a busier access at Oaklands Farm.

In any case sighting a residential site next to a 24 hour light source doesn't seem very sensible.

I think you must agree that to use this site for this purpose would be against the public interest, detrimental to a heritage asset and produce a much more dangerous junction at Ugly Bridge Road. It would also, in my view, probably put the Travellers' children into an area where they could be severely injured or killed by the traffic on Birmingham Road and at the junction with Ugly Bridge Road.

) I would like to comment on the proposed traveller site at GT19, Birmingham Road to which I strongly object. On the following reasons:

Natural Environment
The canal path makes for fantastic walks and this development would impact on the wildlife in and around the canal, within this area heron, kingfishers, swans are regularly seen and are protected, including their nest, under the wildlife and countryside act. This proposed development would disturb their environment.

Historic Environment
I'm amazed that a traveller site is being considered next to the Hatton "flight" locks in the green belt. Your proposed site would directly back onto the locks which were build in 1799. This really is one of the most fantastic parts of the British water ways and would cause a terrible loss to our beautiful historic canals and affect tourism to this local area.

Not only would this site be visible from the canal but also the road, and in a close proximity to the historic Hatton Park buildings. And the views of Hatton Park.

Road safety
The main access point is directly on to a fast moving road, caravans/ cars would be pulling directly onto the main road where there has already been a number of deaths.

This site would be boarded by this main road, I would assume that both children and pets could be located on the site and all that stands between them and a dangerous road is a hedgerow, which I'm sure the children would want to play in.

There are no provisions for parking and turning at the site. Therefore turning and any overflow parking would be on the main road. Decreasing the visibility of drivers and pedestrians crossing the road.

The "Ugly" bridge on the boundary of the proposed development isn't suitable for the regular use with heavy vehicles. And an increase in traffic would increase the danger for walkers crossing the blind bridge to reach the other side of the canal.

Finally with this area located at the bottom of the Hatton locks, which is 146 feet high I would have thought this could be subject to flooding?

Please find our objections to GT11 - Land at Budbrooke Lodge, Hampton Road
1) Avoiding areas where there could be adverse impact on important features of natural and historic environment and sites which can be integrated into the landscape without harming the character of the area: Warwick is an historic town and the proposed site is close to its Racecourse (which brings many tourists to the town) and St. Mary's Land (both of historical importance) and are the largest green space close to the centre of the town. The site on Hampton Road is very close to the Racecourse stable. There is a potential risk of disease being transferred from non-vaccinated animals to thoroughbred racehorses. There is also lot of wildlife in this area and this would be adversely affected if this site were to become a Gypsy site. The Hampton road is one of the main routes bringing tourists into Warwick if this site was chosen this is the first thing they would see when entering the town.

2) Avoiding areas with a risk of flooding: Part of the proposed Hampton Road site (GT11) sits within the flood plain, which is in conflict to the "Planning Policy for Traveller sites". If hard standings were placed in this area it would exacerbate the problems in the flood plain.

3) Promotes peaceful and integrated co existence between site and local community: Judging by the depth of negative feeling regarding the proposed site on Hampton Road "peaceful and integrated co-existence between the site and the local community" appears to be impossible. This could create anger, hatred and resentment within the local community.

4) Safe access to the road network: The junction of Purser Drive on to Hampton Road is very busy and will only become busier as the building on Chase Meadow estate increases. Traffic travels too fast down this stretch of road and to have an entrance to a Gypsy and Traveller site close by on the opposite side of the road could be dangerous especially with caravans turning in and out of the entrance.

5) Avoiding areas where there is potential for noise and disturbance:
Of all the proposed sites GT11 is the closest to an existing large populated area.
The noise from the A46 is very loud, especially where vehicles pass under the bridge where the Hampton Road crosses the A46, because the noise echoes. The site on the Hampton Road is very close to this bridge so there is a high potential for noise on this site.

6) Avoids placing undue pressure on local infrastructure and services: Local services are already struggling with an ever growing population for example local schools are struggling to cope with the increase in pupil numbers.

7) Reflects the extent to which traditional lifestyles (whereby some travellers live and work from the same location omitting travel to work journeys) can contribute to sustainability. If we all had 500 sq metres as 'our pitch' maybe we too could live and work from the same location.

If this site gets the go ahead will existing residents be compensated for the knock on impact this site would have on house prices (leaving some in negative equity) and the ability to sell?

I note that you have given Preferred Status to two G&T sites (GT02 + GT04) in the vicinity of Harbury. These sites were in your original discussion document and I raised my objections to them at that time. Below are my current ( and former objections).

In my opinion neither site should have got to this stage of the process as WDC has not, in my opinion, complied with government guidance in important areas (see below), which makes the whole process flawed and ipso facto any decisions resulting from said process invalid.

At the time the sites were originally considered there had been insufficient consultation as recommended in the government's guidance.
1. There was minimal contact with Stratford District Council. I have it in writing from the Chief Planning Officer that between February 2012 and January 2013 there had been just 3 meetings with SDC, only one of which had any minutes taken. Indeed, in the words of your Chief Planning Officer, "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."
In my opinion, this does not comply with the government's 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"
and 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)
2. Community groups prior to the decision on the sites were not consulted. A meeting was held in Harbury AFTER GT02 and 04 were put forward as preferred sites. This runs contra to the government's guidelines which state:
12- 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."
3. The surgery and the school in Harbury were not consulted to identify if there was spare capacity. This is especially important given that I am led to believe money for extending any current facilities is either not available or extremely limited. This lack of consultation seems to be directly at odds with government guidance 4.11:"to enable provision of suitable accommodation from which travellers can access education, health, welfare and employment infrastructure"

The council failed to carry out any due diligence exercise on the Salford University GTAA report, which has formed the basis of its decision making. For example, WDC's own 2011 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?

Both sites will require the use of compulsory purchase powers. No costings have been provided either for the cost of purchase or for the loss of livelihood of those displaced by the compulsory purchase. This seems a fundamental issue, especially as current guidance from the ministry concerned with G&T sites indicates that such powers should NOT be used in relation to G&T sites.

Finally, I reiterate the following objections I 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 and because of this, public transport would not be able to stop near the sites.

b) There is no separate provision for pedestrians or cyclists . Thus, at neither site is there any safe way for children to get to Harbury School without vehicular assistance (which seems, again, to run contra to government guidelines 4.11 "which travellers can access education,"). This would mean that the site would exacerbate parking and obstruction problems at the school, which have only recently been overcome . The school is already oversubscribed and is likely to remain so given the current village demographic.
c) As far as I can tell, sites GT02 and GT04 have no running water, mains sewerage, drainage or mains gas supply. Whilst the later can be overcome with the use of butane gas cylinders, the former are essential for public health and the prevention of pollution of local water courses. Such pollution is likely to damage local wildlife, grazing livestock and be a health hazard. In addition, the GT04 site is close to a chicken farm and so would be subject to strong atmospheric smells and pollution.

d) I note that your document mentions that sites should not have a high risk of flooding. Site GT04 does have a risk of flooding given that it is affected by water run off from Harbury.

e) Site GT04 will directly affect the view from the well-known Chesterton Windmill, which is important given the historic nature of the surrounding area.

I wish to report my objection to the proposed gypsy sites GT02 and GT04.

I have read the recent literature and attended the meeting/exhibition earlier in the spring at Harbury Village Hall. I have concerns about the original research that sourced these potential Gypsy & Traveller Sites and the fact that the research was not done locally and that gypsys were actually involved in the direction of the research.

GT04

I am concerned about its proximity to my home and village and if this site were successful I fear for the drain on resources that the site would create as school and doctors places are already at maximum capacity.

I am aware that the football club will only agree to the use of the land as a G&T site if they are able to relocate to a city centre site, if this is not possible they do not wish to move so if you choose this land it would be an attempt at a compulsory purchase.

GT02

I object to the suggestion that this site is put forward as a proposed G&T site based on the following facts:

1. I am employed at the Warwickshire Exhibition Centre (WEC) and am clearly aware that the land owners do not wish to sell, so if this site is forced through it would need to be via compulsory purchase which would be costly for the council and take years to complete if it ever would.

2. The threat of this site alone has been sufficient to deter potential event organisers from using our exhibition hall and it has also deterred current organisers working with us from signing extended contracts to work with us over the next 5 years.

3. I am one of 7 permanent employees at the WEC and when we have exhibitions on we employ many more people on a temporary basis, sometimes up to 30 or 40. If the site at GT02 was approved the WEC would be forced to close down and myself and all colleagues would be forced into unemployment.

4. The WEC brings significant revenue into the county/district through the thousands of visitors and hundreds of exhibitors it brings to the Centre each year. Revenue for the district is source through hotels, B&Bs, restaurants, other tourist attractions in the area etc. For some of our events we will book directly accommodation for our exhibitors and we promote local facilities via our website.

5. I have concerns about the location of the proposed site being on such a main road - this does not prove safe access to and from the site for vehicles and there is really no pedestrian access from the proposed site.

6. The proposed site is opposite a business but also a residential home.

7. The adjacent site is protected ancient woodland and igf a G&T site were placed next to it is would have severe damage to wildlife habitat.

8. The land is a historic toll site from medieval times.

9. The land is on the archaeological site.

10. I do question why all the sites are in the south of Warwickshire and I also question the governments suggestion on how manysirte are required - it is far too many for our asre and the proposed sites are too close to each other.

I do sincerely hope that Warwick District Council do remove these 2 options from the local G&T lists.

I would like to express my objections to the proposed sites GT02 and GT04.

My main concerns are as follows:-

1) The Salford GTAA report appears to ignore the impact of the planned transit site at nearby Southam which has been agreed since the completion of the GTAA.
2) According to government planning policy framework, adjacent district councils are required to collaborate but warwick DC and Stratford DC do not seem to be collaborating at any length, save for a reported 10 minute un-minuted meeting.
3) Both GT02 and GT04 sites do not meet national planning framework guidelines recommending 10 minute pavement walks to shops and amenities, they are around 45 minute walks and on dangerously fast roads.
4) Both sites do not meet national planning framework guidelines recommendations for availability of good infrastructure (roads,pavements,broadband,street lighting). Considerable investment would be required to rectify this and difficult for warwick DC to meet within its annual struggle to remain within budget.
5) GT04 is in an area prone to flooding with Harbury lane and surrounding fields often under water. In accordance with planning and building regulations, GT04 would be unable to use soakaway or run-off based drainage systems as the soil is clay based so connection to mains sewerage would be needed and this is not currently available in Harbury lane.
6) Regarding local services, the nearest GP surgery to both sites is over 3 miles away and is already stretched to capacity. The nearest primary and junior school is also at capacity and already experiences issues with lack of vehicle parking resulting in residents near the school being unable to exit their driveways as they are blocked in. this would only be exacerbated by additional vehicles from the GT02 and GT04 sites. If buses are required, where will the bus stops be? It would be dangerous for children at both sites to be waiting for buses at the side of the Fosse way or Harbury lane.
7) The cost to create 5 to 10 permanent pitches at GT04 ranges between £325k to £650k, using government's figures of £65k per pitch. There is no evidence that Gypsies and travellers would be willing to pay these sums and Warwick DC have not suggested an alternative means of raising the revenue required.
8) Development of The sites will damage wildlife habitat at a time when many species are declining in numbers. GT04 is in an area of good quality farmland utilised for livestock and arable farming.

I wish to object to the Gypsy and Traveller preferred site GT04 Land at Harbury Lane, Fosse Way.
My comments and some of my concerns are as follows:
- 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 of the report and /or the relevance of the established need.
- The WDC consultation does not consider as required the existing capacity of current sites within Warwickshire county and adjacent districts.
- The GTAA ignores the impact of the planned Transit site near Southam which has been agreed since completion of the GTAA
- According to the Government's planning policy framework, adjacent DCs are required to collaborate, and yet Warwick DC and Stratford DC are very much out of phase with their consultations so logically they cannot collaborate. Further there is no evidence that WDC has collaborated or discussed with Stratford DC other than a reported "10 minute long but un-minuted meeting" or with Rugby DC
- there is no evidence in WDC's consultation report that as required by NPFF and CLG , that WDC have weighed up the cost to council of Compulsory purchase vs development of underutilised brownfield sites including those that the council already own.
. - The WDC proposals will provide for more accommodation than there are G&T residents within WDC boundary the vast majority of whom already live in houses so the requirement is clearly seriously over-stated
* There is clear evidence via Hansard that MP's now want a fair planning policy that should result in the abolition of the G&T planning requirement
* There has been little (and passive) publicity of the Consultation process and key milestones. Had it not been for the local Community group I would not have known about it - it feels and looks like this is a deliberate underhanded approach.
Specific to Site GT04:
- The site does not meet the fundamental planning criteria laid out in the NPPF, guidance from Department of Communities and Local Government and WDC's own consultation documents for Gypsy & Traveller sites. GT04 does not comply with planning policy whereby sites should provide access to nearby services and quality of life. Specifically:-
- Accessibility to shops and local services: GT04 does not meet national planning framework guidelines recommended 5-10mins walk on a pavement.
-Proximity to local community: GT04 does not meet the national planning framework guidelines recommendation for sites to be on community periphery to encourage integration.
-Establishing 5-10 pitches at GT04 would be disproportionate to the local community (8 residential properties, with 16 adults and 4 children). This is contradictory to national planning framework guidelines recommendations.
- GT04 does not meet national planning framework guidelines recommendations for accessibility to good local transport.
- GT04 does meet national planning framework guidelines recommendations for availability of good infrastructure (roads, pavement, street lighting, broadband, cellphone reception).The infrastructure at GT04 is poor and would require considerable investment to rectify. And this is an expense that WDC should not incur during times of cutbacks in public expenditure and services.

- The area is prone to flooding with Harbury Lane and surrounding fields are often under water.
In accordance with planning and building regs, GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based and will require connection to mains sewerage which does not exist in Harbury Lane.
-Planning policy for G&T requires schools / GP surgeries to be a 5-10 minute walk away, GT04 is at least a 45 minute walk away.
- The nearest GP surgery is three miles away
- that GP surgery is at capacity.
- The nearest primary, junior and senior schools are already at capacity.
- GT04 is located on Harbury Lane and Fosse Way cross roads that is a high risk travel route with high
volumes of traffic and an increasing number of accidents. Speed cameras and warning signs highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to school if indeed such transport exists
- According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This raises serious environmental and health concerns, and was a primary reason that the potential G&T site at Barnwell farm was previously rejected. Simply -Barnwell chicken farm can smell awful and GT04 would not be a good place to live
GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and which would make GT04 an unpleasant place to live but also an unhealthy one.
* The NPFF requires that the assessment of site suitability should be consistent with other planning requests. However I understand that other residential planning applications within 200m of GT04 have been recently rejected by council planning authorities, referencing rural policy on the grounds that the proposal would have an adverse "impact on the character of the area".
- the cost to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's figures (£65k per pitch). In addition to this, G04 site may require relocation of Football club. There is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that G&T can and will buy and develop it
- GT04 is an area of good quality farmland fully utilised for livestock and arable farming.
- GT04 will lack of Integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire
- The proposed site will have an adverse visual impact from Harbury and The Fosse Way (Roman Road).
- If GT04 were to be developed, the use of a vehicle or public transport to shops and schools is a necessity and not considered eco-friendly.
- The site will have a detrimental impact on tourism and visitors to Warwickshire especially including Mallory Court Hotel and a consequential effect on local employment.
- The site will damage wildlife habitat.

Preferred Site GT04 for Gypsies and Travellers (G&T)

I wish to object to the Gypsy and Traveller preferred site GT04 Land at Harbury Lane, Fosse Way.

My comments and some of my concerns are as follows:

* I query the validity and accuracy of the Salford GTAA report in order to establish need.
* The WDC consultation does not consider as required the existing capacity of current sites within Warwickshire county and adjacent districts.
* The GTAA ignores the impact of the planned Transit site near Southam which has been agreed since completion of the GTAA.
* According to the Government's planning policy framework, adjacent DCs are required to collaborate, and yet there is no evidence that WDC has collaborated or discussed with Stratford DC.
* There is no evidence in WDC's consultation report that, as required by NPFF and CLG, WDC have weighed up the cost to council of Compulsory purchase vs development of underutilised brownfield sites including those that the council already own.


Specific to Site GT04:

GT04 does not meet national planning framework guidelines in the following areas:
* Not within recommended 5-10mins walk on a pavement for accessibility to shops, local services or good local transport
* Not on community periphery to encourage integration.
* No good infrastructure (roads, pavement, street lighting, broadband, cellphone reception) .
* G&T requires schools / GP surgeries to be a 5-10 minute walk away with GT04 at least a 45 minute walk away.
* The nearest primary, junior and senior schools & GPs are already at capacity.



The site is unsuitable and unpleasant for G&Ts because:

* The area is prone to flooding with Harbury Lane and surrounding fields often under water.
* In accordance with planning and building regs, GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based and will require connection to mains sewerage which does not exist in Harbury Lane.
* GT04 is located on Harbury Lane and Fosse Way cross roads which is a high risk travel route with high volumes of traffic and an increasing number of accidents.
* Children will be at risk if allowed to stand on a busy road to wait for transport to school.
* According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This raises serious environmental and health concerns.
* GT04 is within 400m of the Harbury Lane Breakers yard which generates noise and air pollution.


In addition,

* The cost to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's figures (£65k per pitch). In addition to this, G04 site may require relocation of Football club. There is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that G&T can and will buy and develop it.
* GT04 is an area of good quality farmland fully utilised for livestock and arable farming.

* The site will damage wildlife habitat.
* GT04 will lack integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire, and views from Harbury and The Fosse Way (Roman Road).
* If GT04 were to be developed, the use of a vehicle or public transport to shops, doctors and schools is a necessity and not considered eco-friendly.

Thank you for taking the time to consider our views.

I would like to respond to the latest consultation process for the five potential sites .

Part A
Part B

Commenting on the Gypsy and Traveller Site Options.
The whole G&T issue seems to be driven to support the Draft Local Plan, rather than to be the correct solution in itself . I strongly believe that the sites should be considered within the New Local Plan and not as a separate exercise.
I have attended the WDC exhibitions and it appears that there is no justifiable reason why the G&T sites cannot be reviewed and incorporated into the new sites designated for providing the 12,300 houses currently under consultation.
I would like to refer my comments specifically to the following sites:
GT12, GT 15 and GT alt 12 alt 01.

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 GT alt 01 - sits 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 site GT alt 01for the same reasons.

* Sites GT 12, GT alt 12 and GT alt 01 - 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 GT 12 and GT12 alt 01 - 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 GT 12 and GT 12 alt 01 - 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 GT 12 and GT12 alt 01 - 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.

* Site GT 15 - this site sits alongside Europa Way which following recent upgrade is now an even busier road. There is no apparent logic to this site what so ever , indeed the site has no access to any local facilities and would be best integrated into one of the areas of land being considered for new local housing


* Sites GT12 and GT 12 alt 01 - there is inadequate pedestrian crossing facilities for safe access into the village. It is an extremely busy road and crossing and road improvement measures would require significant investment to be safe for users.

* Sites GT 12 and GT 12 alt 01 - 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 GT 12 and GT 12 alt 01 - 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 GT 12, GT 12 alt 01 and GT 15, - are not locations which allow peaceful and integrated co-existence with the local community.

* Sites GT 12 and GT 12 alt 01 - development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (eg site 12) totally unviable.

* Sites GT 12 and GT 12 alt 01 - 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 GT 12, GT 12 alt 01 and GT 15 - 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 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. These sites should be integrated into new housing sites identified for the New Local Plan. The new G&T sites can be integrated into those sites from the start. Discussions with developers confirm that they would be willing to accept a number of G&T sites into new housing development areas along with affordable housing schemes.


* Availability - none of the sites listed are available, namely sites GT 12 , GT 12 alt 01 and GT 15. 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.

I would like to respond to the latest consultation process for the five potential sites .

Part A
Part B

Commenting on the Gypsy and Traveller Site Options.
The whole G&T issue seems to be driven to support the Draft Local Plan, rather than to be the correct solution in itself . I strongly believe that the sites should be considered within the New Local Plan and not as a separate exercise.
I have attended the WDC exhibitions and it appears that there is no justifiable reason why the G&T sites cannot be reviewed and incorporated into the new sites designated for providing the 12,300 houses currently under consultation.
I would like to refer my comments specifically to the following sites:
GT12, GT 15 and GT alt 12 alt 01.

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 GT alt 01 - sits 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 site GT alt 01for the same reasons.

* Sites GT 12, GT alt 12 and GT alt 01 - 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 GT 12 and GT12 alt 01 - 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 GT 12 and GT 12 alt 01 - 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 GT 12 and GT12 alt 01 - 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.

* Site GT 15 - this site sits alongside Europa Way which following recent upgrade is now an even busier road. There is no apparent logic to this site what so ever , indeed the site has no access to any local facilities and would be best integrated into one of the areas of land being considered for new local housing


* Sites GT12 and GT 12 alt 01 - there is inadequate pedestrian crossing facilities for safe access into the village. It is an extremely busy road and crossing and road improvement measures would require significant investment to be safe for users.

* Sites GT 12 and GT 12 alt 01 - 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 GT 12 and GT 12 alt 01 - 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 GT 12, GT 12 alt 01 and GT 15, - are not locations which allow peaceful and integrated co-existence with the local community.

* Sites GT 12 and GT 12 alt 01 - development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (eg site 12) totally unviable.

* Sites GT 12 and GT 12 alt 01 - 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 GT 12, GT 12 alt 01 and GT 15 - 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 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. These sites should be integrated into new housing sites identified for the New Local Plan. The new G&T sites can be integrated into those sites from the start. Discussions with developers confirm that they would be willing to accept a number of G&T sites into new housing development areas along with affordable housing schemes.


* Availability - none of the sites listed are available, namely sites GT 12 , GT 12 alt 01 and GT 15. 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.

see attached

I wish to object to this proposed development on the following grounds:-

- 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 of the report and /or the relevance of the established need.
- The WDC consultation does not consider as required the existing capacity of current sites within Warwickshire county and adjacent districts.
- The GTAA ignores the impact of the planned Transit site near Southam which has been agreed since completion of the GTAA
- According to the Government's planning policy framework, adjacent DCs are required to collaborate, and yet Warwick DC and Stratford DC are very much out of phase with their consultations so logically they cannot collaborate. Further there is no evidence that WDC has collaborated or discussed with Stratford DC other than a reported "10 minute long but un-minuted meeting" or with Rugby DC
- there is no evidence in WDC's consultation report that as required by NPFF and CLG , that WDC have weighed up the cost to council of Compulsory purchase vs development of underutilised brownfield sites including those that the council already own.
. - The WDC proposals will provide for more accommodation than there are G&T residents within WDC boundary the vast majority of whom already live in houses so the requirement is clearly seriously over-stated
- There is clear evidence via Hansard that MP's now want a fair planning policy that should result in the abolition of the G&T planning requirement
- There has been little (and passive) publicity of the Consultation process and key milestones. Had it not been for the local Community group I would not have known about it - it feels and looks like this is a deliberate underhanded approach.
Specific to Site GT04:
- The site does not meet the fundamental planning criteria laid out in the NPPF, guidance from Department of Communities and Local Government and WDC's own consultation documents for Gypsy & Traveller sites. GT04 does not comply with planning policy whereby sites should provide access to nearby services and quality of life. Specifically:-
- Accessibility to shops and local services: GT04 does not meet national planning framework guidelines recommended 5-10mins walk on a pavement.
-Proximity to local community: GT04 does not meet the national planning framework guidelines recommendation for sites to be on community periphery to encourage integration.
-Establishing 5-10 pitches at GT04 would be disproportionate to the local community (8 residential properties, with 16 adults and 4 children). This is contradictory to national planning framework guidelines recommendations.
- GT04 does not meet national planning framework guidelines recommendations for accessibility to good local transport.
- GT04 does meet national planning framework guidelines recommendations for availability of good infrastructure (roads, pavement, street lighting, broadband, cellphone reception).The infrastructure at GT04 is poor and would require considerable investment to rectify. And this is an expense that WDC should not incur during times of cutbacks in public expenditure and services.

- The area is prone to flooding with Harbury Lane and surrounding fields are often under water.
In accordance with planning and building regs, GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based and will require connection to mains sewerage which does not exist in Harbury Lane.
-Planning policy for G&T requires schools / GP surgeries to be a 5-10 minute walk away, GT04 is at least a 45 minute walk away.
- The nearest GP surgery is three miles away
- that GP surgery is at capacity.
- The nearest primary, junior and senior schools are already at capacity.
- GT04 is located on Harbury Lane and Fosse Way cross roads that is a high risk travel route with high
volumes of traffic and an increasing number of accidents. Speed cameras and warning signs highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to school if indeed such transport exists
- According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This raises serious environmental and health concerns, and was a primary reason that the potential G&T site at Barnwell farm was previously rejected. Simply -Barnwell chicken farm can smell awful and GT04 would not be a good place to live
GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and which would make GT04 an unpleasant place to live but also an unhealthy one.
- The NPFF requires that the assessment of site suitability should be consistent with other planning requests. However I understand that other residential planning applications within 200m of GT04 have been recently rejected by council planning authorities, referencing rural policy on the grounds that the proposal would have an adverse "impact on the character of the area".

- the cost to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's figures (£65k per pitch). In addition to this, G04 site may require relocation of Football club. There is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that G&T can and will buy and develop it
- GT04 is an area of good quality farmland fully utilised for livestock and arable farming.
- GT04 will lack of Integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire
- The proposed site will have an adverse visual impact from Harbury and The Fosse Way (Roman Road).
- If GT04 were to be developed, the use of a vehicle or public transport to shops and schools is a necessity and not considered eco-friendly.
- The site will have a detrimental impact on tourism and visitors to Warwickshire especially including Mallory Court Hotel and a consequential effect on local employment.
- The site will damage wildlife habitat.

All of the above objections are both valid and reasonable, and I cannot understand why WDC are still considering GT04 as an option.