8. Preferred options for consultation

We oppose any gypsy sites in the Whitnash/Bishops Tachbrook area. This is a lovely area to live and if there was to be a gypsy site anywhere then it would change the area considerably. I have lived here for 14 years and have never faced any problems of any kind but feel that this would change if the site was on Harbury Lane.

Warwick DC Sites for Gypsies and Travellers - Preferred Options
Thank you for consulting The Coal Authority on the above document.
Having reviewed the document, I confirm that we have no specific comments to make at this stage.
Should you require any assistance please contact a member of Planning and Local Authority Liaison at The Coal Authority on our direct line (01623 637 119).

There is really very little evidence as to how WDC finally arrived at these PO choices - objectively some are acceptable but some defy comprehension when set against WDC criteria.

The policies set out in the March 2014 Preferred Options should be refined to improve the decision making process and to help towards arriving at a successful outcome - and one that can be seen as "sound" when subject to Examination in Public.

Policy 1 - to distribute the sites evenly across the District.
This is not only in the interests of the existing settled communities, but more importantly of the G & T family groups themselves.
They will benefit, from not being "bunched " in the southern area which covers only a fifth of the District. G & T groups should not be put in a position where they are in competition with each other for services, schooling or business opportunities.
Most of the proposed sites are remote from Coventry, Kenilworth and northern section of the Fosse Way where much of their traditional activities have been centred.

Policy 2 - only one site should be allocated to any given parish. This make sense in terms of acceptance by the local community, and encouraging the possibilities for positive social contacts with the newcomers. Local services and resources like schools and doctors surgeries, have a much better chance of coping if only one G & T group has to be taken care of.

Policy 3 - sites to be limited to between 5 and 7 pitches - original government advice was 5 to 15 pitches per site, but in para 2.1.2 the report states that "advice has been amended and the lower end of this scale is now recommended". However the Preferred Options ignores this policy by listing 13 of the 15 "preferred"sites to take 15 pitches.

Considering these 3 policies and applying them to the Preferred Options, the following conclusions emerge:-

2.1 Only one site to be in the parish of Bishop's Tachbrook. In this case GTalt01 Brookside Willows is the least worst but should be limited to 5 pitches.

2.2 It is difficult to understand why GT06 at Park Farm is designated AMBER - it is flat and could be easily accessed from the M40 slip road - so if Gtalt01 fails, then this site should be the next in line for this parish.

3.1 The possible selection of GT04 should not be contingent on the football club being relocated. It is highly questionable whether the football club would be better off on a new site - there are many strong reasons for not moving it. But the point here is that the original GT04 meets many of the criteria in para 6; and within that larger extent a suitable site could be identified, probably with access onto the Fosse.

4.1 GT08 in Cubbington should be reinstated as GREEN and "preferred". It's on previously developed land and meets nearly all the criteria.

5.1 Likewise GT01 at Siskin Drive should be reinstated. In the event that Gateway does get the go-ahead, a condition must be that that this large area must provide G & T site as an alternative to GT01.

6.1 At least one small site has to be found in the green belt in the west of the District - see Policies 1 and 2 above. But GT19 looks wrong for reasons of access and proximity of local businesses- and should be regraded as RED.


Site Size

It has become clear through the consultation period that each pitch on a designated site should be sufficient to allow for at least 2 caravans, parking and turning space for several vehicles and outside washing /toilet facilities. The area quoted is 500 sq. m.per pitch. In terms of this space requirement and the noise and activity that will arise, it is understandable that the recommendation is for small sites. The target should therefore be to select sites for 5 -7 pitches rather than 10 to 15.


Conclusion

For WDC to plan for 5 sites spread around the District @ 5 pitches each. To allow for 31 pitches post 2021, one other alternative site for future development to be listed OR 2/3 of the 5 sites to be earmarked for expansion up to 7 pitches.

The policies set out in the March 2014 Preferred Options should be refined to improve the decision making process and to help towards arriving at a successful outcome - and one that can be seen as "sound" when subject to Examination in Public.

Policy 1 - to distribute the sites evenly across the District.
This is not only in the interests of the existing settled communities, but more importantly of the G & T family groups themselves.
They will benefit, from not being "bunched " in the southern area which covers only a fifth of the District. G & T groups should not be put in a position where they are in competition with each other for services, schooling or business opportunities.
Most of the proposed sites are remote from Coventry, Kenilworth and northern section of the Fosse Way where much of their traditional activities have been centred.

Policy 2 - only one site should be allocated to any given parish. This make sense in terms of acceptance by the local community, and encouraging the possibilities for positive social contacts with the newcomers. Local services and resources like schools and doctors surgeries, have a much better chance of coping if only one G & T group has to be taken care of.

Policy 3 - sites to be limited to between 5 and 7 pitches - original government advice was 5 to 15 pitches per site, but in para 2.1.2 the report states that "advice has been amended and the lower end of this scale is now recommended". However the Preferred Options ignores this policy by listing 13 of the 15 "preferred"sites to take 15 pitches.

Considering these 3 policies and applying them to the Preferred Options, the following conclusions emerge:-

2.1 Only one site to be in the parish of Bishop's Tachbrook. In this case GTalt01 Brookside Willows is the least worst but should be limited to 5 pitches.

2.2 It is difficult to understand why GT06 at Park Farm is designated AMBER - it is flat and could be easily accessed from the M40 slip road - so if Gtalt01 fails, then this site should be the next in line for this parish.

3.1 The possible selection of GT04 should not be contingent on the football club being relocated. It is highly questionable whether the football club would be better off on a new site - there are many strong reasons for not moving it. But the point here is that the original GT04 meets many of the criteria in para 6; and within that larger extent a suitable site could be identified, probably with access onto the Fosse.

4.1 GT08 in Cubbington should be reinstated as GREEN and "preferred". It's on previously developed land and meets nearly all the criteria.

5.1 Likewise GT01 at Siskin Drive should be reinstated. In the event that Gateway does get the go-ahead, a condition must be that that this large area must provide G & T site as an alternative to GT01.

6.1 At least one small site has to be found in the green belt in the west of the District - see Policies 1 and 2 above. But GT19 looks wrong for reasons of access and proximity of local businesses- and should be regraded as RED.


Site Size

It has become clear through the consultation period that each pitch on a designated site should be sufficient to allow for at least 2 caravans, parking and turning space for several vehicles and outside washing /toilet facilities. The area quoted is 500 sq. m.per pitch. In terms of this space requirement and the noise and activity that will arise, it is understandable that the recommendation is for small sites. The target should therefore be to select sites for 5 -7 pitches rather than 10 to 15.


Conclusion

For WDC to plan for 5 sites spread around the District @ 5 pitches each. To allow for 31 pitches post 2021, one other alternative site for future development to be listed OR 2/3 of the 5 sites to be earmarked for expansion up to 7 pitches.

I am writing 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 a 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 has ignored 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. Furthermore, 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 indeed 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 as the vast majority already live in houses therefore the requirement is clearly over-stated

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 that recommend a 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.
* 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, mobile phone reception).The infrastructure at GT04 is poor and would require considerable investment to rectify. Surely this is an expense that WDC should not incur during today's times of cutbacks in public expenditure and services?
* The area is prone to flooding with Harbury Lane and surrounding fields often being under water. In accordance with planning and building regulations, 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 and 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. Barnwell chicken farm can smell awful and GT04 would not be a good place to live
* The cost to create 5 to 10 permanent pitches ranges from £325k to £650k, using government's figures (£65k per pitch). In addition to this, GT04 site may require the relocation of a 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
* 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.

Please note my objections and further comments regarding the siting of pitches, etc, for Gypsy and Traveller families at the following locations:
1. GT04- Harbury Lane
* Objection to yet more tax payers money paying for the a relocation of Leamington Football Club
* Very remote from any main facilities
* No pedestrian access - no amenities within walking distance

2. GT15- Land to East of Europa Way
* Pollution risk: Located by the banks of the Tachbrook, as this proposed site could be used as a place of work, there are contamination risks to the environment
* Access onto Europa Way would be dangerous- busy, very fast trunk feeder road
* Busy road would cause noise and air pollution to site
* No bus route to nearby towns and villages
* No pavements- unsuitable as very fast road
* Nearest schools already under pressure
* Land floods regularly
* Steep, sloping ground
* Only a small site, therefore more would be needed
* Tree felling would be required- not environmentally friendly
* Visual impact on route into "Historic Royal Leamington Spa"
* Would be unfair to develop this site and GT04- negative impact on Warwick Gates

3. GTalt01 - Brookside Willows, Banbury Rd
* Would need a safe pavement for walking into Warwick for nearby facilities/ bus routes
* Already has planning/facilities for a caravan site
* Not ideal, but more suitable than others
* Need to overcome contamination issues


4. GT05 - Land at Tachbrook Hill Farm, Bishop's Tachbrook- (WDC Alternative site)
* Prone to flooding
* Accident blackspot- Adjacent to road junction with history of road accidents
* Visual impact on entering the village
* Oversubscribed GP practice and school
* Unsuitable for business use

Additionally, when making the final decision, please can it be taken into consideration that with the vast amount of housing that is to take place South of Leamington and Warwick, that it would be extremely unfair for one community/ area to have more than one G&T site impacting on it, ie: Warwick Gates and Whitnash. These communities already have major housing developments having been granted planning permission very recently by certain political local Councillors, plus a Solar Farm at Bishop's Tachbrook as well as housing. The positive schooling of non-traveller children also needs to be considered.
Therefore it would be more suitable for chosen sites to be several miles apart, impacting on the North and not just the South of Leamington/Warwick, perhaps in areas not earmarked for vast housing developments.....

As a resident of Bishops Tachbrook we have kept a close eye on the proposals for gypsy and traveller sites in the area, particularly those within the parish boundaries.

The two 'preferred' sites appear to be the most suitable for the following reasons:

GTalt01, Brookside Willows, Banbury Road.
* has planning for a caravan site (therefore utilising a site for the original purpose)
* is screened from the main road and will therefore afford some privacy from those staying there
* has easy access to Warwick (including doctors, dentist, schools, shops etc - all of which are walking distance along existing pathways)
* already has a great deal of the infrastructure required in place (including excellent access from the main road)

GT15, Land at Europa Way.
* Council owned land (no cost of purchase)
* Utilising land which is currently unused and of no agricultural value.
* Close to Warwick and its facilities (including doctors, dentist, schools, shops etc)
* Small manageable site
* Has natural screening from road

The 'alternative' sites are not very practical or desirable for the following reasons:

GT05, Tachbrook Hill Farm, Mallory Road.
* Adjacent to very bad junction (already very difficult to turn onto the A452 at peak times)
* Next to a bad section of road (several accidents have occurred there)
* Would require building on good agricultural land
* Would stretch village amenities (shop, school, doctors etc)
* Limited amenities in Bishops Tachbrook
* No existing pathways to closest amenities
* Would be potentially built next to a proposed housing development
* Land would have to be purchased - information to date suggests that the land owner does not want to sell and would therefore require costly 'compulsory purchase'
* Limited natural screening from either roads or existing housing
* Land has tendency to flood close to Mallory Road

GT06, Land at Park Farm/Spinney Farm.
* Would require building on good agricultural land
* Limited/no natural screening from either roads or existing housing
* No existing pathways to closest amenities (Warwick)

To conclude, the current 'preferred' sites within the Bishops Tachbrook parish boundaries would be far more viable than those identified as 'alternative'.

A practical approach must be taken when deciding on the intended sites to minimise the impact of any development on the environment, agricultural land, existing communities, local infrastructure etc whilst providing viable sites for travellers and gypsy's.

My client, The Spirit Pub Co, made representations on the previous proposals for a Gypsy and Traveller site at Stoneleigh Road, Baginton (Ref GY07).

We see from reviewing your current Preferred Options document that the site GT07 has been omitted from the current consultation, as the site is located in the Green Belt, is too close to Coventry airport, where noise vulnerable caravans should not be located, and has insurmountable access issues. For these reasons the site has been categorised as 'RED' in the Preferred Options document.

The 'Red' sites have been excluded from the Council's consideration on the basis that the negative factors affecting the sites are considered to be insurmountable.

We welcome the exclusion of Site GT07 and consider that the Council has made a logical and sensible decision.

Thank you for giving Rugby Borough Council the opportunity to comment on the Gypsy and Traveller Site Allocations Preferred Options consultation document. The authority are satisfied with the content of the consultation document and would like to be kept informed of the next stage of consultation.

I would like the sites for Gypsy & Travellers to be properly planned and integrated into future new developments which would include schools and doctors surgeries rather than plonked into existing communities which is not the best way to accommodate /integrate the gypsies and travellers. It is not beneficial for this group of people to be imposed on communities and will not ease them into village life.

Thank you for your consultation on the above dated 17 March 2014 which was received by Natural England on the same day.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Preferred Options DPD
Having reviewed the preferred option sites and possible alternatives, Natural England concludes that the sites are unlikely to significantly affect any internationally designated sites or significantly harm nationally designated Sites of Special Scientific Interests.
Allocations which have the potential to indirectly affect neighbouring local wildlife sites (including potential sites) (Gtalt01, Gt02 and GTalt02) should be avoided. This complies with the NPPF 'mitigation hierarchy' which states harm should be avoided, mitigated or, as a last resort compensated.
If, through the SA, your authority determines that these sites are in the most sustainable locations (when compared against reasonable alternatives) and they remain allocated, mitigation measures which preserve and enhance their wildlife interest should be identified in the plan.
Sustainability Appraisal
The SA methodology complies with the requirements of SEA Directives, Planning and Compulsory Purchase Act 2004 and the Environmental Assessment of Plans and Programmes Regulations 2004.
Natural England concurs with the appraisal's assessment of each site's sustainability.
We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

The National Farmers Union (NFU) is a professional trade association which represents the interests of approximately 75% of all farmers and growers and has over 180 members in the Warwick District. We have compiled the following comments in response to the consultation entitled 'Sites for Gypsies and Traveller Preferred Options for Sites' which closes on the 5th May, 2014. The NFU has brought the consultation to the attention of members in Warwickshire via County and Branch meetings and has encouraged members to attend the drop in centres and respond individually. The views expressed below are on behalf of the local farming and land management sector in general and not individual members who will naturally respond in their own right. We make our comments in the knowledge that the Council is under a duty to assess the need for Gypsy and Traveller sites in the area and is under pressure to plan for sites within a defined timescale.

The NFU's primary concern is that the site selection and approval process be undertaken using a thorough and well-reasoned assessment not an ad-hoc or random one. We would like to see a higher level of engagement with landowners and farmers especially in the areas that have so far been identified as potentially suitable locations. Every effort must be made to consult with local landowners and listen to their concerns before any decisions are made.

On the subject of compulsory purchase, it is absolutely essential that should the council call upon such powers, appropriate and fully representative values for land and loss of income be used so all affected landowners are fully compensated for any loss to their business. We also feel that it is important to note that any talk of compulsory purchase now and in the future only seeks to undermine such consultation exercises and leads to distrust on both sides.

The consultation document does not currently include sufficient information regarding the process for the selection of the sites, for example we would expect to see more information regarding the sites suitability and facilities. In addition there is very little information relating to how the sites may affect the local infrastructure and the nearest settled communities and businesses.

The local farming community must be fully consulted on all sites and given greater access to information on the site selection process. It is important to remember that farmers are running businesses on their land (it's not just their place of residence) and they have long term plans for investment and expansion, all of which may be affected by local sites. It is also critical that the site selection process takes into account the practical aspects of running a farm business for example avoiding close proximity to livestock units, blocking rural roads and taking high quality agricultural land out of production.

Barford Residents' Association has consulted with many residents in Barford since the Gypsy and Traveller sites were first proposed last year, and we wish you to know that the residents of Barford object most strongly to the sites GT06, GT12, GTalt 12 proposed in the recent plan, with particular reference to the area known as GT12 as we (the Barford Residents) believe they are totally unsuitable for the following reasons mindful of the Council's own criteria.
The first criterion is for convenient access to a GP surgery. There are no GP surgeries in Barford, the nearest quoted in the brochure in Tachbrook is actually 4.4 miles away by road. This site would therefore fail in this criterion.
Although there is a school and limited public transport - the need to cross the Barford Bypass means that these services are not safely accessible and certainly there is no adequate pedestrian crossing facility to assist in accessing these services.
The western part of the area does fall within or very close to the flood plain as identified on the Environment Agency maps. Development in this area would not be consistent with avoiding areas with a high risk of flooding.
In our view safe access would not be possible. The Barford Bypass already has a poor accident record. Adding slow moving vehicles and turning traffic would exacerbate an already unsafe situation.
The Barford Bypass is adjacent to the site and therefore this is not consistent with an objective of avoiding locating development where there is potential for noise and other disturbance. Noise mitigation, if it were possible, would reduce the land available for the site, be very expensive and not very effective.
There are no utilities within the proposed area so these would have to be provided at considerable cost and disturbance to traffic using the Bypass whilst this work was being undertaken. There has to be a question as to whether the Gypsies and Travellers would be able to, or wish to, fund this development as it would add significantly to the individual pitch price.
The proposed site is Grade 2 agricultural land and a reduction in the holding area it is situated in would render it non-viable as a holding.
The Council has produced no evidence in relation to the ecological and biodiversity importance of the land within the areas proposed. It is our contention that development in this area would cause unacceptable harm to biodiversity interest contrary to the provisions of the NPPF. Indeed we are very much aware that the area contains a number of protected species including, but not limited to, water voles and badgers which we understand, to be legally protected species. This, in our view, represents a failure to accord with the Council's proposed criteria to avoid areas where there could be adverse impact on important features of the natural environment.
Given that this site is greenfield and divorced from the settlement of Barford by the Bypass it is not considered capable of accommodating development that could be successfully integrated into the landscape without materially harming the character of the area.


This site does not fully accord with the provisions of 'Planning Policy for Traveller sites' as it does not promote peaceful integrated co-existence between the site and the local community and does not avoid undue pressure on local infrastructure and services.
The owner of the site is not willing to sell and Compulsory purchase proceedings would therefore need to be initiated. This would be strongly resisted by both the landowner and the residents of Barford.




SUMMARY
There are no GP surgeries in Barford.
There is no safe access to the school or public transport as to access both would require crossing the very busy and dangerous Barford Bypass.
The Barford Bypass already has a poor accident record, adding more traffic in this location and particularly large slow moving vehicles would exacerbate an already unsafe situation.
There are no utilities i.e., running water, toilet facilities, waste disposal. GT12 places undue pressure on local infrastructure and services and therefore does not promote peaceful and integrated co-existence between the site and the local community.
In light of the above we wish you to represent our objections to the appropriate interested parties on the basis that these sites, particularly GT12, is not appropriate as a Gypsy and Traveller site as it is unsuitable, undeliverable and could not be developed

PROPOSED STRATEGY
A number of the required Gypsy and Traveller sites should be accommodated in the new housing developments allocated in the Local Plan. This will give Warwick District Council the opportunity to address all the Gypsy and Traveller's needs at the planning stage rather than imposing them on existing communities.

I trust you will take the above points into consideration and reflect the views of many of your constituents when considering the recommendations for Proposed Gypsy & Traveller Sites in the New Local Plan

see attached