PO1 Meeting the Requirement for Permanent Pitches

1. The location GT04 looks very nice, close to local amenities, on a bus route, short distance to shops, Drs, school. Surrounded by lovely countyside, open views. Add to that free utilities and I think I might join them.
2. What is the criteria for being able to use the site?
3. Why such a large area for only 10 pitches?
4. Presumably protecting for the future and inevitably an increase in the number of occupants shortly.
5. What is wrong with the curent status quo? It is a natural equilibrium because they are moved on from fairly unsuitable sites, and this provides a mild deterrent to others considering a similar lifestyle. They are itinerants and so being moved on should not be such a hardship, and it spreads the effect throughout the district/country.
6. Creating a fantastic location for permanent settlement will only encourage the lifestyle, and if you think there are only a limited number of this type you are in cloud cuckoo land.
7. There is a natural percentage of people prepared to tolerate the current lifestyle of gypsies. The ones taking up permanent residence at GT04 will be replaced straight away by others, probably more once the precedent has been set.
8.Given that there has to be sites, and I have no idea how you will police the transit ones, why have you chosen in a very self righteous way such advantaged ones?
9. There are people struggling to make an honest living would would love to live in such a location.
10. It does not matter what the suitability of the location is in terms of amenities, transport drs. schools or anything else compoared to their current chosen lifestyle.
11. All that matters in a democratic society is the number of objectors.
12. Chose the site where thare have been the fewest number of objections and include the alternative sites proposed by objectors.
13. Will the occupants be paying any rates or service charges?
14. Will the normal laws be applied in terms of car tax and insurance for example, and will the sites end up as police no-go areas like Bulkington or Ryton?
15. Most school class sizes are too large, most Drs waiting times are too long, and they never use public transport, so why do you feel obliged to ensure these are important criteria.
16. Just pick the location that has least effect on those law abiding, honest tax paying citizens that chsose to live here first.
17. How near to any of the proposed sites is an associated county councilor?
18. Where is the money coming from to purchase the land in question?
19. Why not donate that money to people who really "need" it? There is no justification for buying a few acres of prime residential land to give to a small group of people, often from Ireland, to live exactly how they chose.
20. Again, if it must happen, be democratic, like we voted you to be, and take the site with least objection and impact on locality, it really is not important how suitable you think the site is.

GT04 is the only obvious choice amongst these 5 sites. GT19 is suitable but is small and will make a very small contribution whilst disturbing many nearby residents.
GT12, GT15, GTalt01 are NOT SUITABLE choices - for multiple reasons - they are all bad for the G&Ts and GT12 will damage an agric holding and GTalt01 will damage an important new tourist caravan site in a very sensitive location.

The Preferred Options document allocates the full requirement of 31 pitches without allowing for any sites in areas where new developments are planned. All of the proposed sites put strain on existing resources whereas if the sites are planned in conjunction with new developments the infrastructure for the Gypsy & Traveller sites can be provided alongside the requirements for the new developments. Integrating the Gypsy & Travellers designed into a new development must be easier than parachuting them into existing communities.

It is NOT REMOTELY clear how WDC have arrived at the choice of these five sites - several of them are unsuitable and should be removed - specifically GT12, GT15 and GTalt01. Conversely GT04 and GT19 seem eminently suitable. Several very suitable sites have been left as "un-chosen green sites" or graded as Amber or Red...

GT04 - very suitable site - has minimal impact on settled communities. GT19 - a very small if otherwise suitable site and no doubt unpopular with nearby residents. GT12 is a TOTALLY UNSUITABLE site - very dangerous and noisy location on side of A429 with major landscape implications and loss of Grade 2 agricultural land. GT15 - is very small, on a busy main road, remote from services, isolated and is unlikely to be economically viable. GTalt01 - whilst superficially suitable, using this site will blight an emerging 650 pitch tourist business which MUST be important to the local economy.

I object to the option of Site GT12 on following grounds:
-no GP surgery in Barford. Chase Meadow and Wellesbourne practices not accepting new patients.
-cost of providing safe access to Barford By- pass will be prohibitive. (E.g. Cost of visibility splays, and safe pedestrian access to village across an extremely busy road with very fast moving traffic) There have been many accidents already at the nearby junctions, some of which have been fatal. This site would involve frequent movements of towing and slow- moving vehicles, which would increase the danger.
-there are currently no utilities available at the site.
-important features: the beautiful and historic Sherbourne Church, built by renowned architect Gilbert Scott. Uninterrupted view across fields will be spoilt.
- no visual screening. Will be a scar on the landscape.
- will have detrimental impact on a small rural community and put great pressure on local services eg Barford primary School which is already over- subscribed.

Ref SDC Reg 18 consultation (Q1 2014) point 9, potential sites need consideration with respect to "previously developed, untidy or derelict land". GT04 and GT02 do not qualify in these respects.

Assessment of site suitability should be consistent with other planning requests. Note that domestic planning applications within GT04 has been recently rejected by council planning authorities, referencing rural policy on the grounds that the proposal would have an "impact to character of the area".

The needs assessment has falsely identified a "required" number of permanent pitches, as clarified in the two key points below (and respective sub points):

Point 1 - 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 and relevance of the established need.

* WDC consultation does not consider existing capacity in current sites within Warwickshire county and adjacent districts.
* WDC's 2011 report "Evidence of local needs and historic demand for G&T sites in Warwick District" identifies the need for 15 transit pitches and "demand for permanent site-based accommodation was low and transitory in nature" (para 1.3).
These figures are in stark contrast to the 2012 Salford findings, identifying need for 180 individuals to be housed in permanent sites.
* WDC have not identified the requirements or classification for G&T community that need to be housed on permanent traveller sites, for example:
a) The population already in brick & mortar housing;
b) The transitory travelling population;
c) The old/infirm who no longer wish to travel.

Point 2 - The Salford GTAA report has a number of flaws, which suggests the findings lack credibility.
* Salford research was conducted by Gypsies, and the interviewees were Gypsies. Ref page 64 "of Romany Gypsy background"; Ref Hansard report 4th Feb Gavin Williamson.
* The Salford report does not contain any impartial external references; For example, there is no comparison with existing government data (ie bi-annual caravan counts, 2011 census, gov stats for cost per pitch).
* Salford report findings do not consider existing capacity in current sites within Warwickshire county and adjacent districts. The report states that this capacity should be considered when interpreting the findings.
* Paragraph 3.5 of GTAA report states there are 124 individuals in 33 households in the study area.
The majority (18/33 households) of Salford report G&T interviewees are currently living in brick & morter housing. Of these, only one family stated they are on the waiting list for a permanent site.
The Salford report finding identifies a need for 25 pitches = 47 caravans (1.9 per pitch), which at 4 people per caravan approximates to 180 individuals.
=> The Salford report suggests new pitch provision to re-house the entire Warwickshire G&T population.

Gtalt01
I make the following comments on this site.
* It has previously been granted planning permission as a touring caravan site which is a similar use in many respects to the proposed use as a gypsy and traveller site for permanent residence, and therefore with careful adaption it can conceivably be suitable for the proposed purpose.
* Re-engineering of the highway has been completed already allowing the site to be established quickly to help deal with the need identified.
* With appropriate screening this site can be established without causing a high visual impact. This is particularly important when considering the historic setting of Warwick Castle and also that this route into historic Warwick is not compromised.
* There is access on foot into Warwick which offers a range of services and amenities, adding to the site's sustainability, however the footpath would need to be improved to provide pushchair and wheel chair access.

GT15
I object to this site being considered as a gypsy and traveller site, for the following reasons:
* Whilst sight lines appear adequate, constructing as safe access for large articulated vehicles onto the very busy Europa Way will be expensive.
* It is proposed that Europa Way will be widened into a dual carriageway. This is likely to reduce the usable area of the proposed site.
* The establishment of vehicular access and hard-standings for park homes and the storage of touring caravans with require the removal of significant amounts of the existing vegetation. This will open up views into the site from both the historic footpath from Bishop's Tachbrook to Warwick and also from the proposed Country Park, south of Harbury Lane. This will create negative visual impacts across the rural landscape of the Tachbrook Valley.
* There will be an unknown impact on the ecology of the Tachbrook which is an important wildlife corridor linking with the Avon.

Alternative Options

GT05
I believe this site should be removed from any further consideration as a site for development as a permanent gypsy and traveller site, for the following reasons.
* A safe access cannot be constructed from the Banbury Road onto the site. This is a fast road with adequate site lines and is has a poor record for accidents.
* There is not adequate access on foot to village amenities.
* The owner is known to be unwilling to sell and I do not support compulsory purchase in these circumstances, for the reasons given below.
* This site has high landscape value according the resent WCC Landscape Ecology and Geology report completed on behalf of the District Council in support of the New Local Plan process and therefore it would be wrong for this to be developed
* The site is highly visible from a long section of Banbury Road and also Mallory Road
* There are potential negative impacts on the listed Tachbrook Hill Farm House and also Greys Mallory house.


GT06
I also believe this site should be removed from any further consideration as a gypsy and traveller site.
* It is rated as amber and therefore has a number of unresolved issues associated with it.
* Both the owner of the proposed site, and the owner of the adjacent site that could provide access are known to be unwilling to sell. Therefore compulsory purchase would be required which I object to in principle for the reasons given below but also because CPO would be a long and lengthy route to acquisition of the site, delaying significantly the delivery of the pitches required.
* The proposed site has a very open aspect and therefore would create a visual impact on the route into historic Warwick
* There is no suitable access onto the site. The creation of the access will exacerbate visual impact and require the removal of a significant length of hedgerows damaging the natural habitat for animals and plants.
* There is no access on foot to key services and amenities. The nearest bus stop is 1/2 mile away but there is not footpath meaning residents would have to walk to the bus stop along a busy road. Therefore this site is not sustainable.
Compulsory Purchase
I object to the use of a CPO to acquire any site against the owner's wishes, for the following reasons:
* The CPO process is long and protracted. This will lead to a long delay in making the necessary pitches available.
* It seems to me that it is immoral, oppressive and draconian that a private owner of a piece of land can be forced to sell that land to the district council so that it can then be sold onto a landlord for commercial gain. CPO should be reserved only for infrastructure projects that are critical for a region or sub region.
Proposed Operating Model
* Any site that is delivered for permanent use by gypsy and travellers should either be operated by the district council or a specialist housing association. The district's intension sell sites onto private landlords for their operation is a high risk strategy and is not acceptable, because the resolution of any poor practices or planning breaches would be long and protracted and would lead to tension arising will the local settled community and this would undermine the district's objectives.

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.

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.
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.
Please therefore provide me with further information on this point.
10. Summary of Alternative Sites - COMMENT
Why are no photographs of the Alternative Sites provided, unlike for the Preferred Sites in section 9? This is arguably prejudicial as all sites should be given the same treatment in the documentation.
Please could Council officers explain this inconsistency?

Sites for Gypsies & Travellers
Preferred options for consultation
The District Council's preferred option is set out in PO1 Meeting the requirement for Permanent pitches. The intention is to provide 31 pitches on permanent sites.
The preferred option selects
GT04 Harbury Lane/Fosse Way up to 10 pitches
GT12 Westham Lane, Barford up to 8 pitches
GT15 East of Europa Way up to 5 pitches
GT19 Birmingham Road, Budbrooke up to 5 pitches
GTalt01 Brookside Willows Banbury Road up to 10 pitches
Total 38 pitches
Conclusion of my response

To provide 31 pitches I consider the best arrangement to be

1. GT04 Harbury Lane land north of the Football club (see section 4) 6 pitches
2. GT12 Land south of Westham Lane, Barford (see section 4) 0 pitches
GT12 land north of Westham Lane within new housing, as single pitches 3 pitches
3. GT19 Birmingham Road, Budbrooke (see section 4) 3 pitches
4. GTalt01 Brookside Willows, Banbury Road (see section 4) 6 pitches
5. GT08 Land north of Depot near Cubbington Heath Farm (see section 5) 7 pitches
6. Riverside House affordable homes, in single pitches (see section 2) 3 pitches
7. Soans Sydenham affordable homes , in single pitches (see section 2) 3 pitches

TOTAL 31 pitches
1. Criteria for selection of sites.
The selection of sites for permanent pitches should be in line with the DCLG Designing Gypsy and Traveller Sites , Good Practice Guide dated May 2008 and which is still current.
Chapter 3 examines Location of sites and recommends, in paras 3.1 & 3.2

3.1 Selecting the right location for a site is a key element in supporting good community relations and maximising its success. As with any other form of housing, poorly located sites, with no easy access to major roads or public transport services, will have a detrimental effect on the ability of residents to:
* Seek or retain employment
* Attend school, further education or training
* Obtain access to health services and shopping facilities.
3.2 Easy access to local services, and to social contact with other residents in the community, should help deal with the myths and stereotypes which can cause community tension and instead encourage a greater sense of community with shared interests.

The Guide also lists as important
* a safe environment for the residents
* Promotion of integrated co-existence between the site and local community
* Easy access to General Practitioner and other health services
* Near to a bus route, shops and schools
* Ground conditions and levels of land
* Not in areas of flood risk.
.
The Guide also strongly states
3. 7 Where possible, sites should be developed near to housing for the settled community as part of mainstream residential developments. As one way of helping to address shortages of site provision local authorities and registered social landlords can consider the feasibility and scope for providing a site for Gypsies and Travellers within their negotiations to provide affordable housing as part of significant new build developments. Even where smaller scale developments are planned they could consider including a small scale site of three to four pitches which are known to work well for single extended families.

Evidence provided to Select Committee on the importance of site location:
"What is working [in Ireland] are small sites. And they are not placed under flyovers or pylons, or beside sewers, canals or tips; they are placed on proper positioned land, bang within the middle of a settled community, and they are working."204]

None of the preferred option sites meet the criteria of 3.7. This is understandable since it is clear that the majority of the public do not want the travelling community anywhere and the District Council does not really want to provide them. This is due to the reputation that the travellers have for abusing other people's property, leaving dirt and damage behind and assumed increased minor crime. Sometimes those fears are real.

As a result, the travelling community as a whole prefer to live as a separate community, in large groups away from urban locations, so sustaining the mistrust between them and the settled community. As well as this, the larger the group, the bigger the perceived threat. It would seem advisable therefore, to dilute any possible effect to the minimum by keeping the number of pitches on a site as low as possible with a range of sites with a different number of pitches to provide sufficient flexibility to meet the needs of the tenants.
2. Small groups of single sites
However, paragraph 3.7 does indicate that some benefit could be gained if, in new affordable housing schemes, a housing association included a small number of single plot sites.

So it is suggested that you consider, on the 2 affordable housing sites recently included in the publication draft of the local plan, Orbit/Deeley at Sydenham and Riverside House redevelopment sites, that, within each of those developments, 3 separate single plots are slipped in between the normal affordable housing. Each plot would have a normal access to the street, a small bungalow amenity building and space for caravans and vehicle parking designed to fit in with the normal housing. They could look to be a natural part of the housing development, similar to a normal house where the owner parks their caravan in their garden next to a bungalow. As a permanent site, it could be offered to those who are not tied to a large group, who might choose to value getting involved in a wider community and could get close to, but not next door to other members of their family group in much the same way that the settled community does. For the children of those families it would give them a wider educational opportunity to reach their potential, rather than being obliged to be constrained to traditional traveller's ways. For the potential wage earner it would give a wider choice of employment opportunities. For the settled community neighbours, the chances of problems are reduced by the dissipation of the number of sites.

The Guidance gives an example in Annex 3b, Small Scale site in urban locations, with a plot about 10m by 20m (200m2) as compared with the 500m2 per pitch suggested for a set of pitches with internal roads. Services and drainage would cost less, being part of a larger development, so this arrangement is probably the least expensive cost per pitch to provide.
3. The operational management method for Gypsies & Travellers Permanent sites.
The District Council's proposed operating model is ownership and operation by an individual traveller landlord. This is unlikely to be a trouble free arrangement and cannot be relied on to permanently meet the established need, nor maintain a well-run site. Since providing a pitch is viewed as providing a supported housing facility, it should be operated by an independent body that can offer pitches fairly to gypsy traveller applicants, with fair rents and resources to maintain the facility and set the way that non-compliance with fair rules can terminate the tenure. This could be either the District Council or a housing association that specialises in this area of work. The District Council shows no appetite to run such sites, so interest should be invited from interested housing associations to purchase the site, finance, build, maintain and manage it. This model could also include implementation of ways of encouraging a greater sense of community with shared interests of the settled and travelling residents.
4. Considering the 5 preferred options.
GT04 Harbury Lane/Fosse Way
The preferred option document describes this site as currently the home ground of the Leamington Football club. The plan , which is not to the scale of 1:10,000 stated in page 37 shows a brown line around the site in which the Football Club and car park is in the south corner. The whole site is 350m by 430m with a small area in the east corner excluded. The total area is 150,300m2 or thereabouts. 10 pitches are suggested which using the 500m2 per pitch would require only 5,000m2.
Major Gas Pipelines run under the site and construction over the pipeline zones will not be permitted by the Health & Safety Executive. There is a small triangular area north of the football club that appears to be outside the zones between the two pipelines, so any location in this area needs to be carefully worked out with National Grid. However, excavations for drainage that would need to pass over the exclusion zones is unlikely to be permissible. Surface water drainage to this area is by ditches above ground and in persistent wet weather water flows off the fields to the south of Harbury Lane towards the car park and pitch of the Football Club. This part of the site is not therefore suitable for a permanent G & T site.
The site is remote to schools, health services, hospitals, shops & community facilities. It is said that some travellers do not find this a problem.
If kept to a maximum of 6 pitches, a 3,000m2 plot, avoiding the Gas pipeline zones, could be located north of the existing football Club with an access road to the site immediately to the west of the club car park. The site itself could be screened from view along Harbury Lane with suitable tree & shrub planting all around it. This location is less likely to be affected by flooding than the football club area.
I would therefore support the use of this site north of the existing Football Club premises with a separate access to Harbury Lane, surrounded by shelter belt tree planting for a maximum of 6 pitches under the direction of a specialist housing association. This would not require relocation of the football club to another location, safeguarding that site for housing required to meet the Local Plan targets. If the football club wanted to move for other reasons then it could be relocated to a suitable site in the green belt as a compatible use of greenbelt.
GT12 Westham Lane, Barford
This site is South of Westham Lane, not north as described in the preferred options document, close to the River Avon on the west, with the Barford by-pass on the east. The plan, which is not to the scale of 1:10,000 stated in page 39 shows a brown line around the site to the edge of the river and has an approximate area of 7,500m2 excluding the shrub belt on the bank of the river.
8 pitches on this site are too many and would be so close to the by-pass to be impossible to hide with planting. This is not good for the area or for the tenants.
The risk of pollution to the river from activities of the tenants as well as a non-mains drainage solution from this development that would be needed, is too high.
The by-pass is a fast road and access on & off the site would have serious safety concerns.
This concept would quickly deteriorate into a problem. The maximum number of pitches that this site could sustain is 3, to release space for setting the site back sufficiently to get adequate screening and small enough to stop it getting out of hand.
Alternatively, in the village housing options document, 3 housing sites have been identified between the bypass and the Wellesbourne Road. Site 2 is for 60 dwellings and site 3 is for 15 dwellings. 40% of these will presumably be affordable homes and it may therefore be an idea to put these 3 sites as single sites, within probably the larger housing site, in a similar manner to that set out in section 2 above.
GT15 East of Europa Way
This is not suitable for a permanent Gypsy & Traveller site because
* It was built as a permanent woodland as part of the Europa Way construction and forms a valuable screen to the east side of the road and is a positive contribution to the Tachbrook Valley landscape as this photo shows which was taken from the bottom right hand corner of the plan on page 41 towards Europa Way. The proposed site is to the right of the single oak tree (left hand side mid distance) at the point where the trees on the horizon are higher than the tree belt to the left. The Tach Brook is at the bottom of the slope on the right, where the trees along the side of the brook show how the brook relates to the wood and fields.
* The site within the brown lines on plan on page 41 stretches from Europa way down to the Tachbrook. The level at Europa Way is about 65m AOD and the level at the top of the bank to the brook is below 55m. This 10m fall occurs over a distance of between 40 and 150m, so the land has considerable falls across it that would make the site difficult for manoeuvring large vehicles and trailers. Note that the plan on page 41 is not to 1:10,000 but at about 1:2,500.

* The access onto Europa Way, which is a fast road when it is not congested, has serious safety concerns for a site containing large vehicles and trailers as well as young children. Roadside vegetation, trees and shrubs, would need to be removed to get adequate visibility splays.
* To construct the permanent site, large numbers of the trees would have to be cleared. This is one piece of young woodland that is playing a valuable part in carbon dioxide absorption, taking out 4 tonnes of CO2 per annum for every 100m2, which for the area of woodland affected means about a total of 450 tonnes per annum. Loss of such woodland would be contrary to the NPPF definition of sustainable development.
* Although the woodland is young it is dense and gives valuable habitat to wildlife. Human intervention from a permanent site would remove those habitats and the deer, badgers and other mammals would not survive in this location.
* The site would need non-mains foul drains so there is a risk of pollution of the waters in the brook that flows swiftly through to New Waters and then into the Avon, both from drainage spillage and debris from the tenants.
* Considering how this site could be laid out for 5 pitches, because it is a relatively narrow piece of woodland, after accounting for the new road access required and the falls across the site, it is probable that 5 pitches could not be satisfactorily sited and would have to be linear, parallel with the road. On a cost per pitch costing it is probably one of the most expensive locations in its capital cost of provision.
* Due to the heavy traffic on Europa Way and the proximity of living spaces to that road it is unlikely that it meets the noise standards required for a permanent site.
* As a site this is remote to any other community and is not as recommended by the DCLG guidelines. All facilities (shops, schools, health etc.) are pretty much only accessible by car.
This site should not have been included as a viable option and should be removed from the list.
GT19 Birmingham Road, Budbrooke
This site is on the A41 to Solihull between this road and the canal. The plan, which is not to the scale of 1:10000 stated in page 43 shows a brown line around the site, demonstrating its restricted nature. It would appear to be about 40m by 40m or 1600m2 so if a plot size is 500m2, then it will only take 3 pitches at most.
The site is an untidy corner but it is close to an urban community. Access could be obtained off the lane that goes south to Ugly Bridge and if the site is fenced and planted it could be reasonably self-contained and screened from the Birmingham Road. However, it would be more liable to succeed if it was limited to 3 pitches.
GTalt01 Brookside Willows, Banbury Road
This site, if it is to be used, needs very careful consideration. It is on the Banbury Road and Castle Park, a Grade 1 historic park, is on the opposite side of the road. It is part of a major visually powerful route into Warwick and forms a major route from the M40 and traffic approaching from the south to visit the area and Castle. It is a major tourist as well historic heritage.
It was granted permission as a holiday caravan site so if used for Gypsy & Travellers, unless this element is successfully run and does not deter visitors, then it will never become that. The District Council needs to decide which group of visitors they wish to attract.
It may be possible to do both. If the number of pitches is constrained to about 6 and a part of the site to the east is selected for the purpose with its own independent access from the Banbury Road and the site is run to a high standard, then it could still be viable as a tourist caravan park.
Providing that the size of the permanent site is limited to 6 pitches taking 100m by 40m of the south east corner of the site with fencing and strong shrub planting around it, it would be more or less be invisible to visitors and if run successfully would not prevent the rest of the site being used for normal caravan purposes. It would also be essential to protect the Tach Brook and its embankments from pollutants, human usage and detritus so that can be a successful wildlife corridor that feeds clean water into New Waters and the River Avon.
5. Alternative Sites

GT02 Land abutting the Fosse Way close to the A425
This area of land is a prominent and valuable piece of landscape on the Fosse Way and a caravan site for anyone, travellers or tourist caravans, would be a extremely negative in this location. So this site should not be used.
However on the east side of the Fosse way, there is The Fosse Exhibition complex and North Fosse Farm. It would be possible to provide a small permanent site in this location using existing services and access and to screen the site with substantial planting.
But it is not suggested that this should considered in this consultation.
GT05 Land at Tachbrook Hill Farm
This land should not be considered for a permanent site because
* It is on the Banbury Road and this is a major route from the M40 to Warwick and Warwick Castle and as such it is part of a major tourist attraction, enhancing the economy of the district. A G & T site here would be clearly seen by visitors coming into the area and be negative to the visitor experience.
* The barn north of the farm buildings at Tachbrook Hill Farm is Listed Grade II. The site suggested is land immediately to the north of the barn and so is part of the context of the listed building. Any development on this site would not be appropriate and is contra to the NPPF.
* The Banbury Road is a fast road. It connects to junction 13 of the M40 only 500m away from Tachbrook Hill Farm and drivers are normally accelerating up to motorway speeds in anticipation of the motorway or when coming off the motorway have not readjusted to non-motorway speeds. Any new junction for slow moving traffic would be a major safety hazard.
* The Banbury Road and its junction with Mallory Road are known accident black spots including a history of fatalities. The frontage to Banbury Road is lined with Oak trees and any sight lines required for a new access would require removal of a considerable number of them. This is not acceptable and it would make the site even more open to the visitor transport route.
* The WCC Landscape Sensitivity, Ecology & Geological Report for the New Local Plan assessed the landscape sensitivity as High. This indicates that development for any purpose should not be permitted.
* It is within 400m of the M40 on which vehicles can be seen travelling along the motorway, demonstrating a straight noise line to the site. It is too close to the motorway and the traffic noise on this site, particularly at night, or the wrong cloud base level, is high.
GT06 Land at Park Farm
This land should not be considered for a permanent site because
* It is on the Banbury Road and this is a major route from the M40 to Warwick and Warwick Castle and as such it is part of a major tourist attraction, enhancing the economy of the district. The land shown on the plan on page 53 is clearly visible to traffic using Banbury Road so substantial visual screening would be required.
* It is close to Castle Park which is a grade 1 Listed Park and is part of the parkland layout for Warwick Castle. Visually, the Castle Park, The Asps farm and Park Farm are all part of the rural context for the Castle and the entrance to Warwick from the south.
* Using part of Park Farm may affect the viability of the whole farm and that would be an unacceptable outcome of taking part of it as a G & T permanent site.
* It is remote from any community and does not have easy access to local services and to social contact with other residents in the community. It is also remote to schools, health and GP services.

GT08 Depot west side of Cubbington Heath Farm.
This site is on the northwest side of the A445, Leicester Lane, from Cubbington to Stoneleigh. The plan, which is not to the scale of 1:10,000 stated in page 55, shows a brown line around the site which is currently a road salt store used by the County council on lease from the current owners. It is presumed that this use would need to remain in the future.

The whole site is rectangular about 200m by 100m and has a good access to the south of the site from the road. The salt store occupies the southern 2/3rds of the site.

The northern end is grassed and is hedged to the road, the northern and western boundaries. It is not used in the salt operations as can be seen in the aerial photo. This part of the site is about 60 by 100 or about 6000m2 so at 500m2 per pitch could accommodate 12 pitches. However, to ensure retention of a substantial part of the green area, only 7 pitches should be provided on this site that would only require 3,500m2 of the available area. In the remaining area additional tree planting should be set out to compensate for any loss of green space that might occur.

Access to the site could be via the existing depot access or could have its own direct access to Leicester Lane but this would require removal of the hedgerow to the road to get adequate site lines. Since the salt store is only used in cold weather it is possible that this limited usage could be managed with the access to the G & T site from the existing access.


The site is close to the farm complex but is over 600m from the crossroads at the north of Cubbington. So it is a convenient distance to the urban area for local services, schools health and for social contact with other residents in the community as advised in the DCLG guidance. It is not visible from the road so would provide privacy to the tenants and although it is in the Green Belt would only have negligible impact on the area, not reducing the distances between the urban areas so separated.

see attached

see attached

see attached

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

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 42):
"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. Please explain what the Council means by this?
"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. What is the difference between that site and this one?
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.

On top of all this Site GT19 is located in the Green Belt. The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, and the Council has failed to demonstrate any "exceptional" circumstances. It should simply not be promoting any Green Belt site above any non Green Belt site. I am aware of correspondence from a Warwick DC officer in the consultation round in 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." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable because the need can be clearly met from non Green Belt sites.
Site GT19 is clearly unsuitable for this use. There are fundamental questions outlined above that I would like a response from Council officers on please.
Please respond to this point about the Green Belt and other questions that have been asked above.
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
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."
This, rather than sound planning reasons, seems to be the principal factor in the Council's site selection process. You are not fully or fairly representing the situation by omitting this information in this case.
Please could Council officers explain this inconsistency? Please can Council officers explain the selection process between Preferred and Alternative sites?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
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 cases where the sites' proximity to a LWS has been included within the commentaries in Section 7.
Please could Council officers explain this inconsistency?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is 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"
Please could Council officers explain this?
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.
Could Council officers please explain this shortlisting process, and provide copies of scoring sheets?
7. Sites Summary Table
GT19 - OBJECT
This key point has 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:
We are aware that the Council recently rejected the proposed development of a similar site between the canal and Birmingham Road owned by Mr Arkwright, closeby to the west along the Birmingham Road.

How does the Council reconcile the refusal of this proposal with listing GT19, a similar nearby site, as a Preferred Site?
7. Sites Summary Table
GT19 - OBJECT
This key point has 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:
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.
Given the congestion, how does the Council think that the movement of large vehicles into and out of the site will be managed?
7. Sites Summary Table
GT19 - OBJECT
This key point has 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. Ecological factors are important as the site is adjacent to the canal, and occupation / development of this site will impact on the visual amenity of the Grand Union Canal.
2. The Council's own plans show that this land has a high sensitivity to housing development.
3. The Grand Union Canal Local Wildlife Site is adjacent to the site.

Why was point 3 not mentioned in Section 7 of this document? Why is GT19 proposed as a Preferred Site given this sensitivity?
7. Sites Summary Table
GT19 - OBJECT
This key point has 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:
There is the possibility of flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly. Part of the site is within high flood risk Zone 3 (the proposed site is only 0.3 acres in size).

With part being within a high flood risk Zone- why has GT19 therefore been proposed as a preferred site?
7. Sites Summary Table
GT19 - OBJECT
This key point has 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:
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?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states:
"Services available on site as currently used by Caravan and Camping Club"
This is seemingly presented as a factor supporting GT19 as a Preferred Site.
Please explain to me the treatment of this factor compared to the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states as a supporting factor:
"Possible use of existing access points"
1. There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.
2. 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?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states:
"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
What evidence is the Council using to make this statement? Please respond.
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
Why is GT19 a Preferred Site? Please respond.
7. Sites Summary Table
OBJECT
As a general point, but with specific regard to site GT19. the commentary and treatment are very one-sided:
1. As a standalone because factors mentioned in the full site assessment for GT19 are omitted from the policy document - this misrepresents the site characteristics
2. There is great inconsistency in the commentary on factors across different sites. For example the phrase "Services available on site as currently used by Caravan and Camping Club" is used as a supporting factor in GT19 but a negative factor for GTalt22.
How can this be? This seriously undermines the soundness and confidence in the Council's approach
3. Warwick District - Context
3.6 - OBJECT
The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, not "special". This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should simply not be promoting any Green Belt site above any non Green Belt site.
I am aware of correspondence from a Warwick DC officer in the consultation round in 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." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable.
3. Warwick District - Context
3.5 - OBJECT
The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, not "special". This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should simply not be promoting any Green Belt site above any non Green Belt site.
I am aware of correspondence from a Warwick DC officer in the consultation round in 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." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable.

To whom it may concern
Regarding the consultation on the Preferred Options Sites for Gypsies and Travellers, I refer you to my below comments:
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is 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"
Please could Council officers explain this?
Please respond.

To whom it may concern
Regarding the consultation on the Preferred Options Sites for Gypsies and Travellers, I refer you to my below comments:
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is 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"
Please could Council officers explain this?
Please respond.