GT06 Land at Park Farm/Spinney Farm (amber)

There is no easy access to GP surgeries, schools etc without driving. Access to Banbury road by vehicles can be hazardous as it's a fast road, particularly whist towing large vehicles. There are no mains services provision on site. This site is near to Castle Park and would have a potential impact on the historical approach to Warwick along Banbury Road. Overall, I do not see how this site fits any of the criteria set out by the council.

This site is not appropriate for a Gypsy / Traveller site for the following reasons:

There is no mains sewage therefore waste disposal would be a problem.

Vehicles travel quickly along Banbury Road, and vehicular access could present a level of danger.

There is no footpath, therefore no pedestrian access. There are also no schools or GP surgeries.

Banbury Road is the one of the main approaches to historic Warwick. It is likely that a site in this location would have a negative impact on the natural and historic aspect of the town of Warwick, particularly given the proximity to Castle Park.

We write with regard to the identification of Brookside Willows on Banbury Road as a potential site for gypsies. This location appears entirely inappropriate, being next door to a Grade 1 Listed Parkland and a tourist route into Warwick. The site also has no amenities or infrastructure or public transport available to it.

We also understand it is proposed that the land opposite the entry to our property on the Barford Road. Aside from not wanting such a site to be opposite our entrance (which is in regular use every day) again this seems an inappropriate site. There are no facilities or amenities available, no public transport, and we understand the site is also part required to be used for grazing as it was previously a rubbish dump. It is also a very busy road with traffic often passing at 70mph and there are no footpaths available.

Please let us know if there are other avenues we should be pursuing in order to object to these proposals.

This site is unsuitable as it will adversely affect the viability of the farm by spliting the land into 2 sections and restricting access to the western part. Valuable agricultural land will be lost and it also requires compulsory purchase. It will adversely affect the visual impact on the approach to the Grade 1 Listed Park and Garden at Warwick Castle Park. There is also a possibility of contamination from a former landfill site. There are no nearby facilities for this site. The proximity of two major roads will increase air and noise pollution and make access dangerous.

Compulsory purchase would be required, and the site would split the farm, making access between its East and West parts awkward, adversely affecting its viability as a business. There may be noise and pollution issues from the nearby major roads, and possibly also from former landfill use of part of the site. Visual impact on the Grade-1-listed Park and Garden at Castle Park could be adversely affected. No facilities or services are near the site. Watercourses and ponds need protecting from any development, and further study of them might affect use of the site.

I strongly object to this site being used for G&T as it is on an old rubbish tip, close to high noise roads and motorways, has no local amenities, bus stops or footpaths and is on the main route into Warwick that will impact tourism and visitors. There are no utilities and its right next to Warwick Castle park, a historic and protected area.

Concerns relating to
* Impact on Tach Brook and water quality
* Cost of construction of electricity supply
* Impact on local wildlife habitats
* Safety implications of additional traffic
* Noise from M40 and A452 - potential air quality issues and therefore health issues
* Limited capacity of local schools - oversubscription already at Bishops Tachbrook - sustainable travel access to schools and other services is low
* GP surgery, school and public transport capacity and access
* Safety issues relating to access and increase in vehicular traffic
* Integration into landscape without harming character of area.
* Difficulties integrating into two distinct sections of local community
* Sustainable travel gains from living and working in one place negated by visiting traffic to site.
* Impact on local businesses
* Infrastructure

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.

I am responding to the consultation on gypsy and traveller sites. My response is focused on the sites nearest to where I live (Bishops Tachbrook) as I can respond more knowledgeably on these.

GT05 Tachbrook Hill Farm (alternative site) - This location is entirely unsuitable for development as it will ruin the ruin the rural environment that, once lost, cannot be regained. The land is good agricultural land and therefore should be used for such purposes, with less good farming land used for development where appropriate. The access to this site is too close to a junction that is already problematic in terms of accidents, which will only be aggravated.

GT15 Europa Way (preferred site) - This site would result in dangerous access to Europa Way and it is less well suited to offering proper facilities/amenities.

GTalt01 Brookside Willows (preferred site) - This site appears to be reasonably well suited to the proposed development as it has already been approved for a caravan site and is closer to towns which are better placed to absorb the demand on amenities. The infrastructure is already in place which makes this a sensible option.

GT06 Park Farm/Spinney Farm (alternative site) - This site is too close to an important local tourist attraction, Warwick Castle, and is unsuitable as it may detract from the appeal of this historical site. It would also ruin the rural environment in this area.

I hope you will take these comments into consideration.

GT05 Land at Tachbrook Hill Farm, Banbury Road (WDC Alternative Site)

* Close to M40 and A452 with accompanying noise pollution and access issues.
* Already difficulty to exit village on A52
* Flooding issues on Mallory Road
* Proximity to Village Incompatible with wanting to live apart from settled community.
* Small village facilities-part time surgery, single form entry primary school
* Visual impact on area
* Can school facilitate the children and any special needs alongside the new housing development
* Field floods
* Noise generated from site
* Main road into village already dangerous
* In 1992 all BT residents were compensated for noise pollution due to siting of M40. GT05 is closer to M40 than BT village. By the precedent set for compensation this makes the site unsuitable for Caravans due to noise. A452 is a main arterial route to M40(s) and to Gaydon Site from Leamington /Warwick making this an extremely busy road especially during morning and evening rush hour.
* Totally unsuitable. Good agricultural land. Will have developmental impact on the approach to the village.
* Exit onto the lane and or main road will be dangerous. Too close proximity to houses.
* Photographic evidence supplied of flooding
* Too much of a vast open space
* Compulsory purchase is unfair in order for the G&T community to operate the site as a business.
* Busy main road surrounding the site.
* No mains set up
* No footpath to school/ docs etc.
* Not suitable for business use.
* Busy junction
* School and Local GP surgery already oversubscribed
* Visual Impact
* Objection - Dangerous Junction
* Not a great entrance to the village
* Only 10 minute walk from Oakley Wood (via wide verge) and opposite guide dogs breeding centre, so not a good idea
* Accident blackspot
* Water logged running across the road
* Visual impact on entering village.
* Compulsory purchase would be required
* Cost to taxpayer
* Objection - subject to flooding
* Objections - adjacent to very busy Banbury road
* Adjacent to a very bad junction - many previous accidents

* North west corner subject to flooding
* Not a level site
* Very bad impact in visual amenity when travelling south on the Banbury road
* Objection - Hill Farm - Loss of visual impact on open county landscape
* Objection - site not suitable for business use.
* Objection - very close to extremely busy road and dangerous junction
* Most unsuitable site - Busy road junction
* Unpleasant vista entering the village
* Too close to village if site used as a business use site, noise would be a problem
* Doctors surgery only part time
* Can only be obtained by compulsory purchase
* Objection - risk of flooding
* Road access onto 2 busy roads which are already and accident blackspot
* Impact on environment-visual impact etc.
* A452 is a death trap. Pulling out of turning onto. There have been many fatalities at that junction and near it
* Dangerous turning into Village
* Visually damaging to our beautiful village
* Road to busy (Banbury Road)
* No footpaths, no bus route
* Reputation damage to our primary school
* As drivers drive towards the motorway on the A452 towards going onto junction 13, they increase their speed before going onto the slip road
* The access from the farmers drive there is a blind spot at the brow of the hill so very dangerous for pulling out of and turning into
* Visual impact for village would be horrendous
* Strongly object - makes an already junction more dangerous
* Adverse visual impact
* Not suitable for business use
* Prone to flooding
* Local school already over-subscribed and not footpath to village
* Compulsory purchase necessary
* Disturbance to guide dog breeding centre Oakley wood road and crematorium
* Land owner very reluctant to sell land - compulsory purchase would be a protracted process
* Strongly object because of impact on village approach
* Size out of proportion with village area
* Very dangerous road junction
* Impact on BT facilities - school surgery shop
* Flooding frequently
* Disastrous effect on rural landscape
* Need to compulsorily purchase Tachbrook (Hill Farm)
* Accidents and fatalities at this junction
* Too close to very busy roads
* accident prone junction

* site susceptible to flooding
* compulsory purchase required
* adverse visual impact on open countryside
* high negative impact on immediate area -oakley wood is protected
* concerned about impact on Guide Dog Breeding centre chose for is safe location for breeding and quietness
* compulsory purchase would be required
* flooding from field running through gardens onto the road
* flooding field and running across the road
* objection - visual impact on entering the village
* should be left for farming
* already hazardous junction - accident waiting to happen
* eyesore for the village entrance
* liable for flooding
* accident blackspot
* local school is cannot accept more children especially with special needs
* Oppose - impact on countryside
* Mallory road like a racetrack now -more would be out of order
* Business use would destroy visual amenity
* Site not suitable for business use
* Does not have any connection to services to provide sustainability (sewage/ water etc)

GT06 Land at Park Farm, Spinney Farm (WDC Alternative Site)
* Would harm the rural buffer zone and destroy the visual amenity on the approach to Warwick
* Severely restricts access for the owner of park farm to his remaining land
* Proximity to major roads A452 and A425 with accompanying road noise pollution and access issues
* Visual impact on entrance to historic Warwick
* Already been used for construction company for road alterations
* ?compulsory purchase expensive
* Visual impact on countryside
* Compulsory purchase necessary and would be resisted (probably)
* Adverse effect on viability of the farm business
* Adverse visual impact on the countryside
* Owner not willing to sell - expense of compulsory purchase
* Objections - access to busy road
* A good alternative - better than village
* Which school would the children attend? BT would it cope alongside new housing development
* Is this site set for facilities needed by Gypsies and Travellers
* Adjacent to very bust roads
* With Barwood application for the Asps, includes schools etc, surely this site (and Brookside) would have less impact on village and amenities.
* As an alternative, better than GT05
* Easy access to Leamington
* Road access onto A425
* Close to other proposed site GT01
* Access to schools in Warwick Leamington
* My second preference but access onto busy road
* Impact on rural landscape and approach to Warwick Castle tourist attraction
* Compulsory purchase required
* No Bus route
* No access to facilities
* Park Farm ought to be "preferred" and Europa way, "alternative" (x2)

GT15 Land to east of Europa Way (WDC Preferred Site)
* Access onto Europa Way would be dangerous
* BT would have to serve the community but capacity at school is questionable
* Doctors surgery is aleady under pressure
* No bus route into Bishops Tachbrook Warwick or Leamington
* GT15 is opposite busy trunk feeder
* BT school and Surgery are already under pressure.
* Minimal visual impact
* Not suitable. Floods regularly
* Access onto and off v fast road
* Heavily wooded - no facilities
* Steep sloping ground
* Road access would need improving
* Second preferred site over GTalt01
* Minimal visual impact - well screened
* Access would appear to cause problems
* No compulsory purchase required
* Busy road
* Only small site and therefore more sites needed (no doubt in Tachbrook)
* No pavements
* On motorway feeder
* Not on bus route
* On busy road accompanying road noise and pollution and access issues
* Concerns over flooding and water contamination
* Small manageable site
* Closer to urban area for employment services education and health
* Would require clearing woodland
* After Brookside Willows, the most suitable site
* Screen from road
* Close to Leamington for doctors etc
* Land owned by Council
* Busy road access already an accident hazard site.
* Trees would have to be felled increasing flooding

* No pavements on Europa Way or access to public transport on foot hence the nearest facilities are not accessible.
* Very busy main road access
* Land floods
* No pavements/ public transport
* Obviously some trees will have to be felled therefore not so well screened
* Well screened. Minimal visual impact
* Busy road
* No site set up.
* The crazy option!! Road access and fast main Europa Way would need traffic calming measures
* Already owned by the council
* Already owned by the council
* Reasonable screening and access
* Low visual impact
* Already owned by Council

GTalt01 Brookside Willows, Banbury Road (WDC Preferred Site)
* Ideal location well screened
* Site already part prepared
* Good road access
* Needs a safe pedestrian footpath into Warwick
* No immediate neighbours
* Infrastructure already in place
* Well away from main road
* Screened
* Preferred site
* Good access to site already there
* Easy access to Warwick Town by Public transport/ on foot
* Less traffic that other main roads locally
* Reused ground - no flooding
* Good site
* Planning for Caravan Site anyway: minimal difference
* Facilities already in existence
* Road access, screening etc. in place
* No compulsory purchase necessary
* Minimum development needed for occupation
* Already partially developed
* Able to be well screened to minimise visual impact
* Preferred - ( least worst)
* Set back off road
* Cars have to slow because of T/ light approach - safer option
* Planning permission approved for a caravan park
* More suitable that some of the alternatives
* Well set back from the road
* Was originally well screened - trees can be replanted.
* Problem entering Warwick over bridge
* Very Close to Warwick parkland - will there be plans put in use regarding access from this site to the park?
* When this site was being used for Landfill, vehicles turning right into it presented considerable danger to other vehicles travelling towards Warwick. Road is even busier now of course. The reality is that drivers do not take care as the go around the bend in the road and being on down slope braking distances are increased.
* Concerns over proximity to water what is the direction of flow?
* Need to overcome contamination issues
* Visual impact entering historic Warwick
* Already designated as a site for caravans
* Well screened from road with trees
* Meets 1/2 the number of pitches required
* Preferred site: already on main road
* Set away from people already homed
* No major impact on surrounding area
* This makes sense: far away from main road not to be seen and already Planned as a caravan park.
* Preferred site as long a screening is maintained
* Basic work already completed
* Reasonable road access
* Access to Warwick Castle Park would need to be controlled
* This is the least worst options
* Access and facilities already there.
* Preferred option:-site partially developed. Has independent access. No major impact on surroundings
* Already partly developed
* Discreet
* Will not devalue the surrounding area
* Well screen
* Has specific road access
* Already partially developed
* Preferable However!! If site on Harbury Lane is passed, then there will be 2 sites affecting/ impacting Warwick Gates
* Preferred: Facilities already in place. Road access is in place and screening
* Most suitable site
* Best access ( and safest)
* Quiet location and screen from road.
* Good access and screening
* Already partly developed
* Established infrastructure screened and well shielded and safe
* No 1` preferred
* Preferred site. Infrastructure already exists
* Good road junction

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.

I wish to oppose this proposed site for the following reasons:- Would harm the rural buffer zone and destroy the visual amenity on the approach to Warwick The partial development of the farm would seriously effect the viability of the farm as a business entity Adverse effect on the rural landscape and the approach to Warwick Castle tourist attraction The site is close to the m40 and A452 and this proposed development will add to the existing noise pollution and access issues

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

I wish to make the following comments and objections with regard to the 'preferred & alternative' sites proposed within the boundaries of the Parish of Bishops Tachbrook.
GTalt01.Brookside Willows,Banbury Road.
1) Ideal location as it is well screened.
2)Infrastructure already in place.
3)Good road access into Warwick & on foot,with the provision of new footpath.
4)Planning for a caravan site already in place.
5)This site provides the best acess to all Warrwick amenities,i,e, schools,shops,medical facilities etc.

GT15,Land at Europa Way.
1) Extremely dangerous location due to fast moving traffic on Europa Way,this will make entrance & exit to & from the site unsuitable.
2)Heavily wooded & sloping ground subject to rainfall run off from surrounding areas.
3) Limited pitch sites available relative to the infrastructure costs to give a suitable site with safe access.

GT05.Tachbrook Hill Farm, Mallory Road.
1) Too close to existing properties in Holt Avenue.
2)No existing adequate screening to the site,new planting will take yeaers to mature.
3)Access onto Mallory Road will be dangerous & not ideal due to the close proximity to the junction with Banbury Road.
4) Too close to the M40 & A452 with the accompanying noise pollution.
5)Will create an unacceptable vsual impact to the Western approach to the village & also when viewed from the Banbury Road.
6)This site is good agricultural land and every effort should be made to keep it so.
7) The village facilities of the part time surgery & the single form entry primary school will be stretched to cater for even more
expansion in addition to the proposed new housing requirements.

GT06. Land at Park Farm/Spinney Farm.
1)Would harm the rural buffer zone & spoil the visual amenity on the South approacn into Warwick.
2) Considerable screening will be required to lessen any impact,& this will be costly & take years to mature.
3)The close proximity to the M40 &A452 is detrimental due to noise pollution & access issues.
4)Loss of good agricultural land which provides a buffer to the Castle Park & Warwick.

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Site GT05. This site is unsuitable as it is adjacent to a dangerous junction and parts of the field are regularly flooded, particularly near the dangerous junction with the A452. Development will lead to further run off causing even more dangerous traffic conditions. Will have a disastrous effect on the rural landscape when entering the village of Bishops Tachbrook. This field is best left for the grazing of sheep.

Site GTalt01. This seems to be a preferred site as it has already had much investment from the council. Not using this site would be a waste of council tax. Easy access into Warwick for schools and services by foot and reasonably screened from the road. No destruction of quality agricultural land at this site.

Site GT06. This site would see the destruction of high quality farmland. The site is not sustainable as it is too far from populations and services.

Site GT15. Europa way is regularly grid locked. Several accidents have occurred on this stretch of road. Access to a community along Europa way will lead to more congestion and a higher risk of accidents

Please see below my comments in reference to the following sites:

GT04: Land at Harbury Lane/Fosse Way - Object

- There are no footpaths connecting to this site, therefore pedestrian access will be dangerous as peak travel times.

- Increased level of healthcare required by the Gypsy and Traveller community will put pressure on the local GP Surgery, which currently only runs on a part time basis.

- There has not been an appropriate solution found in reference to the Sewerage Disposal. A mains connected sewer is preferable, but it is stated in the consultation document that this is "unlikely".

- Cost to move the football club would have to be subsidised by the District Council, this will be a costly exercise with no gain.

GT05: Land at Tachbrook Hill Farm - Object

- Bishops Tachbrook School is already over subscribed, however the consultation document states that 'Children living on this site would secure places over children at a greater distance.' This disadvantages other permanent residents in the village.

- The site is in close proximity to Bishops Tachbrook School and will therefore have implications for the application of "Sara's Law".

- Extra pressure will be put on the local facilities, small local shop.

- Additional traffic would end up using the already congested roads into Warwick and South Leamington

- Increased level of healthcare required by the Gypsy and Traveller community will put pressure on the local GP Surgery, which currently only runs on a part time basis.

- Site is located close to the M40, this makes it unsuitable for residential development due to noise pollution and access issues, at an already busy junction.

- "Compulsory purchase powers" required on this site would further increase the costs to the planning process. In addition the economic viability of Tachbrook Hill Farm may be compromised.

- There has not been an appropriate solution found in reference to the Sewerage Disposal. A mains connected sewer is preferable, but it is stated in the consultation document that this is "unlikely".


GT06: Land at Park Farm/Spinney Farm - Object

- There is the potential for viable agricultural fields to be dissected, through use of only the "central section" of the site.

- The consultation document points out that whilst the site is within Flood Zone 1, 'There is however an ordinary watercourse running through the centre of the site and along the eastern boundary for which no modelling has been undertaken. This could affect the capacity of the site for development and therefore further assessment needs to be undertaken prior to allocation.' The potential contamination of this watercourse from the gypsy and traveller site should be taken into consideration given the possibility of contamination of the River Avon.

- The consultation document highlights possible contamination issues relating to a former landfill site, this will reduce the developable area, making the site less viable.

- Again the site's proximity to major roads A452 and A425, with accompanying road noise pollution and access issues make this site unsuitable for residential purposes. The consultation document states, 'There may also be noise issues connected with proximity to Warwick By-Pass depending on where exactly the site is located'

- "Compulsory purchase powers" required on this site would further increase the costs to the planning process. In addition the economic viability of Park Farm/Spinney Farm may be compromised.

- Increased level of healthcare required by the Gypsy and Traveller community will put pressure on the local GP Surgery, which currently only runs on a part time basis.

- There has not been an appropriate solution found in reference to the Sewerage Disposal. A mains connected sewer is preferable, but it is stated in the consultation document that this is "unlikely".

GT15: Land east of Europa Way - Object


- Bishops Tachbrook School is already over subscribed, however the consultation document states that 'Children living on this site would secure places over children at a greater distance.' This disadvantages other permanent residents in the village.

- There are no footpaths connecting to this site, therefore pedestrian access will be dangerous as peak travel times, with the potential for increased accidents.

- Increased level of healthcare required by the Gypsy and Traveller community will put pressure on the local GP Surgery, which currently only runs on a part time basis.

- There has not been an appropriate solution found in reference to the Sewerage Disposal. A mains connected sewer is preferable, but it is stated in the consultation document that this is "unlikely".

- Site is located close to a busy road, this makes it unsuitable for residential development due to noise pollution and there are access issues, at an already busy junction/main road into Leamington and Warwick.

GTalt01: Brookside Willows, Banbury Road - Comments

- This site does have footpath access to the town centre of Warwick and its facilities.

- The Tachbrook runs along this site and therefore there may be potential contamination of the Brook and River Avon.

- The consultation document highlights possible contamination issues relating to a former landfill site, this will reduce the developable area, making the site less viable and unsuitable for residential use.

- The site is well screened from the road and more of the infrastructure is already in place.

- This site already has planning for a Caravan Site

I would like to take this opportunity to register mine and my family's complaint at the proposed gypsy and traveller sites in the parish of Bishops Tachbrook.
As a resident of Bishops Tachbrook I feel duty bound to complain about the disgusting treatment that Warwick dc has shown to us on this matter . It amounts to the death of a village and the raping of a whole community.
I am complaining on the grounds of the fact that the villagers and the traveller community will not be able to integrate and as such the breakdown of the current harmonious community will be lost.
I will be using whatever media relationships I have to expose the councils plans as well as starting a campaign through social media where anybody who is experiencing the same treatment will be able to register their protest

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

Preferred Site GTalt01
Brookside Willows Banbury Road
Of the proposed preferred sites surrounding Bishop's Tachbrook this one appears to be the most suitable. It has already been developed with infrastructure as a caravan site at great expense but has not been utilised as such for whatever reason. I assumed it was because it is the site of an old dump and there are problems caused by contamination. However as a preferred option this is either not the problem or it can be overcome. I do not know the ownership of the land and whether the site will have to be purchased and at what cost.

Located in a dip, the site is well screened by surrounding woodland and will not impact the landscape. Much of the site is reclaimed land of no great agricultural value. It is elevated above the Tach Brook so not prone to flooding and is near all local amenities & facilities with an already built access to the Banbury Road. The site meets all the criteria as deemed necessary in the guidelines of the NPPF. For all these reasons this site would be suitable for a permanent and transit G&T site.



Preferred Site GT15
Europa Way Bishop's Tachbrook
This site abuts a very busy link road making access and egress very dangerous. The site is steeply sloping and would require major/expensive works to level. Moreover the land is wooded without any facilities and utilities such as sewerage etc. For these reasons I think the site would be unsuitable for a G&T site.










Alternative Site GT05
GT05 Tachbrook Hill Farm, Mallory Road Bishop's Tachbrook

Situated on the edge of Bishop's Tachbrook near the junction of Mallory Road and Banbury Road; this is already a very dangerous junction where a number of accidents including fatalities have been recorded. Increased traffic especially vans and lorries from the proposed G&T site would add to the danger of this junction and access to Mallory Road.

The site on rising elevation is very exposed and would be detrimental to the approach view to the village. In addition the site presently used as agricultural land. Indeed the farmer/landowner is not willing to sell and the site would be subject to compulsory purchase. In addition the extra transient and or permanent G&T population will put an excessive strain on the resources of the village school and part-time GP surgery. For these reasons I believe this location would be unsuitable for a G&T site.



Alternative Site GT06
Park Farm/Spinney Farm Banbury Road

My objection to this site is on the grounds that it would make an enormous adverse affect on the rural landscape and visual approach to Warwick as a major tourist destination. It is close to the important A452 & A425 junctions with heavy motorway access traffic and commuter traffic into Leamington, Warwick and Aston Martin and JLR at Gaydon. Apart from increasing noise and pollution the extra traffic entering & exiting on to the A452 from the site would add an extra road hazard to the already overloaded roads in the area.

The site is also farmland and would diminish the viability of running a farm enterprise. For these reasons this would not make and ideal G&T site

Alternative site GT04
Land at Harbury Lane/Fosse way Junction
It would seem perverse to turn a purpose-developed football ground (home of Leamington Football Club) into a G&T site. The expense and disruption of relocating the Club has not been evaluated or for that matter costed. For this reason alone this would make this a non- viable site. Harbury Lane is already a very busy commuter route from surrounding areas and this site with vehicle entering & exiting on to it would add to the traffic burden and cause a major safety hazard.

It would also be highly visible travelling down the hill from the Fosse way and become an unnecessary blemish on the rural landscape. Overall these reasons make this site a non-viable a G&T site.

WDC Local Plan Gypsies & Travellers Preferred Options Consultation


The JPC accepts that allocations must be made for the G&T community within the WDC New Local Plan - rather than relying on sites coming forward through the conventional planning process and we also understand the importance of G&T issues in the Local Plan process, however the JPC believes that any such allocation must be made on a fully democratic and objective basis.

When the June 2013 consultation was staged we were unimpressed with the level of detail provided and very disappointed at the lack of local knowledge and erroneous justifications for selected sites. It can be no surprise that local communities erupted in response to such ill thought-out blight on our district.

Given the levels of residents' responses it is surprising that the Preferred Options consultation has now followed with a similar level of erroneous information and even less quantifiable justification for the Preferred Option choices.

We find the presentation of material confusing at best given that much of the important evidence is buried on the website as "Further Evidence" and "Background" and much that is there is either erroneous and/or conflicting with the March 2014 PO document. At another level we and the vast majority of our residents who have commented found the "Drop-In Sessions" with just a couple of posters and scattered booklets to be a singularly poor way to disseminate information especially as the staff provided had minimal technical knowledge of the subject matter and made it clear that they would not be collating comment made on the day.

We are also concerned at WDC's apparent willingness to rely on the Compulsory Purchase approach given the associated costs and delays which will render most sites non-viable financially and non-deliverable in the terms required. Furthermore success of the CPO process has yet to be established as evidenced by the 2012 Mid Suffolk DC case when the Inspector found insufficient evidence to support CPO on the grounds of "public interest".

We would question WDC's election to limit site sizes to a maximum of 10 pitches, with some considerably less, as this means that site provision must then blight more communities and settlements than is reasonably necessary. If site size limitation is in order to facilitate management and policing this surely gives credence to many residents' concerns about crime and disorder in or near such sites.

Reduction in site size (or more specifically pitch numbers on individual sites) loses economies of scale in terms of establishment costs, management costs and land take whilst directly impacting a greater number of the general population.

National guidance suggests sites of 5-15 to be preferable and this would suggest that our required 31 pitches could reasonably be accommodated in two or at most three sites.

The JPC would suggest that any or all proposed sites could be best accommodated and assimilated in areas which are not current settlements and that they should be properly planned, at a very early stage, into much larger schemes preferably incorporating residential and employment development.

We find the cursory dismissal of such an approach (Page 12, end of section 5) totally unsatisfactory and unacceptable.

The JPC also believes that the Siskin Drive and Gateway area should be vigorously explored to create a site with a mechanism to accommodate the G&T community within an evolving area where they could best integrate with their surroundings.

Whilst reviewing WDC's commentaries on sites in the original and the current consultation we have found that they are erratic and inconsistent. Criteria are sometimes used to support a choice/site and at other times the same criteria are used in a converse manner. The way in which the supporting Sustainability and Sites Assessments have been used to arrive at the Preferred Options is opaque in the extreme and certainly the interpretation of the Sustainability Assessments based on colour coding appears to be minimally objective.

Examples of inconsistencies relate to noise impacts, site prominence in the landscape, flooding, agricultural land value/viability, proximity of services and pedestrian access/safety. Latterly, especially with the "GTalt" sites, there seems to be an inordinate reference to "surface flooding".

The paperwork provided and the public consultations staged also seem to take no or little account of the cost implications inherent in the various Preferred Option choices and we believe this should be a significant factor when making a final selection given the inherent importance of economic viability.

In consideration of the above the JPC has conducted an objective assessment of all the sites which have come forward under these consultations, as well as our lay skills permit, and concludes that not all of the selected Preferred Options are indeed the best sites of those presented.

The findings are presented in spreadsheet format showing support where we believe it to be appropriate. Where we draw different conclusions we offer rebuttal and further comments as seems appropriate and helpful.

The spreadsheet details are as follows:

* Column 1 - Site identification number and PO indication and JPC support or otherwise
* Column 2 - Précis of WDC comments
* Column 3 - JPC commentary
* Column 4 - Sites which JPC consider could reasonably be progressed (where sites cannot be integrated into "larger schemes").

Inevitably the JPC has been much exercised by contact from residents concerning sites proposed within our JPC parishes and we must comment that these sites seem to have been singularly poorly selected. This situation is not helped by the fact that they seem to have come forward accompanied by blatantly incorrect supporting information, viz:
* Repeated reference to Barford doctors' surgery - when the last part-time surgery closed over 30 years ago
* Inclusion of the Barford Bypass flood compensation pond area as site GT16
* Inclusion of Barford Community Orchard and Riverside Walk in GTalt12
* Inclusion of spillage/reed ponds within GT12 in March 2014
* Confusion over the maps for GT12 And GT16 in June 2013
* Confusion over the map of GT12 in March 2014
* Confusion over the map of GTalt12 in March 2014

On a purely local basis it seems bizarre and is certainly unacceptable to blight Barford, recently judged amongst the best 10 places in the Midlands (and number 57 nationally) to live, with the Preferred Options selection of such obviously poor sites. Should the Barford sites persist we are sure that residents will support the landowner in challenging Compulsory Purchase, increasing costs and delay to all concerned and further impacting deliverability.

We are also reminded that there is a duty to co-operate across boundaries and would draw your attention to the site which Stratford DC have at Blackhill, immediately adjacent to Sherbourne parish.

We hope that you will take this letter and the associated spreadsheet in the constructive manner in which it is intended, in order to assist in achieving the best possible solution for both the settled and travelling communities.

CONSULTATION ON GYPSY & TRAVELLER SITES FOR WARWICK DISTRICT

1. CPRE Warwickshire responded to the Options consultation in 2013. At that stage in the process, CPRE supported two locations in principle, which we considered would meet the practical need for about 25 pitches. These locations were
* Siskin Drive, SE of Coventry (adjacent or close to existing Coventry City Council official site)
* Harbury Lane, at Hobson's Choice (preferably where containers are now stored)

2. These two locations are unfortunately not listed among those put forward during the 2013 consultation. The 2014 Preferred Options consultation document at table 5.1 lists sites stated to have been advanced by respondents in 2013, but neither of these is included in the table. CPRE doubts that the need is for as many as 25 pitches by 2017, as stated by the District Council. Gypsies and travellers often hold land in other Districts, which is not made know in the needs surveys; and there is a risk of double-counting between Districts.

3. The comments on sites below assume this figure of 25 pitches; 30 could be provided if necessary at the locations we suggest.

4. CPRE Warwickshire in summary supports the following locations:

* Hobson's Choice, Harbury Lane, SE of Whitnash 15 pitches
* Siskin Drive, by Coventry Airport, S of Coventry City Council official site 10 pitches
* Birmingham Road, Budbrooke up to 5 pitches
GT04 Land at Harbury Lane/Fosse Way

5. This location is supported and was advanced by CPRE in 2013. We do not support the exact location, which would appear to take over or be alongside Leamington Football Club. This would be an exposed position not easily screened. We support the site on the map extract for GT04 called 'Hobson's Choice'. This is surrounded by a high earth bund, and is used currently for container storage. It lies behind Harbury Lane scrapyard and the old airfield hangar used for indoor go-karting. It would be very suitable for up to 15 pitches and would have no adverse effect on the surrounding environment. As Warwick District Council is willing to consider compulsory purchase of land, this site should be examined closely. The container storage activity need not be at this location and industrial land for it could be found elsewhere.

Siskin Drive, E of Coventry Airport

6. The failure to examine the Siskin Drive area further, and the rejection of it in the 2014 document without explanation, is regrettable. The established existence of the Coventry City Council official site at Siskin Drive, with no adverse environmental or social effects, indicates the general suitability of this area east of Coventry Airport. From the point of view of gypsies and travellers the site is also suitable as it has good road access and does not involve use of minor roads, and there are no private houses nearby. While the local authority boundaries at Siskin Drive are complex (Coventry, Warwick and Rugby all meet here), it should be possible for a Warwick District Council site to be located adjacent to or near the Coventry City Council site.

GT19 Birmingham Road, Budbrooke

7. This has had gypsy occupation in the past. The proximity of other buildings here and the non-agricultural nature of the land adjacent to the A4141 Birmingham Road makes this a potentially acceptable location, but only after the two sites listed above have been developed.


Response on other sites included in the 'Preferred' list (Consultation paper section 9) and on those not supported (Section 10, alternative sites)

GT12 W of Barford Bypass N of Shepham Lane

8. This is open countryside along the western side of the A429 Barford Bypass. It would be very visible, difficult to access and damaging to the setting of Barford. It should be dropped.

Gtalt01 Banbury Road, Warwickshire

9. A gypsy site on the historic road approach to Warwick town centre is not acceptable. This is still a classic rural approach to the historic town. The existing permission for caravans (non-gypsy) and the building of the access does not justify allowing this approach to be degraded by an unattractive and intrusive land use. The site is not being used at present and is better left empty so as to protect the historic approach and the setting of Warwick Castle Park.

GT02 Land at Fosse Way / A425

10. This is a large open landscape, between Radford Hill and North Fosse Farm. It is wholly unsuitable as a gypsy site, being very visible agricultural land. It is partly Grade 3a land and is next to a local wildlife site - the wood known as Parlour Spinney.

GT05 Tachbrook Hill Farm, Bishops Tachbrook

11. This is open farmland between the Banbury Road and Bishops Tachbrook village. With the M40 to the SW, the road is busy with traffic on and off the motorway. The junction between the Banbury Road and Mallory Road is not particularly safe; its rural location makes any junction widening or lighting highly damaging to the character of the immediate area.



Gtalt12 Land SE of Barford Bypass, Barford

12. This appears to have no merit at all as a site. The grounds for objection to GT12 (see above) apply equally to this site.

GT06 Park Farm, Banbury Road, Warwick

13. This is a large area of farmland at Park Farm, on the rural approach to the historic town of Warwick. It would be visible and harm this important setting to Warwick. It would be close to Warwick Castle Park. Similar reasons for objection apply to those listed above for Gtalt01, Banbury Road, Warwick.

GT08 Depot W of Cubbington Heath Farm, Cubbington

14. This location is only worth considering if HS2 is built on the line proposed, as it would then be degraded and could be acceptable as a gypsy site.

GT11 Hampton Road, south of Warwick Racecourse

15. The land north of Henley Road and east of A46 Warwick Bypass is part of Warwick's historic setting. Development of South West Warwick stops at the Henley Road. Urban development should not be allowed to cross it.

GTalt02 Woodyard, Cubbington Road, Rugby Road, Cubbington

16. This would be very harmful to the future of CubbingtonWood, which is replanted Ancient Woodland. The consultation document notes, "North Cubbington Wood is one of the prime cases for woodland restoration for the Princethorpe project which is a complex of woods and hedgerows, currently a Warwickshire Wildlife Trust Living landscape project funded by SITA Trust." A gypsy site here would harm the woodland's restoration and make it less attractive for visitors.

Gtalt03 Henley Road, Hampton-on-the-Hill

17. This site is being promoted by the owner. It would be very harmful to the openness of the Green Belt and to the current rural approach to Warwick from Henley-in-Arden if it were to be developed as a gypsy site. The consultation document fails to describe the appearance of this land or its prominence. It is where the Henley road comes over a crest and Warwick is seen on the skyline. It is too prominent a position to be considered.

Objection to GT15 Land to east of Europa Way (WDC Preferred Site)
I object to this site for the following reasons:-
Road access onto Europa Way, this is busy and also a fast road and liable to flooding. Road noise and pollution could be an issue.
No pavements on Europa Way, no access to public transport, nearest facilities not accessable.
Not screened as probably some trees will have to be felled on the site and may cause more flooding.
Land is not level and liable to flooding and may be water contamination issues.
Nearest facilities to site - can they absorb extra people, Bishops Tachbrook's school and doctors may not be able to cope.
Heavily wooded - possible impact on wildlife.


My preferred option GTalt01 Brookside Willows, Banbury Road (WDC preferred Site)
I prefer this site because:-
It is much more suitable than the other nearby preferred and alternative sites and should not impact on the value of surrounding area.
Meets half the number of pitches required.
Site has planning for caravan site already, so minimal difference and little chance of flooding.
The site has no immediate neighbours and set off the road.
The site is already part prepared, seems to have infrastructure in place already, it is discreet, well screened and easily to be screened off more as road is into Historic Warwick. It should have minimal impact on any surrounding houses.
Has good road access. Safer access to site and there is road junction already in place.
Easy access to Warwick by public transport or on foot if safe footpath made. Access to doctors, schools and facilities easier.


Objection to GT05 Land at Tachbrook Hill Farm, Banbury Road (WDC Alternative Site)
I object to any Gipsy/Traveller sites being erected on this site for the following reasons:-
The land would have to be compulsory purchased. It seems the farmer doesn't want to sell so could take some time to get land. The farmer would lose a source of income when the land will then be available for business use which is unfair.
The proximity to the village is incompatible with Gipsy/Traveler wish to live apart from settled community.
The size of the site is out of proportion to the village size.
The village school is single form entry. Would there be room for extra children and the help/facilities required for children with possibly special needs especially if more houses are built in the village or surrounds?
The village Doctors Surgery is only part time - can be hard to get appointment now.
The visual effect on the entrance to the village would be damaging - a good large piece of agricultural land plus a lovely field to be become an unpleasant eyesore and if used as a business site too, become a noisy addition to a quiet village.
In 1992 all Bishops Tachbrook residents were compensated for noise pollution due to the siting of M40, GT05 is closer to the M40 than the village. This then makes the site unsuitable due to noise from the M40.
Mallory Road and St Chads are busy roads through the village. School children crossing twice a day over Mallory Road would have to be considered, bring more cars through the village is not a good move. The A452 is a main arterial road route to the north and southbound M40, Leamington Spa and Warwick and to the various car companies in Gaydon. The junction of Mallory Road/Banbury Road is impossible to get out of at certain times of the day, increased village population will cause this is to be much worse. The junction is dangerous and there have been accidents and a fatality already. Much of the traffic on the Banbury Road does not adhere to the 50mph limit. The proposed access from the farmers drive is a blind spot at the top of a hill, very dangerous for pulling in and out of the site.
The land is not level, prone to flooding in the northwest corner which then floods the end of Mallory Road/Banbury Road.
There is no connection to services such as sewage and water on this land. Potential large cost to taxpayer.
There are no footpaths from the proposed site into the village and no bus stops by the site.
Potential disruption to Guide Dog centre on it's safe location and quietness and to Oakley Wood which is protected.