GTalt03 Land at Henley Road/Hampton Road, Hampton-on-the-Hill (amber)

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Budbrooke Parish Council has carefully considered the proposed sites in and around the parish. These are our comments.
Oaklands Farm, Birmingham Rd, GT19 - 5 pitches proposed

Site GT19 is in the Green Belt. Of the five preferred option sites currently shortlisted it is the only one in the Green Belt. Our contention is that there are no "very special circumstances" for development, the road is hazardous and similar development sites have been turned down by the Planning Inspector, and therefore GT19 should be removed from the options.

The Government has consistently stated that Green Belt Land should only be used in very exceptional circumstances.

On 1 July 2013, in his written statement to Parliament, Brandon Lewis MP, Local Government Minister stated:
"Our policy document planning policy for traveller sites was issued in March 2012. It makes clear that both temporary and permanent traveller sites are inappropriate development in the green belt and that planning decisions should protect green belt land from such inappropriate development ... .
... it has become apparent that, in some cases, the green belt is not always being given sufficient protection that was the explicit policy intent of ministers.
The Secretary of State wishes to make clear that, in considering planning applications, although each case will depend on the facts, he considers that the single issue of unmet demand, whether for traveller sites or for conventional housing, is unlikely to outweigh harm to the green belt and other harm to constitute the "very special circumstances" justifying inappropriate development in the green belt."

This was reiterated by Brandon Lewis in his 17 January 2014 statement:
"The Secretary of State remains concerned about the extent to which planning appeal decisions are meeting the government's clear policy intentions, particularly as to whether sufficient weight is being given to the importance of green belt protection. Therefore, he intends to continue to consider for recovery appeals involving traveller sites in the green belt."

In February this year The Minister responsible for Travellers, Brandon Lewis MP, said:
"Our policy strengthens protection of the greenbelt and the open countryside by making clear that Traveller sites are inappropriate for greenbelt development and that local authorities should strictly limit the development of new Traveller sites in the open countryside. Unmet demand — whether for traveller sites or for conventional housing — is unlikely to outweigh harm to the greenbelt to constitute the exceptional circumstances that justify inappropriate development in the greenbelt."
Indeed, the Planning Policy for Traveller Sites (PPTS) states:
"Policy E: Traveller Sites in Green Belt
14. Inappropriate development is harmful to the Green Belt and should not be approved, except in very exceptional circumstances. Traveller sites (temporary or permanent) in the green belt are inappropriate development"

The owner of the land at site GT19, Robert Butler, does not want to sell it for a Traveller and Gypsy site. Therefore a Compulsory Purchase Order (CPO) would be needed and Warwick District Council has said that a CPO could be used. This is in complete contravention of ministerial statements.

Oaklands Farm has been the subject of many planning applications over the years. It is a site within a wider hamlet of dwellings along the Birmingham Road, 4 houses immediately to the east towards Warwick, then beyond Ugly Bridge Lane, there is a Shell petrol station and a further 10 properties. At this point there is a roundabout, an entrance to Hatton Park. All the dwellings on the Birmingham Road are of long standing within the Green Belt. The farm has permission for caravan storage and a kennels business on the site:

A number of acceptable developments have been approved in the recent past, however, a significant number have not.

WDC's Level 1 Strategic Flood Risk Assessment Volume 1 states that each site must have an individual assessment. No such assessment is recorded for this site which has been prone to flooding from the Hatton Park development runoff and balancing pools. Water runs across the A4177 and onto the property where the site would be.

An application for using the site for the importation, storage and cutting of timber was granted by WDC Planning Committee subject to conditions but a previous application for trading on the site was refused on the grounds of it being in the Green Belt and also taking into account that the site is on a busy and fast main road which had had 2 fatal accidents in near proximity within the last 5 years.

The landowner applied to extend the caravan storage business and for change of use from agricultural land use to storage, both applications were rejected by WDC as not being permissible in the Green Belt.

It is our understanding that the same arguments apply equally to Oaklands Farm and to Kites Nest Travellers site, which is less than a mile away from Oaklands Farm, in that as the Planning Inspector used the Green Belt argument in the successful removal of travellers. The same arguments can be used with regard to Oaklands Farm from the list of preferred sites.

The Inspector's report from Kites Nest refusal dated 22nd October 2013 stated
"For development to be allowed in the Green Belt, very special circumstances need to be identified. What constitutes very special circumstances are not identified by local planning authorities. The term is consequently a moving target as appear to be the weights and measures used to arrive at a weighted decision. The appellants (at Kites Nest) provided a list of 15 issues that could be considered as very special circumstances as to why the development should be allowed. These did not include such common issues as health, education or children. The issues are complicated and fraught."

There are no arguments in the WDC proposals that identify any very special circumstances.

Other issues noted, in respect of Kites Nest site, by the Inspector and the Secretary of State include:
* the development was very prominent through 'gappy hedges' from public footpaths
* the existing caravans were an "extremely jarring element'.

The Oaklands Farm site
* is very visible due to the 'gappy hedge' along the road
* and from the canal
* and also the road is higher than the site so occupants would be overlooked
* and the canal is higher than the site
* several entrances on to A4177 at this site
* reduced visibility & pull away
* subject to flooding
* risk to children because of A4177, Ugly Bridge Road with blind bridge & canal
* previously mentioned footpath is on the opposite side of the road with no crossing
* noise from the busy A4177 would be "intolerable for residential use especially for caravans which are less well insulated than conventional housing" which were grounds for rejecting GT17, GT18 & GT20
* the speed limit may be lower but this site is closer to the other roads than the mentioned above
* pollution will be high because at peak periods there is often very slow and even stationery traffic constantly pumping harmful exhaust emissions to wards dwellings that are no well insulated as traditional bricks and mortar

The proposed habitat buffer to the south of the site abutting the canal would be inadequate both for incumbent residents and gypsy or traveller site residents [for privacy on both sides of the site] let alone the jarring element of the site for residents and people passing along the road or canal.

The canal is a significant tourist attraction for barges and walkers alike. Such visual intrusion would be detrimental to the tourist traffic and trade and would be counter to current policy. Also, the removal of a Caravan and Camping Club site is contrary to the policy of supporting local communities, which state that unobtrusive Caravan and Camping sites would be considered - this proposal removes one such site from stock.

In addition, in respect to encouraging tourism NE7, "developments should not
d) adversely affect the landscape, heritage, ecological quality and character of a waterways
e) adversely affect the waterways potential for being fully unblocked or discourage the use of the waterway network"
The location of a gypsy and traveller site at GT19 could have a significant impact on walkers and canal boat users and would adversely affect the character and use of the network.

In addition it is suggested that the children could attend Budbrooke School. Budbrooke School is already struggling with numbers due to rising population and children choosing to go to Budbrooke School from Chase Meadow. The additional 100 residential properties that have been allocated to each of Hampton Magna and Hatton Park will make this more challenging. Already SatNav's direct traffic to Warwick Parkway station via Ugly Bridge road so traffic will increase with the Hatton Park development and become an additional risk to people using this site. When Stank's Roundabout {A4177/A46] and roads into Warwick are congested Ugly Bridge Road is a rat run to the Warwick Parkway Station as well as to A46/M40 J15, Stratford and beyond!

The school has recently had an Ofsted inspection reporting it to be in Special Measures; it is understood that this status jeopardises the school's plans for additional classrooms. This would exacerbate the problem of schooling for the site's children. Ferncombe School in Hatton Green is full. Children would have to see places in Warwick via the A4177 with its traffic problems at school run times, at Newborough School again via Warwick or more likely via Hampton Magna & Hampton on the Hill at school run times with substantial volumes or traffic using narrow and unsuitable roads potentially hazardous to the gypsy and traveller children, local residents and Warwick/Chase Meadow residents travelling to Budbrooke School.

In the summary of preferred sites the statement "Subject to agreement with the landowner, this site could be delivered within 5 years" is misleading suggesting that the owner is willing to sell.

Taking all these arguments into account it would be totally inappropriate to locate a Gypsy and Traveller site at GT19, Oaklands Farm


Hampton on the Hill Site GTalt03
The arguments put forward regarding the Oaklands Farm site can equally be used for this site as it is within the green belt, so the Kites Nest arguments are equally very relevant. There is no exceptional circumstance argument for the site to be used, it is very obvious from the main road, Hampton on the Hill being adjacent to the main Henley Road and the lane entering Hampton on the Hill village and it is visible through 'gappy hedges' from the outside looking in but also considering traveller privacy. Site occupants would face being over looked from the road and therefore their privacy would be lost. The road, although subject to a 50mph restriction, is a very fast road and would be unsuitable for turning on and off the site by large vehicles with trailers attached.

In 2009 the following planning application was refused: W/09/0157 for Change of use of land to caravan site for occupation by gypsy family with associated operational development (utility room, septic tank, hard and soft landscaping and widen dropped kerbs) - Land at junction Hampton Road and Henley Road (A4189) Hampton on the Hill, Warwick

The refusal statement is shown below but a key element for the refusal was on site access. The following is an extract from the Highway Control Engineer's correspondence to the Planning Officer:

I do not feel that a stage 1/2 road safety audit is warranted for an access which in actuality will be used as any other single dwelling access would be used. However, having said that, I would now ask for a further condition to be imposed, in that no caravans/dwellings other than the caravans/dwellings as stated in the application shall be placed within the development.

The refusal was taken to appeal and the original refusal was upheld.

Since 2009, there has been no improvement to the highway. Traffic has increased due to commuters from Chase Meadow development using the road to reach the A46/M40 Junction 15, rather than navigating through Chase Meadow, and Warwick Parkway station.

In addition:
* The summary of preferred sites also states that the site here is flat; that is demonstrably not the case as it overlooks and slopes down towards the town of Warwick.
* There are no amenities near the site
* There are no services on site
* A suggestion that if the access point was moved towards the brow of the hill is inappropriate, the whole site would become more conspicuous.
* The Warwick Parkway/Budbrooke School rush hour and school run traffic runs alongside the site making it hazardous to children living on site
* The FAQ states that if land is considered suitable for houses it is suitable for gypsies and travellers, however the opposite will also be the case. Where a development has been refused for development is should not be used for a gypsy and traveller site.
* The additional hard standing will increase the risk of flooding in the area.
* To maintain the site access and egress for maintenance/fire service access within 45 metres of a dwelling on the site should be a consideration given the combustibility of the dwellings and LPG storage and usage would be necessary
* The pond on the adjacent site is seasonal and unsuitable for the provision of water for firefighting purposes
* The site is unsuitable for screening

The current status of the Local plan means that policies that applied at the time of the original refusal remain current; hence arguments in the proposal for GTAlt03 in respect to Very Special Circumstances cannot be justified as they contradict current policies.

It has not been satisfactorily demonstrated that the proposal for gypsy and traveller sites identified above is appropriate or necessary and safe in their locations so must be deemed unsound in the context of the local plan.

Planning Notice of REFUSAL W/09/0157

I am writing to formally lodge my objections to the inclusion of site GTalt03 in this consultation document as a possible site for Gypsies and Travellers for the following reasons:-
1. The site referenced Gtalt03 is in Green Belt and is a previously undeveloped site
The site referenced at GTalt03 is identified as Green Belt. Hampton-on-the-Hill is not identified within either the adopted WDC Local Plan (2006) or within the draft 'Village Housing Options' consultation as a sustainable location for any new residential development. Classification as Green Belt that has previously been undeveloped ought to be deemed as 'inappropriate development' for the purposes of accommodation of Gypsies and Travellers and the site classified as 'red'.
The Governments own guidance issued in March 2012 re Traveller and Gypsy sites (accompanies the National Planning Policy Framework) confirms that in plan making and decision taking (re Traveller and Gypsy sites) Local Authorities should specifically avoid inappropriate development in the Green Belt.
In the last five years the site has been the subject of two planning REFUSALS by the WDC Planning Committee in 2009 and 2011. On each occasion our Parish Council and Ward Councillors, Alan Read (2009) and Clare Saw don (2011) supported local residents in their OBJECTIONS by speaking for them at the Planning Committee meetings. The site has also been DISMISSED by the Planning Inspectorate at an appeal hearing in 2009 and following that in 2010 the WDC took out an Injunction to prevent any development. The Injunction Order (Claim No: OBM30254) on the site owner Miles Maloney and Persons unknown on 27 May 2010. It applies to the whole site of 1.66 hectares and forbids '...the siting of touring caravans/mobile homes and/or using the land for residential development including the occupation of caravans/mobile homes for residential purposes ....' It goes onto state that 'The Defendants be forbidden from undertaking any development on the land including the laying of hard-core and creation of hard standing and /or access roads, the erection of fencing, breaking new pedestrian / vehicular points onto the land and the construction of ancillary buildings'.
The same landowner made a further application on 17 December 2012 - Application number W10/1221. This time for the 'proposed conversion of a barn into a dwelling...' Once again the Case Officer referred the case the PC who spoke on behalf of the residents and stated that the application was inappropriate development in the Green Belt and Highways Safety. The Planning Committee refused the application in their meeting on 22 February 2011.
It is no wonder that the landowner is keen to promote his site as he has failed to develop the land previously. These refusals and dismissal concerned a single dwelling in 0.1 hectare. The current consultation is for 15 pitches in 1.66 hectares. The increased numbers of people and their vehicle movements on and off the Henley Road will greatly increase the highways safety issues. For the purposes of the planning process, the fact that the site is owned by persons identified as Gypsy/Traveller does not detract from the legal assumption that the classification of the site is 'inappropriate development'.
2. Impact on the Green Belt - The site referenced Gtalt03 resides in Green Belt on top on the Hill overlooking Warwick and Warwick Race Course
I would also like to reinforce this with the argument that the development would in actual fact as well as in policy terms be inappropriate as it would 'harm' the Green Belt by reducing the degree of 'openness'.
Development of this site would be very prominent and visually intrusive as the site is highly visible from all around the countryside, standing on top of the hill with views of Warwick. The site which is not level but very undulated with steep slopes in parts is highly visible from all aspects flanked on 2 of the 3 sides of the site by roads that are busy commuter and tourists routes used to access the historic town of Warwick, Warwick Castle and the Race Course. The impact of the site would be exasperated by the ground level being 1 - 2m higher than the Hampton Road; making the site eye level to people entering and leaving the village.
Bearing in mind that the WDC is required to provide pitches that meet the government guidelines for the specific cultural and accommodation needs of the gypsy traveller community, this would mean that each pitch provides accommodation for an individual family (a family being at 3 / 4 individuals - traditional gypsy/traveller families have larger than average households - there is much reported evidence of this fact) consisting of an area of hard-standing on which a park type home or permanent caravan, a touring caravan and associated vehicles, possibly livestock and machinery related to their work, together with a utility room for the sole use of that household and external lighting to ensure safe access at night as well as site lighting to ensure safe access and movement through the site for both pedestrians and vehicles.
All this would have characteristics which would be highly unsympathetic to the local rural environment and as such it would have a negative visual impact on the Green Belt and the approach to historic Warwick. The Gypsy and Traveller community with their very specific housing requirements would not harmonise with the Green Belt it would reside in, on top of a hill and it would be incongruous sited in alongside a small, rural (under 100 houses) old established Warwickshire village with some residents in Hampton-on-the-Hill being in such close proximity to the site that they would overlook the development from their homes.
3. Access and Health and Safety - Hazards to families living alongside main roads
I would also like to reinforce this with the argument that there would be health and safety hazards to families living alongside 2 main roads (the Henley Road - 50mph and the Hampton Road - 60mph), together with issues of both traffic and noise transference through the walls of trailers and caravans as well as health and safety issues to other road users.
The DCLG March 2012 'Planning policy for traveller sites' states:- 'When considering sites adjacent to main roads the government guidance is that careful regard must be given to "The health and safety of children and others who live on the site."
One side of the site is directly next to the Henley Road - A4189 - 50Mph road used by commuters and tourists visiting Warwick. There are no street lighting columns. The second side of the site is directly next to the Hampton Road being derestricted (60mph) used by both the local community and others to access Warwick Parkway, Budbrooke School and the Birmingham Road. Both these roads are flanked by green belt and equally unsuitable for caravans due to access, visibility and speed at which cars travel on both these roads. There is also has no public footpath on the side of the site that butts up to the Hampton Road.
The DCLG (2012) states there is greater noise transference through the walls of trailers and caravans than through conventional housing and the need to design measures for instance noise barriers to abate the impact on quality of life and health.
In addition to noise from the main road (Henley and Hampton Road), noise from the M40 and the Bypass can be heard from the Village and it would therefore be unsuitable for caravans which are less well insulated than conventional housing.
There is no play area and the DCLG (May 2008) Designing Gypsy and Traveller Sites Good Practise positively discourages the placement of sites to close to electricity pylons for H&S reasons. Electricity Transmission line courses the site north east and south west parallel to A4189.
The main access to this site is off the Henley Road - 50 mph. There is currently no access to the site from the Hampton Road. The access to this site on the Henley Road - A4189 - 50Mph is a busy main road. If the council decided to allow the access to be moved this would be just as treacherous for caravans to pull out onto a busy 50 mph road and when considers the increased numbers of people and their vehicle movements on and off the Henley Road it will greatly increase the highways safety issues for Gypsy and Traveller families as well as the wider community.
The Hampton Road is a narrow dangerous road. The site which stands high above the Hampton Road which is not level but very undulated with steep slopes in parts making it unsuitable for moving caravans or accessing from the Hampton Road being derestricted (60mph). The Hampton Road is used for buses which means that vehicles have to slow down to an almost stop to allow bus to pass. This road has also become a rat run with commuters using it to access Warwick Parkway Train Station Budbrooke School and the Birmingham Road in order to avoid the Bypass. The traffic calming measures have recently been removed from the Hampton Road making further hazards as vehicles speed up off the main Henley and maintain their speed up into the village. There is surface flooding along Hampton Road and along the edge of the site. In the winter the Hampton Road is subject to extensive flood water coming off the allotments and the local drains. This creates black ice making access treacherous to all vehicles. If the council decided to allow the access to be moved to the Hampton Road this would be even more treacherous than the Henley Road and greatly increase the highways safety issues for Gypsy and Traveller families as well as the wider community with caravans and vehicle movements on and off the site. Given the narrowness of Hampton Road, the ditch, the steep incline onto the site, the 60 mph speed the site does not lend itself to the integration and inclusion of the Gypsy/traveller into the Community.
Highways safety has been recorded on two separate occasions as reasons for refusing planning on the site. Once on appeal on 27 November 2009 by the Planning Inspectorate (APP/T3725/A/09/2107108) and on a separate application for planning on 17 December 2010 (W10/1221). In both circumstances the refusal was related to a single dwelling, not the current 15 pitches which could conceivably house a minimum of 30 adults (plus visitors and /or transient gypsy/travellers) owning anywhere between 15 - 30 cars, plus work vehicles and caravans, which it would reasonable to assume would create 30-60 vehicle movements through any access road on a daily basis. This very clearly poses a serious risk to both occupants of the site and the health and safety other road users.
The site does not lend itself to the integration and inclusion of the gypsy/traveller into the community and the interests of the settled community and that of the wider community must have their health and safety respected.
4. Size of Site and Co-Existence with the Local Community
It has been suggested that GTalt03 has the capacity for 15 pitches and a recommended maximum of 15 pitches and this does not take into account unauthorised use of the site by other Gypsy and Traveller families (there is much reported evidence and it is known that Gypsy and Travellers are in favour of controlled access to sites, for example using a lockable gate because it is their experience other Travellers may seek to access and stay on a site authorised).
Bearing in mind that the WDC is required to provide pitches that meet the government guidelines for the specific cultural and accommodation needs of the gypsy traveller community, this would mean that each pitch provides accommodation for an individual family (a family being at 3 / 4 individuals - traditional gypsy/traveller families have larger than average households - there is much reported evidence of this fact) consisting of an area of hard-standing on which a park type home or permanent caravan, a touring caravan and associated vehicles, possibly livestock and machinery related to their work, together with a utility room for the sole use of that household and external lighting to ensure safe access at night as well as site lighting to ensure safe access and movement through the site for both pedestrians and vehicles.
The prospect of fifteen pitches would mean that the WDC proposes that between 45 - 60 individuals (this excludes visitors and /or transient gypsy/travellers on the site) be accommodated in a village of approximately 2OO individuals, many of whom are retired including 30 single people living alone. Such a change to the local community, representing an increase in the population of 25 - 30%, would be disproportionate, cause much unrest within the village of Hampton-on-the-Hill and the site would dominate the local community which would give an imbalance to the settled community in the Village.
The site does not lend itself to the integration and inclusion of the gypsy/traveller into the community and the interests of the settled community and that of the wider community must have their human rights respected.
As the WDC has already identified sufficient 'green sites' to meet the identified need, and the Governments own guidance issued in March 2012 re Traveller and Gypsy sites confirms that in plan making and decision taking (re Traveller and Gypsy sites) Local Authorities should specifically avoid inappropriate development in the Green Belt the site referenced as GTalt03 ought to be deemed as 'inappropriate development' for the purposes of accommodation of Gypsies and Travellers and the site classified as 'red'.

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Please record this e mail as formal registration of an objection to the two proposals - referenced for consideration as Traveller accommodation - In short there can be no reasonable requirement for Green Belt land to be considered for such use.

The Government's own guidance issued in March 2012 re traveller sites (accompanies the National Planning Policy Framework) reconfirms that in plan making and decision taking (re traveller sites) Local Authorities should specifically avoid inappropriate development in Green Belts. Any consideration here will go against that guidance.

Apart from arguing & stating the green belt policy principle, it is also worthwhile reinforcing that the development would in actual fact as well as in policy terms be inappropriate - it would 'harm' the Green Belt by reducing the degree of 'openness' (The appraisal notes that GT alt03 in particular is open). Arguments for the value of the site(s) in terms of how their contribution to the green belt - contributing to 'openness' and to separating urban areas from each other are also relevant here. Furthermore development on the sites would be prominent/ visually intrusive and the recommendation of an owner is not a relevant variable in the context of Green Belt policy

GT19 is the only green belt site on the Council's list of proposed sites and it should not be looked at as anything else - to do so will open up 100's of potentially inappropriate sites as being a possible consideration and result in policy not being a basis for policy outcomes.

Having consulted professionals and researched this process I would like to make the following comments regarding traveller and Gypsy site references GT19 & GTalt03:

Sites in the Green Belt should only be considered at all in policy terms if no other viable options are available and this does not appear to be the case. The Government's own guidance issued in March 2012 re traveller sites (accompanies the National Planning Policy Framework) reconfirms that in plan making and decision taking (re traveller sites) Local Authorities should specifically avoid inappropriate development in Green Belts.

The process to date seems to readily dismiss non-Green Belt sites because they are previously or currently allocated for other uses. Whilst these circumstances may bring practical implications / conflicting expectations they should not be ruled out so quickly as the exercise should not be limited only to currently unallocated sites it should be integral to planning the area as a whole.

The developments would be inappropriate, not just in policy terms but they would also 'harm' the Green Belt by reducing the degree of 'openness' referred to in the appraisals, as any development would clearly be prominent and visually intrusive.

In the appraisal, the Council has noted GTalt03 as an open, green belt site and has not argued that there are is any exceptional case to allow development against the context of green belt policies.

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.

WDC Local Plan Gypsies & Travellers Preferred Options Consultation
I am writing to register my objections and give my views on the suitability of the following Gypsy and Traveller Preferred Options Consultation.

GT12/GTalt12 - Land at north and west of Westham Lane
* Warwick District Council (WDC) Criteria states that the site should have "convenient access to a GP surgery, school, and public transport" - The nearest GP Surgery is nearly 5 miles away by road in Bishops Tachbrook and there is not an easy access from Barford.
* WDC Criteria states that the site should "avoid areas with a high risk of flooding" - This site sits within (part) and otherwise immediately adjacent to areas identified by the Environment Agency as having significant flood risk.
* WDC Criteria states that the site should have "Safe access to the road network and provision for parking, turning and servicing on site" - Vehicular access to this site is from the A429 trunk road (The Barford Bypass) which was constructed as a bypass to Barford. It is a 60 mph speed limit road and there have been a significant number of traffic accidents including a fatality. There is also inadequate pedestrian crossing facilities for safe access into the village. Access would be difficult and expensive whilst being very dangerous for both vehicle users and pedestrians
* WDC Criteria states that the site should "avoid areas where there is the potential for noise and other disturbance" - Noise levels from the By Pass and M40 roundabout can be heard through double glazing in the surrounding houses. The continuous noise from the Barford Bypass could not be reduced effectively or economically by constructing barriers.
* WDC Criteria states that the site should have "Provision of utilities (running water, toilet facilities, waste disposal, etc)" - There are no such services available in the area and the cost for supplying these for a small number of pitches would be considerable and therefore render the site uneconomical.
* WDC Criteria states that the site should be "Avoiding areas where there could be adverse impact on important features of the natural and historic environment" - The
proposed site is on the busy route between the historic town of Warwick and the Cotswolds, and the impact on the landscape and tourism of a Gypsy and Traveller site would be immense.



WDC Local Plan Gypsies & Travellers Preferred Options Consultation - Cont/d
* WDC Criteria states that the "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" - The proposed site is green field and a satellite from Barford village, the development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity and character of the site.
* WDC Criteria states "Promotes peaceful and integrated co-existence between the site and the local community" - The A429 Barford Bypass isolates the site from the village and therefore presents a physical barrier to integration with the village.
* WDC Criteria states "Avoids placing undue pressure on local infrastructure and services" - This site does not fully meet with the provisions of Planning Policy for Gipsy & Traveller sites as it does not promote peaceful integrated co-existence between the proposed sites and the local community. It will also place undue pressure on the local infrastructure and services. It would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
The Gypsy and Traveller community should be catered for and integrated into new, larger mixed development sites being proposed through the New Local Plan. Larger pitches would be more economical as opposed to smaller pitches which would drive down the pitch costs, gets economies of scale and has less impact on fewer communities and residents.

The following sites would seem eminently more suitable to a greater or lesser degree than the two proposed sites adjacent to Barford Bypass:

Sites GT02- Land Abutting Fosse Way at Junction with A425 (part) already has an immediate access to popular route for Gypsies and Travellers.

SiteGTalt03 Henley Road /Hampton Road - where the landowner is very keen to promote the site for the required purpose. The site is available and deliverable.

Warwick District Council should be requiring Gypsy and Traveller sites are delivered within the proposed major new housing developments. This would ensure that the sites could be properly designed in a sustainable fashion and be fully integrated into a local community which will provide facilities such as a school, doctor's surgery and shops which are accessible on foot, on bike, by bus and by car.

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.

I am writing to express in the strongest possible terms by objection to the proposed Gypsy site at GT04 on the site currently offered by Leamington Football Club. Even if you believe that the council are required to provide such facilities, that they are necessary and that the people involved in fact want them (all of which are more than debatable), there are some very grave inaccuracies and irregularities about the process and the proposals.

It is absolutely clear that the whole process has been engineered by Warwick DC to push the sites chosen to the very boundaries of the District. This will have two very clear benefits to Warwick DC, firstly it will eliminate any impact on their residents (and therefore voters) of these sites, and secondly it will push the costs for the provision of services such as schools, Doctors, Policing and other welfare onto neighbouring districts. Both of these objectives are utterly deplorable.

On order to achieve these aims, Warwick DC have clearly judged each site not on defined, creditable, consistent, stated and scored criteria, instead they have mixed and matched criteria and weighing to achieve the outcome that suits their own political agenda. Issues that are deemed as worthy of comment for one site are omitted for another, and initial proposals - right down to the actual land in question - have been adjusted to include or exclude sites as required.

Contradictions and inconsistencies
The latest consultation document is full of contradictions, for example, one site is ruled out due to high pressure gas mains, the next a site is altered to accommodate the fact that there is a high pressure gas main. Similarly, one minute the residents of the travellers site needs access to major road network, the next minute they do not or it is too noisy. The arguments made are clearly 'convenient' to suit the agenda of Warwick district council, which is clearly to push this provision to the farthest boundary and onto Stratford-upon-Avon DC and their residents.

The idea that Gypsies will be content to avoid the closest services for Doctors and Schools in Harbury and head to Bishops Itchington due to an arbitrary district boundary as are fanciful as they are preposterous.

Changing the definition of GT04
Furthermore there have been several differences between the initial proposals and the revised proposal, not least that the initial proposal at GT04 stated that the site would be opposite Barwell Farm and it is now limited to the football club. This devious provision of information meant that objections to the first proposal focussed on a different area to that which is now being proposed, which meant that some key factors may have been overlooked and some key arguments voided.

Specific contradictions when comparing sites (and paragraph 6.1)
There are enormous irregularities in the pro's and con's provided in the consultation, where considerations that are applicable to one site are equally applicable to another but ignored. The application list shown in 6.2 of the document highlights this perfectly. In fact, 6.2 is actually a list of further considerations that may or may not be referred to as appropriate to suit the councils agenda.

For example:
GT04 lies within a flood plane, so the 'new' proposed area, which is different to that considered in the first consultation, has been cherry picked to cover only the part that does not lie in this area. This approach has not been afforded to any other proposed site with flood considerations.

GT04 has issues around danger to wildlife, again the 'new' proposed area, which is different to that considered in the first consultation, has been cherry picked to cover only the part that does not lie in this area. This approach has not been afforded to any other proposed site with wildlife considerations.

Various sites mention a high pressure gas main. Only site GT04 has been sub divided to get around this 'problem'.

GT06 'may cause problems for viable agricultural unit'. Of course the land at GT04 could otherwise form prime agricultural land (if indeed that is a consideration) should the football club vacate and the provision of these facilities will of course have an impact on neighbouring agricultural land.

GT08 is flagged as being within 1km of a railway line. GT04 is also within 1km of a railway line.

GT08 is noted as being (potentially too) remote from transport links and the like. It is no more remote than GT04.

Various sites mention potential road noise from the A46 and M40, yet the Fosse Way (which is adjacent to the GT04 site) is one of the busiest roads in the area.

GT13 mentions failed planning applications previously. Without any detail it is impossible to say that those same reasons for failing to approve this site be any less relevant to GT04.

GT13 is noted as being too remote from services and facilities, remote from primary road network and on high quality landscape. All three of these reasons are more applicable to GT04 than GT13.

GT14 mentions contamination from use as a poultry Farm. This is nonsensical, what possible contamination could there be arising from a poultry farm?

Gtalt02. By far and away the biggest irregularities focusses on Gtalt02, which is marked as 'amber'. When compared to GT04:
* it is apparently remote from services, although no more remote than GT04,
* it would require the purchase of a timber business, whereas mention of the cost and disruption of re-homing a football club is conspicuous by it's absence
* the road may be dangerous even though mention of the Fosse Way, the most dangerous road in Warwickshire if not the Midlands - again not mentioned in GT04.
* Mention of the ancient woodland, although the view from Chesterton Windmill is completely omitted in reference to GT04. (but then I suppose that falls in Statford-upon-Avon DC so that probably doesn't count).

Gtalt03 appears to have not been delivered as 'green' on the basis of being on Greenbelt. If this is an overriding issue or is simply too difficult, then these sites should never have been considered in the first place - what is the point of including and then omitting anything on a green belt is not to force non-green belt sites through. This is consistent throughout the document.

Gtalt04 is stated as being remote from ALL services and facilities, despite being next to a railway station and in a village every bit as well served as anything within 2 miles of GT04.

The reasons given for Gtalt06 are so vague it is not worth commenting on, and all of the positive reasons for inclusion at other sites (such as proximity to services, near to transport links, not being on the greenbelt etc etc) have been completely omitted. Very clearly this is bowing to pressure from a landowner and as such this site should be reconsidered and judged in parallel to the other sites whereby pro's are considered in addition to just the 'cons'.

Gtalt07 mentions being 'open to views from the West'. This is a very odd reason and I cannot see why views from Chesterton Windmill have been entirely omitted in the case of GT04.

Gtalt09 (and others) I am intrigued about the mention of land being 'allocated for residential use'. How a gypsy site would not be considered 'residential use' is very odd, except of course if these is a windfall to the council in selling the land to a developer.

Gtalt10 mentions that the area excluded for risk of flooding but that this is going to be remedied, it is completely unclear as to why this is a problem.

Gtalt13 (excusing typo) - states that the road is not suitable to serve caravans, but these are to be fixed units . This is an enormous and concerning irregularity. Furthermore, it is incongruous that the council are seemingly not willing to improve a road but they are willing to move a whole football club with the costs that this activity would incur.

Gtalt15 - again these are no comments about how 'good' the provision of services would be at this site. Furthermore, there is no 'Olympus Way' in Leamington spa, but access from ' Olympus Avenue' would be ideal for residents.

Gtalt16 is far too vague to comment.

Gtalt22 is mentioned as being 'very open and conspicuous', as well as unpalatable to the neighbours. This is a complete re-write of the rules that all other sites have been judged by.

Consideration of Neighbours

I was alarmed, concerned and ultimately unsurprised when told by a representative of Warwick DC that they have travelled the length and breath of the country to similar sites to speak to traveller families, council officials yet not (even once) those local residents that are affected by the sites. This is entirely preposterous, a scandalous mis-use of public money and shows the utter discontempt for residents (especially those of neighbouring Districts) that will be impacted by these plans.

Ideal sites

The following sites should be utilised. In each case they are either already marked 'Green' or the reasons for being amber or red are extremely weak in comparison with other sites.

GT06 - none of the reasons given against using GT06 are strong enough to preclude the site as being Green. Utilising 6 pitches at this site would spread the burden of provision around the district.

GT11 - as above, none of the reasons given are strong enough to preclude the site as being marked Green. This site would give access to the plentiful services in Warwick and has access to facilities and transport links. The only real reason this has been excluded is the council do not want Gypsy's 'in their backyard', as well as probably objections to a current or potential developer.

GT19 - again, an ideal site and possibly small enough for the local community to absorb, although this should be carefully monitored.

Gtalt01 - already earmarked as a camping site but unlikely to be viable as a business. If indeed there is a requirement, desire and need for such facilities, this a very clear and obvious place that gives residents access to the plentiful services on offer in Warwick Town.

On this point, it is as astonishing as it is unsurprising that the district council has not been 'able' to find any 'green rated' sites that would mean that the provision of services is drawn from the council home of Leamington Spa.

Gtalt02 - again, none of the reasons given are strong enough to preclude the site as being marked Green. This site would give access to the plentiful services in Leamington Spa and has access to facilities and transport links. The only real reason this has been excluded is the council do not want Gypsy's 'in their backyard'.

Gtalt03 - again, reasons not strong enough to preclude the site as being marked Green. This site would give access to the plentiful services in Warwick and has access to facilities and transport links. Likely to be affected by the views of a potential developer.

Gtalt12 - Marked Green, although there does seem likely to be a significant amount of pressure put on services in Barford which I believe may fall in Stratford-upon-Avon DC area.

Gtalt15 - Again, it is not clear as to why this site is not marked as green as different criteria seem to have been given to this and other sites. To claim that some remote sites are close enough to facilities and services but then to not comment in relation to this site is entirely perplexing.

The proposed sites at GT17, GT18 and GT20 are all absolutely ideal for a development of this type. There is not a single criteria that are not met by these sites and it seems that the wishes of one group (in this instance the highways) are accepted and not questioned unlike the view of residents elsewhere.
Best mix

The best mix is to place up to 38 pitches all at GT17, GT18 and GT20. As an alternative, the following mix would best meet the needs of the travelling community, not impact disproportionally on the lives of small communities in and near to Warwick District. All of these sites would have significant space to expand.

GT06 Land at Park Farm, Spinney Farm - 6 'pitches' (currently AMBER)
GT11 Land at Budbrooke Lodge, Racecourse and Hampton Road - 5 'pitches' (currently AMBER)
GT19 Land adjacent Shell Petrol Filling Station, Birmingham Road, Budbrooke, Warwick - 5 'pitches' (currently GREEN)
GTalt01 Brookside Willows, Banbury Road - 15 'pitches' (currently GREEN)
GTalt02 Land off Rugby Road, Cubbington - 5 'pitches' (currently AMBER)
GTalt03 Henley Road/Hampton Road, Hampton-on-the-Hill - 5 'pitches' (currently AMBER)
GTalt15 r.o. department store, Leamington Retail Park - 5 'pitches' (currently RED)

That is if these facilities are needed at all - which frankly nobody believes.

Yours sincerely

James Skidmore

I am writing to register our objections and give our views on the suitability of the following Gypsy and Traveller Preferred Options Consultation.

GT12/GTalt12 - Land at north and west of Westham Lane
* Warwick District Council (WDC) Criteria states that the site should have "convenient access to a GP surgery, school, and public transport" - The nearest GP Surgery is nearly 5 miles away by road in Bishops Tachbrook and there is not an easy access from Barford.
* WDC Criteria states that the site should "avoid areas with a high risk of flooding" - This site sits within (part) and otherwise immediately adjacent to areas identified by the Environment Agency as having significant flood risk.
* WDC Criteria states that the site should have "Safe access to the road network and provision for parking, turning and servicing on site" - Vehicular access to this site is from the A429 trunk road (The Barford Bypass) which was constructed as a bypass to Barford. It is a 60 mph speed limit road and there have been a significant number of traffic accidents including a fatality. There is also inadequate pedestrian crossing facilities for safe access into the village. Access would be difficult and expensive whilst being very dangerous for both vehicle users and pedestrians
* WDC Criteria states that the site should "avoid areas where there is the potential for noise and other disturbance" - Noise levels from the By Pass and M40 roundabout can be heard through double glazing in the surrounding houses. The continuous noise from the Barford Bypass could not be reduced effectively or economically by constructing barriers.
* WDC Criteria states that the site should have "Provision of utilities (running water, toilet facilities, waste disposal, etc)" - There are no such services available in the area and the cost for supplying these for a small number of pitches would be considerable and therefore render the site uneconomical.
* WDC Criteria states that the site should be "Avoiding areas where there could be adverse impact on important features of the natural and historic environment" - The
proposed site is on the busy route between the historic town of Warwick and the Cotwolds, and the impact on the landscape and tourism of a Gypsy and Traveller site would be immense.

* WDC Criteria states that the "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" - The proposed site is green field and a satellite from Barford village, the development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity and character of the site.
* WDC Criteria states "Promotes peaceful and integrated co-existence between the site and the local community" - The A429 Barford Bypass isolates the site from the village and therefore presents a physical barrier to integration with the village.
* WDC Criteria states "Avoids placing undue pressure on local infrastructure and services" - This site does not fully meet with the provisions of Planning Policy for Gipsy & Traveller sites as it does not promote peaceful integrated co-existence between the proposed sites and the local community. It will also place undue pressure on the local infrastructure and services. It would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
The Gypsy and Traveller community should be catered for and integrated into new, larger mixed development sites being proposed through the New Local Plan. Larger pitches would be more economical as opposed to smaller pitches which would drive down the pitch costs, gets economies of scale and has less impact on fewer communities and residents.

The following sites would seem eminently more suitable to a greater or lesser degree than the two proposed sites adjacent to Barford Bypass:

* Sites GT02- Land Abutting Fosse Way at Junction with A425 (part) already has an immediate access to popular route for Gypsies and Travellers.

* SiteGTalt03 Henley Road /Hampton Road - where the landowner is very keen to promote the site for the required purpose. The site is available and deliverable.

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

see attached

see attached

The Governments Planning Policy states that G& T sites are inappropriate development in the GREEN BELT unless very special circumstances can be proven.
This is reinforced by Brandon Lewis Local Government Minister in July 2013 in a written statement which says: "Having considered recent planning decisions by Councils and Planning Inspectorate, it has become apparent that, in some cases the Green Belt is not always being given the sufficient protection that was the explicit policy intent of ministers.

The Secretary of State also makes clear in January 2014 that he considers unmet demand whether for traveller sites or conventional housing is unlikely to outweigh harm to the green belt.

The Governments policy is clear that there must be wholly exceptional circumstances to justify identifying traveller sites within the Green Belt.
Applying this to site GTalt03 the question is what very special circumstances could possibly justify this prominent site for 15 pitches.

The site was refused planning W09/0157 at APPEAL for a single caravan for a gypsy family in November 2009. The District Council took out an injunction to prevent any unlawful occupancy of the land.

It is therefore untenable that the same Council is currently promoting the site for a 15 pitch development on a 1.6 hectare open aspect GREEN BELT field.

In addition Hampton on the Hill is not identified as a sustainable location for any new residential development, therefore if the village is not a location for new housing then it should NOT be considered a sustainable location for a traveller site.

Access onto and off the Henley Road (not Hampton Road) would prove extremely dangerous particularly with trailer vehicles.
The Inspector ruled that access was a reason for refusal of application W09/157.

The visual impact of a traveller site on this elevated position on a main road into the county town of Warwick would be detrimental to the area and impossible to disguise.

A public footpath crosses the westerly boundary of the site leading to Hampton on the Hill allotments A 15 pitch traveller site so close would be very intrusive and detrimental to the amenity of allotment holders.

The site is crossed by a 33000 Volt electricity line which requires access for maintenance and would pose a serious Health and Safety issue. A very significant constraint to any development of the site.

Other constraints on the development of this site relate to noise/pollution from traffic on two boundaries and the possibility of flooding on the ground adjacent to Hampton Road.

No consideration has been mentioned with regard to a satisfactory sewage system or whether a connection could be made to the main sewer.

In addition I understand that a covenant exists relating to a requirement that the land should always remain for agricultural/equestrian use.

I cannot see any reasons why this site is being considered, NO very special circumstances have been proved therefore the site should be removed from further consultations and be re-classified as a RED site.

The Governments Planning Policy states that G& T sites are inappropriate development in the GREEN BELT unless very special circumstances can be proven.
This is reinforced by Brandon Lewis Local Government Minister in July 2013 in a written statement which says: "Having considered recent planning decisions by Councils and Planning Inspectorate, it has become apparent that, in some cases the Green Belt is not always being given the sufficient protection that was the explicit policy intent of ministers.

The Secretary of State also makes clear in January 2014 that he considers unmet demand whether for traveller sites or conventional housing is unlikely to outweigh harm to the green belt.

The Governments policy is clear that there must be wholly exceptional circumstances to justify identifying traveller sites within the Green Belt.
Applying this to site GTalt03 the question is what very special circumstances could possibly justify this prominent site for 15 pitches.

The site was refused planning W09/0157 at APPEAL for a single caravan for a gypsy family in November 2009. The District Council took out an injunction to prevent any unlawful occupancy of the land.

It is therefore untenable that the same Council is currently promoting the site for a 15 pitch development on a 1.6 hectare open aspect GREEN BELT field.

In addition Hampton on the Hill is not identified as a sustainable location for any new residential development, therefore if the village is not a location for new housing then it should NOT be considered a sustainable location for a traveller site.

Access onto and off the Henley Road (not Hampton Road) would prove extremely dangerous particularly with trailer vehicles.
The Inspector ruled that access was a reason for refusal of application W09/157.

The visual impact of a traveller site on this elevated position on a main road into the county town of Warwick would be detrimental to the area and impossible to disguise.

A public footpath crosses the westerly boundary of the site leading to Hampton on the Hill allotments A 15 pitch traveller site so close would be very intrusive and detrimental to the amenity of allotment holders.

The site is crossed by a 33000 Volt electricity line which requires access for maintenance and would pose a serious Health and Safety issue. A very significant constraint to any development of the site.

Other constraints on the development of this site relate to noise/pollution from traffic on two boundaries and the possibility of flooding on the ground adjacent to Hampton Road.

No consideration has been mentioned with regard to a satisfactory sewage system or whether a connection could be made to the main sewer.

In addition I understand that a covenant exists relating to a requirement that the land should always remain for agricultural/equestrian use.

I cannot see any reasons why this site is being considered, NO very special circumstances have been proved therefore the site should be removed from further consultations and be re-classified as a RED site.

The Governments Planning Policy states that G& T sites are inappropriate development in the GREEN BELT unless very special circumstances can be proven.
This is reinforced by Brandon Lewis Local Government Minister in July 2013 in a written statement which says: "Having considered recent planning decisions by Councils and Planning Inspectorate, it has become apparent that, in some cases the Green Belt is not always being given the sufficient protection that was the explicit policy intent of ministers.

The Secretary of State also makes clear in January 2014 that he considers unmet demand whether for traveller sites or conventional housing is unlikely to outweigh harm to the green belt.

The Governments policy is clear that there must be wholly exceptional circumstances to justify identifying traveller sites within the Green Belt.
Applying this to site GTalt03 the question is what very special circumstances could possibly justify this prominent site for 15 pitches.

The site was refused planning W09/0157 at APPEAL for a single caravan for a gypsy family in November 2009. The District Council took out an injunction to prevent any unlawful occupancy of the land.

It is therefore untenable that the same Council is currently promoting the site for a 15 pitch development on a 1.6 hectare open aspect GREEN BELT field.

In addition Hampton on the Hill is not identified as a sustainable location for any new residential development, therefore if the village is not a location for new housing then it should NOT be considered a sustainable location for a traveller site.

Access onto and off the Henley Road (not Hampton Road) would prove extremely dangerous particularly with trailer vehicles.
The Inspector ruled that access was a reason for refusal of application W09/157.

The visual impact of a traveller site on this elevated position on a main road into the county town of Warwick would be detrimental to the area and impossible to disguise.

A public footpath crosses the westerly boundary of the site leading to Hampton on the Hill allotments A 15 pitch traveller site so close would be very intrusive and detrimental to the amenity of allotment holders.

The site is crossed by a 33000 Volt electricity line which requires access for maintenance and would pose a serious Health and Safety issue. A very significant constraint to any development of the site.

Other constraints on the development of this site relate to noise/pollution from traffic on two boundaries and the possibility of flooding on the ground adjacent to Hampton Road.

No consideration has been mentioned with regard to a satisfactory sewage system or whether a connection could be made to the main sewer.

In addition I understand that a covenant exists relating to a requirement that the land should always remain for agricultural/equestrian use.

I cannot see any reasons why this site is being considered, NO very special circumstances have been proved therefore the site should be removed from further consultations and be re-classified as a RED site.

The Governments Planning Policy states that G& T sites are inappropriate development in the GREEN BELT unless very special circumstances can be proven.
This is reinforced by Brandon Lewis Local Government Minister in July 2013 in a written statement which says: "Having considered recent planning decisions by Councils and Planning Inspectorate, it has become apparent that, in some cases the Green Belt is not always being given the sufficient protection that was the explicit policy intent of ministers.

The Secretary of State also makes clear in January 2014 that he considers unmet demand whether for traveller sites or conventional housing is unlikely to outweigh harm to the green belt.

The Governments policy is clear that there must be wholly exceptional circumstances to justify identifying traveller sites within the Green Belt.
Applying this to site GTalt03 the question is what very special circumstances could possibly justify this prominent site for 15 pitches.

The site was refused planning W09/0157 at APPEAL for a single caravan for a gypsy family in November 2009. The District Council took out an injunction to prevent any unlawful occupancy of the land.

It is therefore untenable that the same Council is currently promoting the site for a 15 pitch development on a 1.6 hectare open aspect GREEN BELT field.

In addition Hampton on the Hill is not identified as a sustainable location for any new residential development, therefore if the village is not a location for new housing then it should NOT be considered a sustainable location for a traveller site.

Access onto and off the Henley Road (not Hampton Road) would prove extremely dangerous particularly with trailer vehicles.
The Inspector ruled that access was a reason for refusal of application W09/157.

The visual impact of a traveller site on this elevated position on a main road into the county town of Warwick would be detrimental to the area and impossible to disguise.

A public footpath crosses the westerly boundary of the site leading to Hampton on the Hill allotments A 15 pitch traveller site so close would be very intrusive and detrimental to the amenity of allotment holders.

The site is crossed by a 33000 Volt electricity line which requires access for maintenance and would pose a serious Health and Safety issue. A very significant constraint to any development of the site.

Other constraints on the development of this site relate to noise/pollution from traffic on two boundaries and the possibility of flooding on the ground adjacent to Hampton Road.

No consideration has been mentioned with regard to a satisfactory sewage system or whether a connection could be made to the main sewer.

In addition I understand that a covenant exists relating to a requirement that the land should always remain for agricultural/equestrian use.

I cannot see any reasons why this site is being considered, NO very special circumstances have been proved therefore the site should be removed from further consultations and be re-classified as a RED site.

The Governments Planning Policy states that G& T sites are inappropriate development in the GREEN BELT unless very special circumstances can be proven.
This is reinforced by Brandon Lewis Local Government Minister in July 2013 in a written statement which says: "Having considered recent planning decisions by Councils and Planning Inspectorate, it has become apparent that, in some cases the Green Belt is not always being given the sufficient protection that was the explicit policy intent of ministers.

The Secretary of State also makes clear in January 2014 that he considers unmet demand whether for traveller sites or conventional housing is unlikely to outweigh harm to the green belt.

The Governments policy is clear that there must be wholly exceptional circumstances to justify identifying traveller sites within the Green Belt.
Applying this to site GTalt03 the question is what very special circumstances could possibly justify this prominent site for 15 pitches.

The site was refused planning W09/0157 at APPEAL for a single caravan for a gypsy family in November 2009. The District Council took out an injunction to prevent any unlawful occupancy of the land.

It is therefore untenable that the same Council is currently promoting the site for a 15 pitch development on a 1.6 hectare open aspect GREEN BELT field.

In addition Hampton on the Hill is not identified as a sustainable location for any new residential development, therefore if the village is not a location for new housing then it should NOT be considered a sustainable location for a traveller site.

Access onto and off the Henley Road (not Hampton Road) would prove extremely dangerous particularly with trailer vehicles.
The Inspector ruled that access was a reason for refusal of application W09/157.

The visual impact of a traveller site on this elevated position on a main road into the county town of Warwick would be detrimental to the area and impossible to disguise.

A public footpath crosses the westerly boundary of the site leading to Hampton on the Hill allotments A 15 pitch traveller site so close would be very intrusive and detrimental to the amenity of allotment holders.

The site is crossed by a 33000 Volt electricity line which requires access for maintenance and would pose a serious Health and Safety issue. A very significant constraint to any development of the site.

Other constraints on the development of this site relate to noise/pollution from traffic on two boundaries and the possibility of flooding on the ground adjacent to Hampton Road.

No consideration has been mentioned with regard to a satisfactory sewage system or whether a connection could be made to the main sewer.

In addition I understand that a covenant exists relating to a requirement that the land should always remain for agricultural/equestrian use.

I cannot see any reasons why this site is being considered, NO very special circumstances have been proved therefore the site should be removed from further consultations and be re-classified as a RED site.

The Governments Planning Policy states that G& T sites are inappropriate development in the GREEN BELT unless very special circumstances can be proven.
This is reinforced by Brandon Lewis Local Government Minister in July 2013 in a written statement which says: "Having considered recent planning decisions by Councils and Planning Inspectorate, it has become apparent that, in some cases the Green Belt is not always being given the sufficient protection that was the explicit policy intent of ministers.

The Secretary of State also makes clear in January 2014 that he considers unmet demand whether for traveller sites or conventional housing is unlikely to outweigh harm to the green belt.

The Governments policy is clear that there must be wholly exceptional circumstances to justify identifying traveller sites within the Green Belt.
Applying this to site GTalt03 the question is what very special circumstances could possibly justify this prominent site for 15 pitches.

The site was refused planning W09/0157 at APPEAL for a single caravan for a gypsy family in November 2009. The District Council took out an injunction to prevent any unlawful occupancy of the land.

It is therefore untenable that the same Council is currently promoting the site for a 15 pitch development on a 1.6 hectare open aspect GREEN BELT field.

In addition Hampton on the Hill is not identified as a sustainable location for any new residential development, therefore if the village is not a location for new housing then it should NOT be considered a sustainable location for a traveller site.

Access onto and off the Henley Road (not Hampton Road) would prove extremely dangerous particularly with trailer vehicles.
The Inspector ruled that access was a reason for refusal of application W09/157.

The visual impact of a traveller site on this elevated position on a main road into the county town of Warwick would be detrimental to the area and impossible to disguise.

A public footpath crosses the westerly boundary of the site leading to Hampton on the Hill allotments A 15 pitch traveller site so close would be very intrusive and detrimental to the amenity of allotment holders.

The site is crossed by a 33000 Volt electricity line which requires access for maintenance and would pose a serious Health and Safety issue. A very significant constraint to any development of the site.

Other constraints on the development of this site relate to noise/pollution from traffic on two boundaries and the possibility of flooding on the ground adjacent to Hampton Road.

No consideration has been mentioned with regard to a satisfactory sewage system or whether a connection could be made to the main sewer.

In addition I understand that a covenant exists relating to a requirement that the land should always remain for agricultural/equestrian use.

I cannot see any reasons why this site is being considered, NO very special circumstances have been proved therefore the site should be removed from further consultations and be re-classified as a RED site.

The Governments Planning Policy states that G& T sites are inappropriate development in the GREEN BELT unless very special circumstances can be proven.
This is reinforced by Brandon Lewis Local Government Minister in July 2013 in a written statement which says: "Having considered recent planning decisions by Councils and Planning Inspectorate, it has become apparent that, in some cases the Green Belt is not always being given the sufficient protection that was the explicit policy intent of ministers.

The Secretary of State also makes clear in January 2014 that he considers unmet demand whether for traveller sites or conventional housing is unlikely to outweigh harm to the green belt.

The Governments policy is clear that there must be wholly exceptional circumstances to justify identifying traveller sites within the Green Belt.
Applying this to site GTalt03 the question is what very special circumstances could possibly justify this prominent site for 15 pitches.

The site was refused planning W09/0157 at APPEAL for a single caravan for a gypsy family in November 2009. The District Council took out an injunction to prevent any unlawful occupancy of the land.

It is therefore untenable that the same Council is currently promoting the site for a 15 pitch development on a 1.6 hectare open aspect GREEN BELT field.

In addition Hampton on the Hill is not identified as a sustainable location for any new residential development, therefore if the village is not a location for new housing then it should NOT be considered a sustainable location for a traveller site.

Access onto and off the Henley Road (not Hampton Road) would prove extremely dangerous particularly with trailer vehicles.
The Inspector ruled that access was a reason for refusal of application W09/157.

The visual impact of a traveller site on this elevated position on a main road into the county town of Warwick would be detrimental to the area and impossible to disguise.

A public footpath crosses the westerly boundary of the site leading to Hampton on the Hill allotments A 15 pitch traveller site so close would be very intrusive and detrimental to the amenity of allotment holders.

The site is crossed by a 33000 Volt electricity line which requires access for maintenance and would pose a serious Health and Safety issue. A very significant constraint to any development of the site.

Other constraints on the development of this site relate to noise/pollution from traffic on two boundaries and the possibility of flooding on the ground adjacent to Hampton Road.

No consideration has been mentioned with regard to a satisfactory sewage system or whether a connection could be made to the main sewer.

In addition I understand that a covenant exists relating to a requirement that the land should always remain for agricultural/equestrian use.

I cannot see any reasons why this site is being considered, NO very special circumstances have been proved therefore the site should be removed from further consultations and be re-classified as a RED site.