Preferred Options for Sites

Barford Residents Association wishes to submit an objection to site GT 12 as a preferred option based on the criteria stated on P 13 of the Preferred Options Document March 2014
1. The first criterion is for convenient access to a GP surgery. There has not been a GP surgery in Barford for over 30 years. The nearest surgery quoted is in Bishops Tachbrook which is a difficult 4.4 miles away by road. Although there is a school and buses do pass through the village hourly during the day - the need to cross the Barford Bypass means that these services are not easily accessible by pedestrians.
2. The western part of the area falls within the flood plain. Development in this area would not be consistent with avoiding areas with a high risk of flooding.
3. Safe access to the road network would not be possible. Large slow moving vehicles trying to enter or leave this site would cause an unacceptable and unnecessary hazard on a fast moving (60 mph) road that already has a poor accident record. (12 notifiable accidents, 3 severe and 1 fatality since opening in 2006)
4. 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. When the Barford Bypass was built compensation was paid to several households on the West side of Barford in respect of the noise disturbance caused. Site GT 12 is much closer to the Bypass than these houses and caravans are thin walled and provide little attenuation for occupants. This is proposed as a site for only 8 pitches - but if noise reduction measures are to be taken then the area needed for this would significantly reduce the space available for sites and make the site un-viable.
5. There are no utilities within the proposed area so these would have to be provided. The cost of providing these would make it an uneconomic proposition.
6. The Council has produced no evidence in relation to the ecological and biodiversity importance of the land within the areas proposed. Development in this area would cause unacceptable harm to biodiversity interest contrary to the provisions of the NPPF. The area contains a number of protected species including water voles and badgers. This 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.
7. As site GT12 is in flat open countryside any new development could not be considered to positively enhance the environment and increase its openness. If a site of eight pitches is planned within GT12 then a significant development of some 1.8 hectares including at least eight or so permanent amenity buildings could not be integrated into the landscape without harming the unspoilt character of the area.
8. This site is physically separated from the settlement of Barford by the Bypass. It will not be possible to achieve peaceful integrated co-existence between the site and the village as the Bypass will cause a natural barrier.
9. Undue pressure will be placed on the local infrastructure which is stretched at the moment and will be further strained by the addition of 70 - 90 houses allocated in the New Local Plan. In particular the school is full at present - and although only 8 pitches are planned we are advised that Traveller families tend to be larger than average and this could result in more than 20 extra places being required.
There are some additional factors that are relevant to the decision but do not fit into the response categories defined.
The proposed site is Grade 2 agricultural land. It forms part of a small holding and selecting this area as a Gypsy & Traveller site will render the holding un-viable. The loss of this resource is not necessary and selecting an alternative site would enable this to be conserved.
The owner of the site is not willing to sell and Compulsory purchase proceedings would therefore need to be initiated. This will necessarily take a long time and is not guaranteed to be successful. No previous CPOs have been granted for Gypsy & Traveller sites in England. We are aware of one CPO by Mid Suffolk DC that has failed. There are alternative sites where the owner is willing to sell or the land is currently owned by WCC. These sites should be considered in preference to sites that may not be deliverable.
ALTERNATIVE STRATEGIES
BRA supports the proposal that 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.
The new Local Plan proposes a residential site at Thickthorn near Kenilworth. Currently the site is in the Green Belt and this indicates that WDC is willing and able to adjust the Green Belt boundaries to accommodate new development. The Publication 'Planning Policy for Travellers Site DCLG March 2012' states that 'a Local Planning Authority can make an exceptional limited alteration to the defined Green Belt boundary which might be to accommodate a site inset within the Green Belt to meet a specific identified need for a traveller site. It should do so only through the plan making process and not in response to a planning application. If land is removed from the Green Belt in this way it should be specifically allocated in the Development Plan as a traveller site only.' The WDC decision to exempt the green belt from the areas allocated for Gypsy and Traveller sites has resulted in an unacceptable concentration of these sites in the South of the District. This is evident in the brochure where the plan of the Green and amber sites is at twice the scale of the red sites and all the green sites are in the Southern half of the map. The council are currently preparing the New Local Plan and thus have an opportunity for a full review of the Green Belt throughout the whole district. Section 9 of the NPPF about protecting Green Belt land also makes it clear that the Local Plan is an opportunity to review the boundaries of the Green Belt.
SUMMARY
Barford Residents Association strongly objects to the inclusion of Site GT12 as a preferred site for a Gypsy and Traveller site to be located.
It fails all the criteria set out by Warwick District Council for a suitable site.
Necessary measures to reduce noise at the site from the adjacent Barford Bypass would reduce the available area to such an extent that less than 5 pitches that could be established making the site unviable.
The need to use a Compulsory Purchase Order to obtain the site and the likelihood that this will fail makes the site undeliverable.
FOOTNOTE
Although this objection is to the selection of GT 12 as a preferred site it should be noted that these comments are equally applicable to site GT alt 12, (not on the preferred list) which is nearby and also separated from Barford by the Bypass.

Barford Residents Association wishes to submit an objection to site GT 12 as a preferred option based on the criteria stated on P 13 of the Preferred Options Document March 2014
1. The first criterion is for convenient access to a GP surgery. There has not been a GP surgery in Barford for over 30 years. The nearest surgery quoted is in Bishops Tachbrook which is a difficult 4.4 miles away by road. Although there is a school and buses do pass through the village hourly during the day - the need to cross the Barford Bypass means that these services are not easily accessible by pedestrians.
2. The western part of the area falls within the flood plain. Development in this area would not be consistent with avoiding areas with a high risk of flooding.
3. Safe access to the road network would not be possible. Large slow moving vehicles trying to enter or leave this site would cause an unacceptable and unnecessary hazard on a fast moving (60 mph) road that already has a poor accident record. (12 notifiable accidents, 3 severe and 1 fatality since opening in 2006)
4. 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. When the Barford Bypass was built compensation was paid to several households on the West side of Barford in respect of the noise disturbance caused. Site GT 12 is much closer to the Bypass than these houses and caravans are thin walled and provide little attenuation for occupants. This is proposed as a site for only 8 pitches - but if noise reduction measures are to be taken then the area needed for this would significantly reduce the space available for sites and make the site un-viable.
5. There are no utilities within the proposed area so these would have to be provided. The cost of providing these would make it an uneconomic proposition.
6. The Council has produced no evidence in relation to the ecological and biodiversity importance of the land within the areas proposed. Development in this area would cause unacceptable harm to biodiversity interest contrary to the provisions of the NPPF. The area contains a number of protected species including water voles and badgers. This 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.
7. As site GT12 is in flat open countryside any new development could not be considered to positively enhance the environment and increase its openness. If a site of eight pitches is planned within GT12 then a significant development of some 1.8 hectares including at least eight or so permanent amenity buildings could not be integrated into the landscape without harming the unspoilt character of the area.
8. This site is physically separated from the settlement of Barford by the Bypass. It will not be possible to achieve peaceful integrated co-existence between the site and the village as the Bypass will cause a natural barrier.
9. Undue pressure will be placed on the local infrastructure which is stretched at the moment and will be further strained by the addition of 70 - 90 houses allocated in the New Local Plan. In particular the school is full at present - and although only 8 pitches are planned we are advised that Traveller families tend to be larger than average and this could result in more than 20 extra places being required.
There are some additional factors that are relevant to the decision but do not fit into the response categories defined.
The proposed site is Grade 2 agricultural land. It forms part of a small holding and selecting this area as a Gypsy & Traveller site will render the holding un-viable. The loss of this resource is not necessary and selecting an alternative site would enable this to be conserved.
The owner of the site is not willing to sell and Compulsory purchase proceedings would therefore need to be initiated. This will necessarily take a long time and is not guaranteed to be successful. No previous CPOs have been granted for Gypsy & Traveller sites in England. We are aware of one CPO by Mid Suffolk DC that has failed. There are alternative sites where the owner is willing to sell or the land is currently owned by WCC. These sites should be considered in preference to sites that may not be deliverable.
ALTERNATIVE STRATEGIES
BRA supports the proposal that 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.
The new Local Plan proposes a residential site at Thickthorn near Kenilworth. Currently the site is in the Green Belt and this indicates that WDC is willing and able to adjust the Green Belt boundaries to accommodate new development. The Publication 'Planning Policy for Travellers Site DCLG March 2012' states that 'a Local Planning Authority can make an exceptional limited alteration to the defined Green Belt boundary which might be to accommodate a site inset within the Green Belt to meet a specific identified need for a traveller site. It should do so only through the plan making process and not in response to a planning application. If land is removed from the Green Belt in this way it should be specifically allocated in the Development Plan as a traveller site only.' The WDC decision to exempt the green belt from the areas allocated for Gypsy and Traveller sites has resulted in an unacceptable concentration of these sites in the South of the District. This is evident in the brochure where the plan of the Green and amber sites is at twice the scale of the red sites and all the green sites are in the Southern half of the map. The council are currently preparing the New Local Plan and thus have an opportunity for a full review of the Green Belt throughout the whole district. Section 9 of the NPPF about protecting Green Belt land also makes it clear that the Local Plan is an opportunity to review the boundaries of the Green Belt.
SUMMARY
Barford Residents Association strongly objects to the inclusion of Site GT12 as a preferred site for a Gypsy and Traveller site to be located.
It fails all the criteria set out by Warwick District Council for a suitable site.
Necessary measures to reduce noise at the site from the adjacent Barford Bypass would reduce the available area to such an extent that less than 5 pitches that could be established making the site unviable.
The need to use a Compulsory Purchase Order to obtain the site and the likelihood that this will fail makes the site undeliverable.
FOOTNOTE
Although this objection is to the selection of GT 12 as a preferred site it should be noted that these comments are equally applicable to site GT alt 12, (not on the preferred list) which is nearby and also separated from Barford by the Bypass.

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

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

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

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