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Objection to GT19 in response to the consultation document "Warwick District Council March 2014, Sites for Gypsies and Travellers, Preferred Options for Sites"
Dear Sir/Madam
I write to you to formally submit my objection to the proposed Gypsy and Traveller site on the land adjacent to the Shell Petrol Filling Station, Birmingham Road, Budbrooke, Warwick (site reference GT19).
In summary, GT19 is not suitable for developing a Gypsy and Traveller site on the following grounds:
GT19 is not previously developed land
Inappropriate use of Green Belt
Safety for the Gypsies and Travellers, all pedestrians and all road users
Sustainability for the Gypsies and Travellers, local residents and Oaklands Farm
Inappropriate use of tax payers' money
Therefore, GT19 should be removed from the list of proposed Gypsy and Traveller sites, preferred, alternative or otherwise.
The supporting detail for the above objection has been set out in 3 sections below:
1. An appraisal of the summary for GT19 extracted from the Consultation Document
2. An appraisal of the Proposed Gypsy and Traveller Site Assessment Criteria in relation to GT19
3. Other factors material to this objection
For ease of reading, the following terms will be used throughout this letter:
Consultation Document - the consultation document referenced above
GT19 - the proposed Gypsy and Traveller site referenced above
WDC - Warwick District Council
Oaklands Farm - the entire Oaklands Farm site of which GT19 is part
A4177 - the Birmingham Road running adjacent to the north side of GT19
1. Summary of preferred option sites, extracted from the Consultation Document for GT19
The following summary for GT19 is extracted from section 9, page 42 of the Consultation Document with specific comments and objections added in line:
a. The land is in the Green Belt but part of a larger use making it previously developed land. This statement is very misleading. Yes, of course some areas of the overall site areas have been previously developed, but GT19 is an open pasture and very clearly has not been previously developed meaning that it does not meet the PO1 criteria set out in the Consultation Document.
There have been a number of planning applications for Oaklands Farm to date and three of the most pertinent to this Consultation Document and this objection are referenced below:
i. For planning application W20020836, the present owner sought to store caravans and this was refused with the key reasons including:
Prominent position within the Green Belt and Special Landscape Area known as the Arden Parklands
Adjacent to the busy A4177
Close proximity to the Grand Union Canal which is very popular tourist destination for local residents and visitors to the area.
Seriously detrimental to the visual amenity
Not of sufficient merit to justify a breach of Green Belt policy
ii. Through previous planning application W20021250, the present owner sought permission to park caravans pre- and post-repair in an alternative area on the site. This was refused and all parking restricted to the area adjacent to the canal boundary and therefore the parking of caravans on GT19 was prohibited under this refusal. The reason cited was in the interests of the visual amenity of the area.
iii. An outline planning application (W/10/0245) was submitted in 2010 to replace the existing dwelling at Oaklands Farm with a new dwelling at the eastern edge of GT19 extending into the Oaklands Farm site. This was approved in April 2011 and the reserved matters application (W/14/0474) was submitted in April 2014 which includes the detailed landscaping leaving the majority of GT19 as open land and being a very sensible use of the overall Oaklands Farm site to ensure its future viability.
These planning applications are the strongest indication that the Oaklands Farm site requires careful development to ensure its future viability whilst fully considering the needs of the Green Belt. It is also clear that through the previous refusals of planning applications that the development of GT19 as a Gypsy and Traveller site is not appropriate.
b. It is located adjacent to a petrol filling station and other houses and although faces open countryside currently, has an urban feel on this side of the Birmingham Road. The term "urban feel" is very subjective and is very misleading. There are only a handful of properties and buildings along this part of Birmingham Road and the views are dominated by open fields, the Grand Union Canal, trees and hedgerows. If a subjective assessment of this particular site was appropriate, I would suggest that the vast majority of people would assess as "rural feel" rather than "urban feel". As indicated through the various planning refusals for the development of GT19, this site is not suitable for developing as a Gypsy and Traveller site.
c. Currently this part of the land is used as a site for the Camping and Caravan Club so services are already available. GT19 only has water within its boundary, but there is a chemical toilet disposal point, toilet, electricity and gas available on Oaklands Farm.
d. The site area has been reduced from that originally considered to avoid other existing uses and retain the viability of the remaining unit. The viability of the remaining unit relies on the continued use of the caravan repair service, kennels and Camping and Caravan Club site, and all 3 income streams would be seriously impacted if GT19 went ahead:
Camping and Caravan Club: clearly the bookings would cease as that is the land being proposed for GT19.
caravan repair service: it is very hard to see how this would not be severely impacted as whilst there is little evidence that crime increases through the introduction of a Gypsy and Traveller site, there is a very strong public perception that it does. Therefore the general public are unlikely to continue to use the caravan repair service leaving their expensive caravans adjacent to GT19.
kennel business: the majority of gypsies and travellers have pet dogs and the general public are highly likely to avoid using the Oaklands Farm kennel service, being put off through risk of disease (from dogs and other pets belonging to the gypsies and travellers who have not had the recommended inoculations) and the likelihood of the dogs belonging to the gypsies and travellers running loose, barking and frightening their pets whilst boarding at the kennels and during drop off and pick up.
e. The existing access points are already used for the Camping and Caravan Club caravans and fewer movements of large vehicles would take place on a permanent site. The proposed GT19 site does not have access to the A4177 via the access point used by the Camping and Caravan Club. It is highly unlikely that the Highways Department would approve an extra access point onto the A4177 on highway safety grounds due to visual splay issues and distance to other access points already there. Using the Ugly Bridge Road access point would not be possible for similar reasons and this access has been specifically excluded by WDC for any use other than agricultural in the interest of highway safety under planning application W20021250.
The movement of the large, permanent caravans would be extremely dangerous for any access point to GT19 and it has been made clear that the proposal would provide for smaller caravans on each pitch which would be moved much more frequently and significantly than for the existing Caravan and Camping Club site which only has a handful of movements per week.
f. This site could connect to the existing foul sewer. The toilet and chemical toilet disposal point for the Camping and Caravan Club site are located next to the existing dwelling at Oaklands Farm which is approximately 60m from GT19.
g. A habitat buffer would be required along the line of the watercourse which flows along the southern boundary. In order to screen GT19 from passing traffic and pedestrians, a significant additional buffer would be required all the way around the site as the existing hedges and trees are intermittent in places and being largely deciduous, for around 50% of the year, they provide very little screening. This would reduce the stated 0.3 hectare area meaning that achieving 5 pitches is highly unlikely.
h. The land is Grade 3 agricultural land and therefore not of the highest quality. The Department for Environment, Food and Rural Affairs (DEFRA) definition of grade 3 agricultural land is "good to moderate quality agricultural land". It is clear to see that this field would make a perfect grazing pasture which is indeed the case for a number of fields in the local area. Just because the current owner has chosen not to use the field in this way is no reason to suggest the land should be developed as a Gypsy and Traveller site.
i. The Priority area school would be Budbrooke Primary School where numbers are falling. The school does currently take children from Warwick which is out of its catchment area. A bid has been made for funding to expand this school based on the knowledge that there could be more 'in area' children in the future when new village housing is developed. The sustainability, numbers and future of the school are all currently unclear as the school has recently been put into special measures. There is a very active parent group working to resolve this situation and quickly and it is looking very likely the school will become an Academy. Exactly what this means is yet to be established and therefore, the availability of places to serve children resident on GT19 is also in question.
j. There is a GP surgery located at Hampton Magna (1.1 miles) and public transport is provided by the 68 bus service, the 60 bus service (irregular) and the 511 bus service (irregular) all of which pass the site. There is a serious error here on the viability of the public transport links to support GT19:
 The 60 service is a Warwick College inter-campus service, so the frequency and availability to the public is in question.
The 511 service is very infrequent (not irregular) only running on Wednesday and Saturday with just one outward and one return bus on each of those days.
The 68 service stops on the A4177 opposite GT19 on its way into Warwick and the return stop is 0.25 mile away at the bottom of Hatton Park. In both cases, passengers would need to cross the A4177 which is extremely dangerous with no pavements on the GT19 boundary to the A4177 or Ugly Bridge Road. There is the alternative of using the canal tow path to cross further up the A4177 at the pedestrian refuge island (at Middle Lock Lane) but this extends
the distance to the bus stop to over 1 mile for journeys into Warwick and 0.75 mile for return journeys making the shorter route or dangerous shortcut across the petrol filling station the much more likely route.
k. Subject to agreement with the landowner, this site could be delivered within 5 years. Due to the issues identified above around the viability of the remaining unit, it is highly unlikely this is achievable.
2. Proposed Gypsy and Traveller Site Assessment Criteria
The council has based its assessment of the proposed sites on clear criteria set out in section 6.1, page 13 of the Consultation Document. These are included below with specific comments and objections added in line:
Criteria Comments and Objections 1 Convenient access to a GP surgery, school, and public transport There is a GP surgery approximately 1.1 miles way and infant/junior school approximately 1.4 miles away, and as noted above the availability of places is in doubt because the school is currently in special measures and the future plans for the school are unclear. The public transport is very limited to this site (see details above) and pedestrian access to the bus stops referenced is very dangerous. 2 Avoiding areas with a high risk of flooding A full survey should be carried out as there is a water course running along the southern boundary approximately 1m below the site level and during wetter periods the site can get very waterlogged. 3 Safe access to the road network and provision for parking, turning and servicing on site It is highly unlikely that this criterion can be met without significant development of the road system. The proposed site does not include access to the A4177 and an additional access to the A4177 is unlikely on highway safety grounds. Using the Ugly Bridge Road access would be extremely dangerous and has been specifically limited to agricultural use by WDC through a previous planning application (W20021250) again on highway safety grounds. 4 Avoiding areas where there is the potential for noise and other disturbance The site is right next to the busy A4177 and therefore it is highly unlikely that acceptable noise levels can be reached. It is also adjacent to the petrol filling station which operates 24x7 therefore having a steady stream of vehicles throughout the night and night lighting which would be very intrusive for the Gypsies and Travellers living just a few
metres away. 5 Provision of utilities (running water, toilet facilities, waste disposal, etc) GT19 only has water provision with all other services available on Oaklands Farm. 6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment This cannot be achieved. There have been various planning applications to WDC for GT19 and in all but one case the application has been refused with various reasons which equally apply to the proposed Gypsy and Traveller site. The key reasons for refusal are:  Prominent position within the Green Belt and Special Landscape Area known as the Arden Parklands  Close proximity to the Grand Union Canal which is a very popular tourist destination for local residents and visitors to the area.  Seriously detrimental to the visual amenity The only planning application for GT19 to be approved is an outline planning application (W/10/0245) to replace the existing dwelling at Oaklands Farm with a new dwelling at the eastern edge of GT19 extending into the Oaklands Farm site. This was approved in April 2011 and the reserved matters application (W/14/0474) was submitted in April 2014 which includes the detailed landscaping leaving the majority of GT19 as open land and being a very sensible use of the overall Oaklands Farm site to ensure its future viability. 7 Sites which can be integrated into the landscape without harming the character of the area. Site development will accord with national guidance on site design and facility provision This is not possible. The canal towpath runs along the entire length of the south side of GT19 at a higher elevation, and there are views from the A4177 across GT19 to the canal. Even if adequate screening could be provided, the open nature of the area and views over the canal will be severely impacted, and without adequate screening, the visual amenity of the area would be severely impacted. Developing GT19 as a Gypsy and Traveller site will severely harm the character of the area which would have a significant impact on the local community and visitors to the area who come to enjoy the Grand Union Canal with views over the open countryside and Warwick. 8 Promotes peaceful and integrated co-existence between the site and the local community The overriding feeling in the local community is that GT19 will not add any value to the local community and is not a suitable location for a Gypsy and Traveller Site. Therefore, a
peaceful and integrated co-existence with the local community is highly unlikely. With the towpath just a few metres from GT19, any issues with dogs running loose or barking at passing walkers (some with their pet dogs) and cyclists will at best be a nuisance and more likely to introduce a significant danger with a canal lock adjacent on the other side. Any issues will directly impact local tourism and deter the people who regularly walk along the towpath to seek other routes which would be a great loss to the overall community. 9 Avoids placing undue pressure on local infrastructure and services The road network in the local area is currently severely stretched and already creates significant local frustration. The introduction of GT19 would compound that situation further. 10 Reflects the extent to which traditional lifestyles (whereby some travellers live and work-from the same location thereby omitting many travel to work journeys) can contribute to sustainability Due to the very small size of the site, it is doubtful that this can be achieved unless the number of pitches is significantly reduced or the nature of the proposed work was office/computer based rather than requiring a workshop, outbuildings or yard.
3. Others factors material to the objection of GT19
a. Green Belt There are a number of policies relating to the Green Belt and refusals of previous planning applications which very clearly indicate that the development of GT19 as a Gypsy and Traveller site would be inappropriate. Some of the key relevant policies are:
i. Section 9 "Protecting Green Belt land" of the National Planning Policy Framework published March 2012 This sets out a number of policies specifically relating to the protection of the Green Belt. There are 3 in particular which should be considered in relation to the GT19 proposal:
87. As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.
88. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason
of inappropriateness, and any other harm, is clearly outweighed by other considerations.
89. A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:
buildings for agriculture and forestry;
provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it;
the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building; the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces; limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan; or
limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.
With the required 31 pitches being achievable through the other preferred sites or alternative sites there are clearly not "very special circumstances" sufficient to warrant the use of GT19 by outweighing the harm to the green belt. Additionally, the policy above (reference 89) excludes the building of any amenity blocks which would therefore not allow the criteria to be met as set out in the Planning Policy For Traveller Sites published in March 2012.
ii. Kites Nest Lane Beausale, Warwick - planning application W/12/1428 Planning permission was refused on 6/2/2013 for a change of use at this site from agriculture and keeping of horses to a gypsy and traveller site:
The reason(s) for the Council's decision for refusal is/are:
1 The proposal constitutes inappropriate development within the West Midlands Green Belt as set out in the National Planning Policy Framework and so is harmful by definition. There would also be encroachment and harm to the openness of this part of the Green Belt resulting from both the change of use and erection of buildings inherent with a gypsy caravan site. This together with the significant harm to the character and appearance of the Arden Regional Character Area and component Ancient Arden and Arden Parklands landscape type as defined by the Warwickshire Landscape Guidelines SPG amount to substantial other harm which cannot satisfactorily be mitigated by the proposed concept landscaping scheme. On the other side of the balancing exercise it is accepted that there is a quantified and unmet need for permanent gypsy and traveller pitches in Warwick District contrary to national policy and that some of the personal circumstances of some of the applicants need to be given some weight. However it is appropriate to allow the emerging Warwick District Local Plan process to run its course since there is a
likelihood that that need could be met either on sites outside the Green Belt or if necessary less attractive sites within the Green Belt. It is considered that such factors do not amount to very special circumstances that clearly outweigh the policy presumption against the identified harm to the Green Belt.
The same fundamental principles apply to GT19.
iii. Planning Policy For Traveller Sites The government published the Planning Policy For Traveller Sites in March 2012. There are a number of key policies in this document which have been covered above and the most significant policy which is not met by the proposed GT19 site is:
Policy E: Traveller sites in Green Belt 14. Inappropriate development is harmful to the Green Belt and should not be approved, except in very special circumstances. Traveller sites (temporary or permanent) in the Green Belt are inappropriate development.
This policy coupled with the fact that there are sufficient pitches available across the other preferred and alternative sites which are not in the Green Belt means that very special circumstances do not exist, and therefore this makes GT19 unsuitable as a Gypsy and Traveller site.
b. Safety The A4177 is a very busy road, dangerous for cars and very dangerous for pedestrians and cyclists with a number of serious accidents over the last few years with a number of fatalities. This situation continues to get worse due to the increased volume of traffic on the A4177 and bottleneck at Stanks Island into Warwick.
Due to the proximity to the busy A4177, Ugly Bridge Road and the canal, it would be necessary to secure the site on all sides to prevent pets and children straying outside of GT19 endangering themselves and other road users.
Crossing the A4177 is extremely dangerous - if crossing to or from GT19 there are numerous accesses and road junctions for pedestrians to aware of and there are no pavements on the A4177 side. Additionally, there is no street lighting on any side of GT19 making pedestrian access at night a particular problem.
The canal runs behind the site and would present a significant risk to young children. The houses in the community with children have large and secured gardens and it is very rare to see small children along the canal without their parents due to the danger of the canal itself and in particular the locks.
The access to the site will present a significant problem and it is difficult to see how access can be provided without introducing significant additional risk to road safety especially for the delivery of 25m mobile homes and regular movements of 15m trailers.
c. Sustainability The level of traffic on the A4177 and the commonly used routes through Warwick and Leamington Spa is already at the point where the daily lives of local residents is being severely impacted.
In morning rush hour, the 1 mile journey from the bottom of Hatton Park to Stanks Island can take up to 30 minutes; it regularly takes 15 minutes and in extreme cases
can be 1-2 hours if there is an accident on the M40 or M42. Additional traffic, however low in volume, should not be added to this locality without proper measures being taken in the wider road network.
Due to the small size of the site, it is unlikely that provision for Gypsies and Travellers to work on the site would be possible.
As outlined above, the delivery of GT19 would make the existing Oaklands Farm site unviable and would have a significant negative impact on the current owner's livelihood.
d. Size of site The government published the "Designing Gypsy and Traveller Sites - a Good Practice Guide" in May 2008. This outlines a number of considerations including pitch size, access, buffers and screening with some of the more relevant points relating to GT19 being:
accommodate trailers up to 15m, up to 2 smaller touring caravans and 2 additional vehicles
provide a suitable recreational area for children with no other suitable play area in the surrounding area
provide amenity buildings
provide access roads in the site to a minimum width of 3m.
For practical reasons, caravan sites require a greater degree of land usage per household than for smaller houses and Gypsy and Traveller sites are no exception.
Additionally, once populated, the small site would have very limited flexibility for visitors which would be seriously detrimental to the lifestyle of Gypsies and Travellers and would run a very high risk of illegal occupation of surrounding fields and properties to accommodate visitors to GT19. There has already been significant disruption to the local community at the Kites Nest site and at the lower end of the footpath leading up to King Edwards Park, and this is not a situation that the local community wishes to be repeated.
Considering all of the above, it is very doubtful that GT19 could deliver 5 pitches and therefore would fall below the government guideline of between 5 and 15 pitches per site. Additionally, when considering the likely cost and further erosion in the number of pitches to fully address the safety issues and with the ability to deliver the full number of 31 pitches through other sites, it does not make sense to proceed with GT19.
e. Inappropriate use of tax payer's money
As indicated in the "size of site" section above, the maximum number of pitches that GT19 could support is likely to be 3-4.
There would be a significant cost implication of developing GT19 including:
Purchase of GT19
Site preparation including hard standing, connection to services and suitable screening
Site safety considerations including perimeter security to prevent children and pets wandering onto the road or canal
Site access and highway safety considerations for vehicles, likely to include significant re-development of the road system adjacent to the site
Highway safety considerations for pedestrians - to include a crossing of some description and the addition of suitable lighting at night
Compensation for the economic impact to Oaklands Farm
The total of the above would therefore run into hundreds of thousands of pounds and in excess of £100,000 per pitch. As a tax payer to WDC, I would be appalled at this level of expense and I know that this would be a view shared by the vast majority of WDC tax payers.
I look forward to seeing the revised proposal for the development of Gypsy and Traveller sites with GT19 removed as a result of this consultation.