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We write on behalf of Taylor Wimpey UK Ltd in respect of the Warwick District Council Gypsies and Travellers Preferred Options consultation document. Whilst there is an identified need to be met for Gypsies and Travellers either living in or passing through the area, it is imperative that the preferred sites are located where they embrace opportunities for community cohesion and maximise the accessibility of services for all. In addition the Green Belt designation of land, as exists across much of Warwick District, should be given due weight.
Preferred site at land off Birmingham Road, Budbrooke (site GT19)
We note that, despite our previous representations, site GT19 has now been recognised as a 'preferred' site by the Council for meeting the Gypsy and Traveller need over the Plan period. Whilst the site is located in the Green Belt, the Council have seemingly determined that the status of the site as previously developed land provides the exceptional circumstances required by paragraph 83 of the National Planning Policy Framework (NPPF).
The Planning Policy for Traveller Sites document published by DCLG in March 2012 states in paragraph 14 that, 'Traveller sites (temporary or permanent) in the Green Belt are inappropriate development.' As per paragraph 83 of the NPPF it then goes on to add in paragraph 15 that 'Green Belt boundaries should be altered only in exceptional circumstances.'
In assessing the site for the Preferred Options consultation document there is a limited reference to the 'exceptional circumstances' test in the NPPF, however, at no point in assessing site GT19 does it state precisely how the Council have determined that this test has been met. Although the statement at the start of the summary of GT19 on page 42, 'The land is in the Green Belt but part of a larger use making it previously developed land', suggests that the development status of the site as previously developed land is what, in the Council's view, offsets the loss of Green Belt land and provides an exceptional circumstance.
However, we would consider that in order to demonstrate exceptional circumstances in this regard it should be demonstrated that the needs for the Gypsy and Traveller community cannot be met on non-Green Belt sites. We do not consider that this has been demonstrated by the Council at this
time and we would ask that further justification is provided at any subsequent consultation period if the Council consider this to be the case.
In addition, we would note that the character of the land as a Caravan and Camping Club site is different to that of a Gypsy and Traveller site. The Caravan and Camping Club site is likely to have usage restrictions in terms of the number of consecutive days that people can remain on the site and limited usage in the winter months, whilst Gypsies and Travellers will be residing on this site as a permanent base and thus a quite different effect on the site is anticipated.
We would also disagree that there is an 'urban feel' to this side of Birmingham Road, as set out on page 42 of the Preferred Options consultation document. There is, at best, a partial ribbon of development along the southern side of Birmingham Road. However even this ribbon is punctuated by green gaps along its route and thus in our view aspects of rurality are retained along the southern side of Birmingham Road.
We are also concerned as to whether the location of the Birmingham Road will lead to a level of detachment from the community which is inconsistent with the aspirations set out in paragraph 11 of the aforementioned Planning Policy for Traveller sites document, including:
* promote peaceful and integrated co-existence between the site and the local community; and
* provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there or on others as a result of new development (Para. 11).
Summary
Given the above it is considered that the Council have failed to show the exceptional circumstances required for releasing Gypsy and Traveller sites in the Green Belt. Furthermore the Council should ensure that there are opportunities to achieve community cohesion and access essential services for the travelling community on any sites included as future allocations. In our view, these factors should restrict development of a Gypsy and Traveller site on the preferred option site on land to the south of Birmingham Road, Budbrooke (site GT19).
We trust the enclosed representations are clear. If however you have any queries or wish to discuss the above in any further detail, please do not hesitate to contact me.