Testun llawn:
Response to the Warwick District Council (WDC) consultation on its Preferred Options for permanent sites for the accommodation of Gypsies and Travellers - GTalt03: Land at Henley Road/Hampton Road, Hampton on the Hill (Amber).
I formally lodge my objections to the classification of GTalt03 for the following reasons:
Green Belt and Previously Undeveloped Site
The site referenced as GTalt03 is identified as Green Belt in the Draft Local Plan. As such it has not been allocated for housing allocation nor is it within the boundaries of the village growth envelope for Hampton-on-the-Hill. 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 reclassified as 'red'.
DCLG March 2012 'Planning policy for traveller sites' Policy E: Traveller sites in Green Belt states:
"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."
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'.
I note that WDC has stated that "(t)he Council does not intend to own or manage Gypsy & Traveller sites itself. Experience of other Local Authorities shows that the best way for sites to be provided and run are by Gypsies and Travellers purchasing and setting them up for themselves." Again, WDC's intention not to own or manage sites and its preference for sites to be provided and run by Gypsies and Travellers does not override the site's classification as Green Belt; such preferences/unofficial criteria are not contained in the Government's 'Planning policy for traveller sites' or the National Planning Policy Framework.
In addition it is noted that:
a) the Gypsy and Traveller Accommodation Assessment (GTAA) for Warwick District, undertaken by Salford University in 2012, identified a need for 31 permanent pitches to be provided over a 15 year period, 25 within the first five years and in addition 6-8 transit pitches over the full 15 years; and
b) WDC has already identified sufficient 'green' sites to meet this identified need:
Site Reference Capacity (potential no. pitches) Recommended Maximum
GT04 15 10
GT12 15 8
GT15 5 5
GT19 5 5
GTalt01 15 10
GT02 15 10
GT05 15 10
GT12 8 8
TOTAL 93 66
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.
Bearing in mind that a pitch provides: 'accommodation for an individual family and consists of an area of hard-standing on which a park type home or permanent caravan, a touring caravan and associated vehicles can be located, together with a utility room for sole use of that household; and, assuming that a 'family' consists of 3/4 individuals (traditionally gypsy/traveller families are larger than average households - there is much reported evidence of this fact), WDC proposes that between 45-60 individuals (this excludes visitors and/or transient gypsy/travellers on the site) can be accommodated by a village of approximately 200 individuals, predominantly retired and substantial numbers of elderly women (including 30 elderly women living alone).
Such a change to the local community, representing an increase in population of 25-30%, would be disproportionate and the site would dominate the local community.
The development of the 1.66ha site will substantially change the character of the area. Given the physical and aesthetic nature of the proposal and the fact that the site is highly and clearly visible from both the Henley Road and the Hampton Road - such a development will permanently and substantially change the characteristics of the village. 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.
The site does not lend itself to the integration and inclusion of the gypsy/traveller into community.
The westerly aspect of this site is adjacent to the local community allotments; a small area bordered, on the opposite side, by residential properties. Hampton-on-the-Hill is a long established settled community with a particular socio-economic mix. Village residents' values are demonstrated by their financial and emotional investment, their permanence and their commitment to the preservation of the rural community. Their lifestyles are marked by quiet, sedentary and countryside pursuits.
The introduction of the Gypsy and Travellers site will lead to an imbalance of that community with little integration between the two. The lifestyles and cultural norms of the community for whom the land is sought are not renowned for quiet, sedentary activity or countryside pursuits. Whereas noise, disturbance, unruly and sometimes squalid conditions tend to be more commonly recognized features. Moreover, their 'travelling' tradition and practice belies disregard for the concept of an established community, a certain disrespect for the environment and an unlikely empathy for the residents of such a place. To find anything of common interest between the two lifestyles/cultures could not be more difficult. Inflicting a group of neighbours with such a divergent lifestyle on the established community would be cruel, divisive and highly contentious. It is very likely that there would be conflict, disputes, suspicions and discriminatory allegations. Harmonious coexistence is highly improbable and outcomes could have a significant impact on local authority resources.
The human rights of the existing settled community has to take priority over the transient population that is the Gypsy and Travellers community.
Children
It is noted that WDC accepts that Budbrooke Primary School is full/close to capacity. The assumption that additional funding for a school extension/expansion will be obtainable is not substantiated and certainly not guaranteed. Furthermore, given the housing allocation in the draft Local Plan for housing development in Hampton Magna of 100-150 properties, it would be reasonable to assume that the new housing development will require anywhere between 100-300 additional school places (approximately 10 classrooms). Substantial investment will be required to accommodate educational requirements in the area.
In addition, we have concerns for the safety of children on the site it is surrounded on two sides by busy roads with a speed limit of 50mph on Henley Road and Hampton Road being derestricted (60mph). There is no play area close to the site and the DCLG (May 2008) Designing Gypsy and Traveller Sites Good Practice Guide positively discourages the placement of sites close to electricity pylons for health and safety reasons.
Access
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 related to a single dwelling, not the current proposal for 15 pitches which could conceivably house a minimum of 30 adults (plus visitors and/or transient gypsy/travellers) owning anywhere between 15-30 vehicles which it would be reasonable to assume would create an additional 30-60 vehicle movements through any access road on a daily basis. This clearly poses a serious risk to both the occupants of the site and other road users.
It is noted that WDC has suggested that "(a)ccess is achievable along the Hampton Road with the required visibility splays". Given the narrowness of the road, the ditch, the steep incline onto the site, the 60mph speed limit and the possible numbers of vehicle movements I would suggest that this is not a viable option and that WDC is not sufficiently considering Highways Safety in its proposal.
Warwick Tourism and the Business Community
The site will be prominent to visitors entering and leaving the historic town of Warwick which is celebrating its 1100th year in 2014. Have Development Services consulted with Tourism Services and the wider business community about the potential impact this site is likely to have on the very important Warwick tourism trade?
Topography
The consultation document states that site GTalt03 is a level site when nothing could be further from the truth. The site is on the hill of Hampton-on-the-Hill which already has an issue with surface drainage onto Hampton Road. If the site is developed as suggested with a significant proportion of hard standing to accommodate mobile homes, caravans, motorhomes, vans, cars and other accommodation then this will exacerbate the already apparent flood and icing risk which will be a significant danger to the existing community and the incoming community.