BASE HEADER
Gwrthwynebu
Preferred Options for Sites
ID sylw: 65030
Derbyniwyd: 21/04/2014
Ymatebydd: Sarah Smith
2. History: How we got to this point
2.4 -OBJECTION
The assessment from Salford University contains no adequate "demonstration of the need for 31 pitches", the public was not consulted in its production and as the sole basis of the Council's policy, it is unreliable and unsound.
9. Summary of Preferred Option Sites
GT19 (p.42) - OBJECT
Against the Council's own criteria in section 6.1, GT19 fails on the following points.
1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.
Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.
As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.
The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.
As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.
The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.
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 FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
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
In addition, the commentary and treatment for this site is very one-sided. Firstly this is true as a standalone because factors mentioned in the full site assessment are omitted from the policy document. Secondly there is great inconsistency in the commentary on factors across different sites, which seriously undermines the soundness and confidence in the Council's approach.
For example (referring to the commentary on page 42):
"Site area reduced to avoid other existing uses and retain viability of remaining unit" There is no proof or even indication that this will be the case
"Possible use of existing access points" There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.
How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?
"Services available on site as currently used by Caravan and Camping Club" This is spun as a factor supporting GT19 as a Preferred Site. How does this compare with the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?
"Urban feel" This is subjective. Please explain what the Council means by this?
"A habitat buffer would be required"
Why it is not mentioned that the site is adjacent to Grand Union Canal Local Wildlife Site?
"Subject to agreement with the landowner, this site could be delivered within 5 years."
As the site is not readily available, why is this a Preferred Site?
The following key points have not been mentioned in the commentary within Section 9 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
1) The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this, why has GT19 therefore been proposed as a preferred site?
2) Possible flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly.
3) Part of the site is within high flood risk Zone 3. The proposed site is 0.3 acres in size. With part being within a high flood risk Zone- why does it therefore remain a preferred option?
4) Ecological factors being adjacent to the canal, and the Council's own plans show that this land has a high sensitivity to housing development.
5) Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
6) GT19 is adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
7) The Council recently rejected the proposed development of a similar site owned by Mr Arkwright further west along the Birmingham Road. What is the difference between that site and this one?
8) Reference to the site being located within the Green Belt have been included - however the reference that it has been "previously developed land" is misleading. The previous use of the land was for agricultural purposes.
On top of all this Site GT19 is located in the Green Belt. The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, and the Council has failed to demonstrate any "exceptional" circumstances. It should simply not be promoting any Green Belt site above any non Green Belt site. I am aware of correspondence from a Warwick DC officer in the consultation round in July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable because the need can be clearly met from non Green Belt sites.
Site GT19 is clearly unsuitable for this use. There are fundamental questions outlined above that I would like a response from Council officers on please.
Please respond to this point about the Green Belt and other questions that have been asked above.
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
GT19 - there is no mention that Mr Butler, the current owner of GT19, is not prepared to sell the land to the Council. A fact which he has told all Hatton Park Residents - and was confirmed by Clare Sawdon in the recent Hatton Park Action Group meeting of March 2014.
By comparison Sites GT02, GT05, GT06, GT08 and GTalt12, all in the Alternative Sites list, all say "the land owner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward."
This, rather than sound planning reasons, seems to be the principal factor in the Council's site selection process. You are not fully or fairly representing the situation by omitting this information in this case.
Please could Council officers explain this inconsistency? Please can Council officers explain the selection process between Preferred and Alternative sites?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
GT19 - Within the Detailed Gypsy and Traveller Site Assessments it has been noted that "the site is adjacent to the Grand Union Canal Local Wildlife Site." This comment has not been included within Section 7 and the site remains a preferred option.
By comparison there are numerous other cases where the sites' proximity to a LWS has been included within the commentaries in Section 7.
Please could Council officers explain this inconsistency?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
GT19 - "Services available on site as currently used by Caravan and Camping Club " has been presented as a positive factor.
By comparison:
GTalt22 - "As a Caravan and Camping Club site, this use would not be suitable"
Please could Council officers explain this?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
A fundamental flaw in this draft policy is that there is no explanation of why some 'green' sites are in Preferred Sites and others are Alternative Sites.
Could Council officers please explain this shortlisting process, and provide copies of scoring sheets?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
We are aware that the Council recently rejected the proposed development of a similar site between the canal and Birmingham Road owned by Mr Arkwright, closeby to the west along the Birmingham Road.
How does the Council reconcile the refusal of this proposal with listing GT19, a similar nearby site, as a Preferred Site?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
Given the congestion, how does the Council think that the movement of large vehicles into and out of the site will be managed?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
1. Ecological factors are important as the site is adjacent to the canal, and occupation / development of this site will impact on the visual amenity of the Grand Union Canal.
2. The Council's own plans show that this land has a high sensitivity to housing development.
3. The Grand Union Canal Local Wildlife Site is adjacent to the site.
Why was point 3 not mentioned in Section 7 of this document? Why is GT19 proposed as a Preferred Site given this sensitivity?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
There is the possibility of flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly. Part of the site is within high flood risk Zone 3 (the proposed site is only 0.3 acres in size).
With part being within a high flood risk Zone- why has GT19 therefore been proposed as a preferred site?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this.
Why has GT19 therefore been proposed as a preferred site?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states:
"Services available on site as currently used by Caravan and Camping Club"
This is seemingly presented as a factor supporting GT19 as a Preferred Site.
Please explain to me the treatment of this factor compared to the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states as a supporting factor:
"Possible use of existing access points"
1. There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.
2. How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states:
"Site area reduced to avoid other existing uses and retain viability of remaining unit"
There is no proof or even indication that this will be the case
What evidence is the Council using to make this statement? Please respond.
7. Sites Summary Table
GT19 - OBJECT
Against the Council's own criteria in section 6.1, GT19 fails on the following points.
1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.
Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.
As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.
The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.
As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.
The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.
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 FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
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
Why is GT19 a Preferred Site? Please respond.
7. Sites Summary Table
OBJECT
As a general point, but with specific regard to site GT19. the commentary and treatment are very one-sided:
1. As a standalone because factors mentioned in the full site assessment for GT19 are omitted from the policy document - this misrepresents the site characteristics
2. There is great inconsistency in the commentary on factors across different sites. For example the phrase "Services available on site as currently used by Caravan and Camping Club" is used as a supporting factor in GT19 but a negative factor for GTalt22.
How can this be? This seriously undermines the soundness and confidence in the Council's approach
3. Warwick District - Context
3.6 - OBJECT
The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, not "special". This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should simply not be promoting any Green Belt site above any non Green Belt site.
I am aware of correspondence from a Warwick DC officer in the consultation round in July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable.
3. Warwick District - Context
3.5 - OBJECT
The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, not "special". This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should simply not be promoting any Green Belt site above any non Green Belt site.
I am aware of correspondence from a Warwick DC officer in the consultation round in July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable.