Testun llawn:
WDC Local Plan Gypsies & Travellers Preferred Options Consultation
The JPC accepts that allocations must be made for the G&T community within the WDC New Local Plan - rather than relying on sites coming forward through the conventional planning process and we also understand the importance of G&T issues in the Local Plan process, however the JPC believes that any such allocation must be made on a fully democratic and objective basis.
When the June 2013 consultation was staged we were unimpressed with the level of detail provided and very disappointed at the lack of local knowledge and erroneous justifications for selected sites. It can be no surprise that local communities erupted in response to such ill thought-out blight on our district.
Given the levels of residents' responses it is surprising that the Preferred Options consultation has now followed with a similar level of erroneous information and even less quantifiable justification for the Preferred Option choices.
We find the presentation of material confusing at best given that much of the important evidence is buried on the website as "Further Evidence" and "Background" and much that is there is either erroneous and/or conflicting with the March 2014 PO document. At another level we and the vast majority of our residents who have commented found the "Drop-In Sessions" with just a couple of posters and scattered booklets to be a singularly poor way to disseminate information especially as the staff provided had minimal technical knowledge of the subject matter and made it clear that they would not be collating comment made on the day.
We are also concerned at WDC's apparent willingness to rely on the Compulsory Purchase approach given the associated costs and delays which will render most sites non-viable financially and non-deliverable in the terms required. Furthermore success of the CPO process has yet to be established as evidenced by the 2012 Mid Suffolk DC case when the Inspector found insufficient evidence to support CPO on the grounds of "public interest".
We would question WDC's election to limit site sizes to a maximum of 10 pitches, with some considerably less, as this means that site provision must then blight more communities and settlements than is reasonably necessary. If site size limitation is in order to facilitate management and policing this surely gives credence to many residents' concerns about crime and disorder in or near such sites.
Reduction in site size (or more specifically pitch numbers on individual sites) loses economies of scale in terms of establishment costs, management costs and land take whilst directly impacting a greater number of the general population.
National guidance suggests sites of 5-15 to be preferable and this would suggest that our required 31 pitches could reasonably be accommodated in two or at most three sites.
The JPC would suggest that any or all proposed sites could be best accommodated and assimilated in areas which are not current settlements and that they should be properly planned, at a very early stage, into much larger schemes preferably incorporating residential and employment development.
We find the cursory dismissal of such an approach (Page 12, end of section 5) totally unsatisfactory and unacceptable.
The JPC also believes that the Siskin Drive and Gateway area should be vigorously explored to create a site with a mechanism to accommodate the G&T community within an evolving area where they could best integrate with their surroundings.
Whilst reviewing WDC's commentaries on sites in the original and the current consultation we have found that they are erratic and inconsistent. Criteria are sometimes used to support a choice/site and at other times the same criteria are used in a converse manner. The way in which the supporting Sustainability and Sites Assessments have been used to arrive at the Preferred Options is opaque in the extreme and certainly the interpretation of the Sustainability Assessments based on colour coding appears to be minimally objective.
Examples of inconsistencies relate to noise impacts, site prominence in the landscape, flooding, agricultural land value/viability, proximity of services and pedestrian access/safety. Latterly, especially with the "GTalt" sites, there seems to be an inordinate reference to "surface flooding".
The paperwork provided and the public consultations staged also seem to take no or little account of the cost implications inherent in the various Preferred Option choices and we believe this should be a significant factor when making a final selection given the inherent importance of economic viability.
In consideration of the above the JPC has conducted an objective assessment of all the sites which have come forward under these consultations, as well as our lay skills permit, and concludes that not all of the selected Preferred Options are indeed the best sites of those presented.
The findings are presented in spreadsheet format showing support where we believe it to be appropriate. Where we draw different conclusions we offer rebuttal and further comments as seems appropriate and helpful.
The spreadsheet details are as follows:
* Column 1 - Site identification number and PO indication and JPC support or otherwise
* Column 2 - Précis of WDC comments
* Column 3 - JPC commentary
* Column 4 - Sites which JPC consider could reasonably be progressed (where sites cannot be integrated into "larger schemes").
Inevitably the JPC has been much exercised by contact from residents concerning sites proposed within our JPC parishes and we must comment that these sites seem to have been singularly poorly selected. This situation is not helped by the fact that they seem to have come forward accompanied by blatantly incorrect supporting information, viz:
* Repeated reference to Barford doctors' surgery - when the last part-time surgery closed over 30 years ago
* Inclusion of the Barford Bypass flood compensation pond area as site GT16
* Inclusion of Barford Community Orchard and Riverside Walk in GTalt12
* Inclusion of spillage/reed ponds within GT12 in March 2014
* Confusion over the maps for GT12 And GT16 in June 2013
* Confusion over the map of GT12 in March 2014
* Confusion over the map of GTalt12 in March 2014
On a purely local basis it seems bizarre and is certainly unacceptable to blight Barford, recently judged amongst the best 10 places in the Midlands (and number 57 nationally) to live, with the Preferred Options selection of such obviously poor sites. Should the Barford sites persist we are sure that residents will support the landowner in challenging Compulsory Purchase, increasing costs and delay to all concerned and further impacting deliverability.
We are also reminded that there is a duty to co-operate across boundaries and would draw your attention to the site which Stratford DC have at Blackhill, immediately adjacent to Sherbourne parish.
We hope that you will take this letter and the associated spreadsheet in the constructive manner in which it is intended, in order to assist in achieving the best possible solution for both the settled and travelling communities.