Testun llawn:
1) Access
The Council's Consultation document fails to address the issue of Access to the proposed site simply stating 'Advice expected from WCC soon'. However unless Severn Trent Water are willing to provide access to the site across their land (which they have indicated they would not) then the current narrow farm track leading to the site from Longbridge would be totally inadequate. The Government's own guidelines on planning Gypsy and Traveller sites set some very strict guidelines around access, particularly for Emergency Vehicles stating that:
'In designing a site, all routes for vehicles on the site, and for access to the site, must allow easy access for emergency vehicles and safe places for turning vehicles' and 'To increase potential access points for emergency vehicles, more than one access route into the site is recommended. Where possible, site roads should be designed to allow two vehicles to pass each other (minimum 5.5m). Specific guidance should be sought from the local fire authority for each site'.
The current farm track would therefore appear to be totally unsuitable. In addition, accessing the site from Longbridge would place the main entrance to the site next to a Grade 2 listed building (Longbridge Manor) which is itself located on a dangerous bend in the road with poor visibility for motorists.
2) Air, Water and Soil Quality
The Council's own Sustainability Assessment identified this as an area of significant concern (flagged as red) with a 'potential major negative effect'. They have suggested that these issues could be 'mitigated' but have provided little further detail and clearly a site located very close to a sewage works and a busy motorway is likely to have issues with all 3 and therefore is not suitable for a permanent residential development, particularly one where children will live.
The government's own guidelines on planning Gypsy and Traveller sites state that:
'It is essential to ensure that the location of a site will provide a safe environment for the residents. Sites should not be situated near refuse sites, industrial processes or other hazardous places, as this will obviously have a detrimental effect on the general health and well-being of the residents and pose particular safety risks for young children. All prospective site locations should be considered carefully before any decision is taken to proceed, to ensure that the health and safety of prospective
residents are not at risk'.
The fact that they have flagged this issue as red but not subsequently highlighted it in either the consultation document itself or the response form suggests that this is another area to focus on.
3) Flood Risk
Again the Council's own 'Sustainability Agreement' identified this as an area of concern (flagged as yellow) indicating a 'minor negative effect'. Nevertheless they have confirmed that the site is on a designated flood plain within flood zones 2 and 3.
The government's own guidelines on planning Gypsy and Traveller sites states that 'Caravan sites for permanent residence are considered "highly vulnerable" and should not be permitted in areas where there is a high probability that flooding will occur (Zone 3 areas)'. The Consultation Document states that the Council has a technical report endorsed by the Environment Agency saying that the risk of flooding can (once again) be 'mitigated' and this will 'eradicate the threat completely' but the report is quite high level and simply sets out possible options that could potentially address the flooding risk so it doesn't mean that the flood risk can definitely be eliminated. Nor does it detail the cost of all this mitigation work.
Given the Government's own guidelines the Council will need to prove definitively that the risk of flooding can be completely eliminated (as well as explaining who will pay for all the necessary work) or clearly the site is not suitable.
4) Effect on the local Economy
In the Council's own Sustainability Assessment this section is graded as '?' and the supporting commentary states that 'the effect on the economy is uncertain at this stage'. Furthermore the Consultation Documentation makes no mention of the potential effect of the site on the local economy in its criteria at all. Given that the Tournament Fields business park remains largely undeveloped after almost 10 years and the likely effect on future demand if a Gypsy and Traveller site is opened opposite to it, this clearly suggests that the Council is trying to avoid the whole issue of the negative effect on the local economy that the proposed site could have.