Testun llawn:
I recognise the ethical and legal responsibilities of the Council to provide permanent sites for the travelling communities in the Warwick District area. However, the selection of the Stratford Road site is incorrect in the substance of the decision and in the process of the decision (including not facilitating a full set of public meetings with suitable access for the working community; particularly for those who travel long distances using the transport links highlighted by the Council as an advantage of this site - this seems a highly incoherent approach from the Council that suggests that the Council is trying to rush this decision through without sufficient engagement with the local community). These failures in substance and procedures of the decision-making process unfortunately leaves Warwick District Council highly vulnerable to a successful legal challenge - at the end of such a challenge, there will ultimately be no winners as the Council (and ultimately council tax payers) will foot a bill for a legal process that will have delivered nothing for the travelling community, and is likely to have damaged the economic prospects of a very important employment area of Warwick. Therefore, in the interests of all parties, I urge Warwick District Council to step back now from this decision and concentrate its efforts on taking forward alternative sites that do not have the availability and viability problems inherent in the Stratford road site.
My main objections are on the grounds of:
1) economic impact, which is ignored in the Consultation Document despite the proximity of the site to Tournament Fields, the flagship business park in the area on which the Council has placed so much emphasis in the past. Further, the Council's own Sustainability Assessment has described the economic impact as being uncertain
2) quality of soil, water and air. The Council must be very careful of being seen to treat the travelling community as second-class citizens, for whom it sets lower thresholds for the quality of their living environment. This is a particular risk for the Council when its own Sustainability Assessment highlighted this as an area with a 'potential major negative effect'. The Council has provided very little detail on how it would mitigate these impacts and indeed has neglected to highlight the issue in the consultation process (hopefully by accident rather than as a deliberate attempt to distort the consultation process). The issue of a healthy and safe environment will be so important to resolve to ensure a satisfactory quality of life, particularly considering the presence of children in the travelling community. An obvious point in this regard is the closeness of the site to the Severn Trent treatment works, which is highly relevant to the government's own guidelines on planning Gypsy and Traveller sites, which emphasise that 'sites.... should not be situated near refuse sites, industrial processes or other hazardous places'
3) the issue of access is an area which is completely not addressed by the Council's own Consultation document, as it is left open-ended. This is totally unsatisfactory given the importance to the travelling community of ensuring safe and frequent access by large vehicles to the site. My understanding is that the only access currently available is a narrow farm track (passing by a listed building) which is totally inadequate in light of the strict guidelines for access set out in the Government's own guidelines on planning Gypsy and Traveller sites. The Council seems to be adopting a position of closing their eyes and crossing their fingers that the access fairy will solve all their problems.
4) Flood Risk. This is highlighted as an area of concern in the Council's own 'Sustainability Agreement', with the site being on designated flood plain within flood zones 2 and 3. This contravenes the government's own guidelines on planning traveller sites, which states that sites should not be permitted in Zone 3 areas.
The Council has a high-level report that it could 'eradicate the threat completely' but the cost of doing so is not quantified as part of the costs of developing the sites - this includes the need to avoid any knock-on effects on the flood risks in other residential areas nearby. ie if the effect of the mitigation measures are simply to move the flooding problem to another nearby location, then the Council will be open to legal challenge from the residents who will suffer from the higher flood risk.