Testun llawn:
This letter lays out my objections to the land detailed above being allocated and used as a permanent Gypsy and Traveller site.
The first point I wish to raise relates to my complete dissatisfaction with the consultation process undertaken. There has been little or no publicity surrounding this proposal other than that generated by the resident's association and some local councillors. It is Warwick District Councils responsibility to ensure a transparent and fair process is followed. Paragraph 6a of PPTS states that local planning authorities should: "pay particular attention to early and effective community engagement with both Settled and Traveller communities'. The process undertaken has not been either early or effective. It has been an 11th hour insertion into the local plan and the process itself has been completely inadequate (for reasons I will cover below). In fact the inclusion of Stratford Road in the final short list of three preferred sites is completely against process and planning guidelines. It was not on the original list of c.20 sites and including it at the last minute highlights a lack of transparency and logic in the site selection process.
Secondly, WDC states that the reason it was included at the last minute was because Severn Trent said they could reduce the cordon sanitaire, as part of a wider employment development. The proposed location of the Gypsy and Traveller site is not in the cordon sanitaire, so that is not the reason why it has now been included - please can you explain exactly why it has been inserted as a final preferred option at the last minute despite it being considered inappropriate at the previous shortlisting stage. In addition, why was the second sustainability appraisal (SA) which was undertaken on this site revised in a number of areas which were previously negative for reasons not clear. This point is not just relating to the flooding risk which I address separately but items such as historic environment, prudent use of land and natural resources. In the document dated February 2014 'Sustainability_Appraisal_of_Gypsy_and Traveller_Site_Options'. These criteria were assessed as minor negatives (the flood risk being a major negative). In the SA produced in July 2014, the potential effects of these items were revised to positive from minor negative (for prudent use of land and resources) and neutral from minor negative (for historic environment). Flood risk had been revised to neutral from major negative. The basis of assessment and in fact the exact parcel of land assessed in the second SA is unclear. This work was undertaken in July 2014 however we were told in August 2014 that they could not identify the exact location of the proposed site, therefore I am unable to understand how the sustainability assessment can be accurate and I am unable to understand from the information provided why the revisions described above were made.
Thirdly, the information provided to the public as part of the consultation process has not been fit for purpose at best and in some cases misleading. It does not provide evidence of a compelling reason why the site is considered appropriate by WDC (never mind a preferred option).
In key areas the consultation document has provided no information that local residents could use in determining the suitability of the proposed site (for example the impact on local economy), and in other areas the WDC has alluded to further updates and reports that have not subsequently been published during the term of the 6-week consultation (for example expected guidance in relation to suitability of site access). The ecology report seemed to appear part way through the process despite it being produced prior to start of the consultation period. It was also very difficult at the start of the consultation period to find the expert reports e.g. flood risk. They were contained on an evidence base page alongside lots of other documents relating to the local plan. It was also not clear from the titles of the documents what they related to. Part way through the process, these were placed on the consultation 'home' page. The quality of some of these reports is also questionable, in particular the noise assessment report which seemed to be a 'quick and dirty' assessment to tick a box and not a thorough and robust assessment of the considerable noise issue at this site. In addition, the flood risk report does not address the specific risk to mobile accommodation posed by flooding, which is one of the key areas of concern. It is understandable that this is not addressed as this report was commissioned by Severn Trent who commissioned it for part of the land to be used as an employment site. This report therefore is not suitable for consideration in this process. In conclusion, this is a wholly inadequate way in which to run a consultation process and not acceptable in any way. All of these documents should have been easily available at the start of the process and they should be quality documents providing a thorough and robust assessment of the specific risks attached to a development of this nature.
Finally, engagement with the public has been extremely poor. I was unable to attend a drop in session however my husband attended and I was hoping that the WDC would attend the orderly and well organised public meeting on the 4th December so certain specific questions I had / have could be addressed, however it was reported that as we would voice our opinions that the council would not attend!!! This is terrible and I would like to understand why the council did not provide the residents who could not attend the drop in sessions with an opportunity to ask questions. I also understand that inaccurate information was handed out during the drop-in sessions, related to Severn Trent Water's role in the Gypsy and Traveller site. Not everyone who attended those sessions will be aware that they have received incorrect information, therefore this process has been further confused and in fact the consultation should be considered to have not provided the consultees with the ability to fully understand the proposal and the reasons this site has been selected over other sites.
Reasons for objection to the site:
Suitability of site as a place to live
The site in question is unsuitable for people to live (regardless of who the people are) and I believe that if WDC elects to place Gypsies/Travellers there, it is a poor reflection on Warwick. The point of providing permanent sites is to improve the quality of life for these communities. This should not be considered as just an improvement, it should be considered in terms of equal to settled communities. I think it is morally wrong to offer these communities the option of living next to a sewage works and a motorway, which they may accept as an improvement on their current situation but does not give them the quality of life the planned sites should be giving.
The site is unsuitable for many reasons:
* It is on a Flood Zone (2 and 3). Government guidance says you shouldn't locate Gypsy/Traveller sites on flood zones. The report you have released in relation to this suggests extensive work is required to mitigate the flood risk, but that further work is required to assess the extent of the risk and investigate whether the mitigations are actually possible. You should not select the site as a preferred option for the Local Plan until all necessary investigations have taken place and the risk, the feasibility of required mitigations and the cost thereof are all fully understood. As discussed above the report was also commissioned by Severn Trent in relation to the potential employment site and not the Gypsy and Traveller site (they have confirmed they are objecting against the location also). The government guidelines highlight the specific vulnerability of the Gypsy and Traveller sites to flooding so any report should be specifically addressing this issue. We have been informed the two sites and decisions are mutually exclusive; therefore I do not understand why a report relating to an employment site has been submitted as evidence for the Gypsy and Traveller site.
* It is next to a sewage works. Again, government guidance states Gypsy/Traveller sites shouldn't be located next to industrial/sewage sites.
* It is extremely close to the M40. The emissions from traffic would make the air quality very poor you would be putting the health of Gypsy/Traveller families at risk.
* The noise from the M40 is relentless and significant. In chase meadow, the noise can be heard at all times of day/night. Given I imagine caravans/mobile homes are less sound proofed, this is not a pleasant or healthy environment for families. I refer you back to my comments on the quality of the report produced also, which is not acceptable at this stage in the process.
* The location is unsafe on all sides, which again is not an acceptable solution and will not improve the quality of life to the standard to which it should be raised.
Severn Trent and David Webb, the two owners of the land apart from WDC, both state they are against their land being used for a Gypsy and Traveller site, therefore a compulsory purchase order would be required. This would be an expensive, bureaucratic and time consuming process which would stall the Local Plan and waste taxpayers' money.