We are emailing in response to the New Local Plan and the Revised Development Strategy.

We have read with interest the Local Plan on your website. We are aware of a potential site on Warwick Gates for development but find the plan vague with regards to Traveller sites in particular.

As residents living on Warwick Gates we are concerned about any further developments without extra infrastructure being provided.

There is no local school provision on Warwick Gates which has caused difficulties with gaining a place at a good local Primary school. We personally travel to Barford as with some other parents, to obtain a good standard of education for our children.

Other families we know are spread across schools in Harbury, Coten End, Woodloes etc. We are aware there are spaces at Whitnash Primary but there are lots of parents which would be unhappy to put their child in a school which recently has been in special measures. Briar Hill Primary School and St Margaret's our nearest school already oversubscribed.

The nearest catchment school for Secondary education (Myton) is also over subscribed which also puts additional pressure on the infrastructure.

It is unusual for us to take such a strong view and I am very liberal minded but we are especially against an local Traveller accommodation which as we specified above would put an impossible burden on our community and schools.

The recent difficulties which residents have had when Traveller sites have appeared on the edge of Warwick Gates has given us a direct insight to the problems which it can cause.

We know that it is a difficult decision on where to put these sites but next to an estate which is already under strain from adequate schools provision and which has first hand experience of living next to Travellers is not the place to consider this.

This site is located on the banks of the Tachbrook which could result in water contamination.

A narrow site which would need direct access off Europa Way, in open countryside. It would be unsuitable as a gypsy site and should be removed from the list of potential locations.

Site GT15 is unsuitable and unsustainable as a Gypsy & Traveller Site.

The site does not have convenient access to a GP surgery, school and public transport.

Other suggested sites are more suitable and more sustainable - Sites 1, 11 18 and 17. These sites are more accessible to the major urban areas and accordingly more sustainable.

* Why did you decide not to disperse the houses over the whole of the district? The concentrated location of large pitches in few areas south of Warwick, Leamington and Whitnash lacks social cohesion which leads to anti social behaviour and poor education performance. This majority of sites are south of the rivers and are around Warwick Gates and Chase Meadow; what kind of community is likely to be born as a result of these new pitches, especially as these are in areas with poor transport links to the areas that give the most support to the under privileged i.e. the town centres.

* We think that such a number of new sites contradicts the vision that Warwick District Council has, "providing a mix of historic towns and villages set within a rural landscape of open farmland and parklands".

* Utilities, Services (Police, Dentists, and Doctors etc.) are all stretched to the limit now. With both the major hospitals only accessible across congested bridges over the river Avon, we fear for how long it will take emergency cases to get the medical resources they need and this additional traffic will add to the congestion.

* The proposed site will be detrimental to the Health care provision for the G&T community through their remoteness from suitable capacity and suitable provision of service. It is recognised that this community will need good access to Primary, General and Specialist healthcare.

* The increase in traffic and noise arising additional, often heavy vehicles in this area will result in further pollution and add to existing air quality problems in Warwick and Leamington town centres. At peak times the traffic along Europa Way (even as far as the J14 M40), Gallows Hill, Tachbrook Road and Tachbrook Park Drive are already grid locked, your proposed development will simply be adding to the congestion already experienced. So far you have failed to fix the current problems and there is no evidence on your part to suggest that you will, even for when this proposed development is complete.

* We see no sense in carpeting our green spaces with housing for a mobile population to travel elsewhere. Our remaining agricultural land should be preserved to feed future generations. The UK currently imports around 40% of its food - an untenable situation as identified by DEFRA's Food Chain Analysis Group in December 2006. To carry-out non-sustainable development and changing agricultural usage green field land to built environment seems irresponsible and foolhardy at a time when Climate Change, Food Security, Energy Security and the Global Economy are all at large and likely to be so for some considerable time.


* There are simply not enough schools in the area to cope with these sites; Whitnash and Bishop's Tachbrook Primary Schools and Myton Secondary School are already heavily oversubscribed. New and existing schools are controlled by Warwickshire County Council; therefore the District Council is unable to guarantee that the large number of school age children who will live in the proposed sites will be able to find a local school to attend. Therefore, the capacity of the Schools in the area to provide secure and stable education to families moving into/out of the proposed Gypsy and Traveller site will compromise the G&T families' capability to provide a secure education to their children. The local authority have a legal duty to educate children as do their parents.
* Is it practical to expect local schools to be able to take on children as and when required? Do they have the space? Do they have the funding for these children? Due to the itinerant nature of these families' lifestyles, the children will often have difficulty keeping up or catching up with other pupils and will need the provision of extra resources like special needs teachers.

* Parents may have to travel miles in order to take their children to and from school. Alternatively, children may be required to walk long distances to and from school, which is likely to lead to an increase in truancy. This time spent travelling to and from school could be better spent actually focusing on their studies or enjoying recreational activities.

* It is very likely that many gypsy and traveller parents will have to travel to school by car. Travellers will also have to travel by car in order to reach their places of work. This will create even more morning and afternoon congestion on roads that are already extremely busy during these times. At peak times, the traffic along Europa Way (even as far as J14 of the M40), Gallows Hill, Tachbrook Road and Tachbrook Park drive, are grid locked. Your proposed developments will directly impact these roads.

* Public Transport - There is very limited public transport available in this area. The proposed site would mean residents of the G&T settlement would in reality have no alternative but to use private vehicles to travel to/from the site. The limited availability comprises only a very limited bus service, therefore if a Gypsy and Traveller site were to be established on this site it would result in an increase in the use of cars and other vehicles in the local area. This opposes a number of Warwick District Council's policies. This should be avoided both for the safety of the drivers, and the safety of children at the site.
* The huge increase in traffic in the area will result in an incredible increase in pollution and contribute to the existing air quality problems in Warwick and Leamington. The Highways Transport Development Control has estimated the potential increase in traffic to be in the order of 9 to 11 movements per pitch. Resulting in an additional 45 to 55 movements (2 way) per day on our busy local roads.
* It is interesting that the council choose to use the word "pitch" when we are considering an application for 5 "units". I do not feel it is safe to assume that an estimate made on the basis of a "pitch" equates to the same basis for a "unit"
* Even if the two terms did equate, we have to take into account that the planning application is only an illustration, and not a restriction on the use of the land. It would be quite feasible to park another 2 caravans on each "unit", thereby doubling the potential amount of traffic. This would result in 90 to 110 movements (2 way) per day.
* In order for people living in the area to travel into the town centre, it is necessary to cross the River Leam. There are currently only 3 bridges that make this possible, and these bridges can already become highly congested. Residents who move into the proposed sites will also have to travel this way in order to reach the facilities in Leamington town centre. The District Council has no control over plans for new roads or bridges and, therefore, is unable to rectify the problems they will be creating.

* Such a large number of proposed new sites in the area contradicts the very vision that Warwick District Council claims to have:

"A mix of historic towns and villages set within a rural landscape of open farmland and parklands, that have been developed a grown in a way which has protected their individual characteristics, and identities, contributed towards creating high quality safe environments with low levels of waste and pollution..." (The Preferred Vision for Warwick District to 2026: Point 1, Core Strategy document, June 2009).

* Of particular concern is the Southern area of Warwick, Leamington Spa and Whitnash as the Warwick Gates development of around 1,600 homes has already placed serious pressure on the roads and schools in this area and further development will seriously exacerbate the problem.
* Road Safety/Road Access - Road access to the site is via an extremely busy "A Road", where there have been a number of accidents over the years.

* If it becomes another suburb of Leamington Spa this will reduce the quality of life for the community here in Warwick Gates, Whitnash and in Bishops Tachbrook. The proposed site and associated facilities would not be suitable nor meet the needs of the gypsy and travelling community, nor the existing communities of Warwick Gates, Whitnash and Bishop's Tachbrook. I believe that this site is completely unsuitable for members of the gypsy and travelling communities and would severely compromise peaceful and integrated co-existence between the site and the local community.

* Employment - Employment opportunities within this area extremely limited with the demise of AP, Fords, IBM and other firms there is not the work available for incomers. Many people already leave the area to work elsewhere. A large proportion of people living on Warwick Gates commute up and down the M40 or by rail as far away as London. The proposed site would be therefore provide little opportunity for the G&T community to pursue careers and obtain employment.

* Foul Sewer: There is currently no provision on or near the site for the disposal of foul sewage into an adopted foul and surface water sewer system. Septic tanks only collect the solids, they are designed so that in principal, the foul water is allowed to overflow, run off slowly and be filtered as it passes through the ground. Septic tanks need emptying. An average septic tank is normally adequate for a family, and requires emptying once a year. This cost is normally paid for by the resident. It has not been made clear how the costs on the proposed site would be managed. In fact it is not clear if there is anyone responsible for emptying the tank. Failure to empty the tank would result in worse pollution than caused by the foul water run-off. We'd have to add solid sewage run-off to the problem. The provisions identified are considered inadequate and present an environmental threat to the area.

* Locating the site so near to residential areas would have a seriously detrimental impact on house prices. The increased risk of crime rates would also result in an increase in house insurance premiums.

* Flooding - The proposed site has a history of flooding. The proposed Gypsy and Traveller site will therefore compromise the G&T families' capability to provide a safe and pleasant living environment/habitat. I believe that the Task Force believe that the flooding issues can be simply resolved through use of Sustainable Drainage Systems; the cost of implementing SDS on this type of site is significant and not appropriate when public expenditure must be curtailed in response to the global recession/economic climate. This could potentially lead to unjustified and ill-directed resentment from the local community towards the residents of the "planning approved" site on the basis of funding/spend by the local authority when other more pressing needs in the area are currently facing severe budget cuts.

* I understand that the Gypsy community have stated that they wish to have sites located on the outskirts of towns, near schools, close to major roads and near to medical facilities. Therefore it is clear for the reasons outlined above that this G&T community needs. It would appear that there are other locations which are much more suitable.

* While there are grants to councils towards the provision of Gypsy and Traveller sites, these are nowhere near enough to cover the costs. Most of this will have to be borne by local council tax payers.
* There are many people who use the local roads for walking, jogging, cycling, and horse riding. With the expected increase in traffic, as mentioned above, and the potential for an increased number of animals (e.g. dogs), these road users will be put at increased risk.
* This is an agricultural area. Since the local land is water-logged, movement of farm machinery often leaves the roads muddy. What would be considered normal traffic on a clean main road would be considered unsafe on our muddy roads, and the danger to road users will be compounded by movement of G&T site traffic.

* Why did you decide not to disperse the houses over the whole of the district? The concentrated location of large pitches in few areas south of Warwick, Leamington and Whitnash lacks social cohesion which leads to anti social behaviour and poor education performance. This majority of sites are south of the rivers and are around Warwick Gates and Chase Meadow; what kind of community is likely to be born as a result of these new pitches, especially as these are in areas with poor transport links to the areas that give the most support to the under privileged i.e. the town centres.

* We think that such a number of new sites contradicts the vision that Warwick District Council has, "providing a mix of historic towns and villages set within a rural landscape of open farmland and parklands".

* Utilities, Services (Police, Dentists, and Doctors etc.) are all stretched to the limit now. With both the major hospitals only accessible across congested bridges over the river Avon, we fear for how long it will take emergency cases to get the medical resources they need and this additional traffic will add to the congestion.

* The proposed site will be detrimental to the Health care provision for the G&T community through their remoteness from suitable capacity and suitable provision of service. It is recognised that this community will need good access to Primary, General and Specialist healthcare.

* The increase in traffic and noise arising additional, often heavy vehicles in this area will result in further pollution and add to existing air quality problems in Warwick and Leamington town centres. At peak times the traffic along Europa Way (even as far as the J14 M40), Gallows Hill, Tachbrook Road and Tachbrook Park Drive are already grid locked, your proposed development will simply be adding to the congestion already experienced. So far you have failed to fix the current problems and there is no evidence on your part to suggest that you will, even for when this proposed development is complete.

* We see no sense in carpeting our green spaces with housing for a mobile population to travel elsewhere. Our remaining agricultural land should be preserved to feed future generations. The UK currently imports around 40% of its food - an untenable situation as identified by DEFRA's Food Chain Analysis Group in December 2006. To carry-out non-sustainable development and changing agricultural usage green field land to built environment seems irresponsible and foolhardy at a time when Climate Change, Food Security, Energy Security and the Global Economy are all at large and likely to be so for some considerable time.


* There are simply not enough schools in the area to cope with these sites; Whitnash and Bishop's Tachbrook Primary Schools and Myton Secondary School are already heavily oversubscribed. New and existing schools are controlled by Warwickshire County Council; therefore the District Council is unable to guarantee that the large number of school age children who will live in the proposed sites will be able to find a local school to attend. Therefore, the capacity of the Schools in the area to provide secure and stable education to families moving into/out of the proposed Gypsy and Traveller site will compromise the G&T families' capability to provide a secure education to their children. The local authority have a legal duty to educate children as do their parents.
* Is it practical to expect local schools to be able to take on children as and when required? Do they have the space? Do they have the funding for these children? Due to the itinerant nature of these families' lifestyles, the children will often have difficulty keeping up or catching up with other pupils and will need the provision of extra resources like special needs teachers.

* Parents may have to travel miles in order to take their children to and from school. Alternatively, children may be required to walk long distances to and from school, which is likely to lead to an increase in truancy. This time spent travelling to and from school could be better spent actually focusing on their studies or enjoying recreational activities.

* It is very likely that many gypsy and traveller parents will have to travel to school by car. Travellers will also have to travel by car in order to reach their places of work. This will create even more morning and afternoon congestion on roads that are already extremely busy during these times. At peak times, the traffic along Europa Way (even as far as J14 of the M40), Gallows Hill, Tachbrook Road and Tachbrook Park drive, are grid locked. Your proposed developments will directly impact these roads.

* Public Transport - There is very limited public transport available in this area. The proposed site would mean residents of the G&T settlement would in reality have no alternative but to use private vehicles to travel to/from the site. The limited availability comprises only a very limited bus service, therefore if a Gypsy and Traveller site were to be established on this site it would result in an increase in the use of cars and other vehicles in the local area. This opposes a number of Warwick District Council's policies. This should be avoided both for the safety of the drivers, and the safety of children at the site.
* The huge increase in traffic in the area will result in an incredible increase in pollution and contribute to the existing air quality problems in Warwick and Leamington. The Highways Transport Development Control has estimated the potential increase in traffic to be in the order of 9 to 11 movements per pitch. Resulting in an additional 45 to 55 movements (2 way) per day on our busy local roads.
* It is interesting that the council choose to use the word "pitch" when we are considering an application for 5 "units". I do not feel it is safe to assume that an estimate made on the basis of a "pitch" equates to the same basis for a "unit"
* Even if the two terms did equate, we have to take into account that the planning application is only an illustration, and not a restriction on the use of the land. It would be quite feasible to park another 2 caravans on each "unit", thereby doubling the potential amount of traffic. This would result in 90 to 110 movements (2 way) per day.
* In order for people living in the area to travel into the town centre, it is necessary to cross the River Leam. There are currently only 3 bridges that make this possible, and these bridges can already become highly congested. Residents who move into the proposed sites will also have to travel this way in order to reach the facilities in Leamington town centre. The District Council has no control over plans for new roads or bridges and, therefore, is unable to rectify the problems they will be creating.

* Such a large number of proposed new sites in the area contradicts the very vision that Warwick District Council claims to have:

"A mix of historic towns and villages set within a rural landscape of open farmland and parklands, that have been developed a grown in a way which has protected their individual characteristics, and identities, contributed towards creating high quality safe environments with low levels of waste and pollution..." (The Preferred Vision for Warwick District to 2026: Point 1, Core Strategy document, June 2009).

* Of particular concern is the Southern area of Warwick, Leamington Spa and Whitnash as the Warwick Gates development of around 1,600 homes has already placed serious pressure on the roads and schools in this area and further development will seriously exacerbate the problem.
* Road Safety/Road Access - Road access to the site is via an extremely busy "A Road", where there have been a number of accidents over the years.

* If it becomes another suburb of Leamington Spa this will reduce the quality of life for the community here in Warwick Gates, Whitnash and in Bishops Tachbrook. The proposed site and associated facilities would not be suitable nor meet the needs of the gypsy and travelling community, nor the existing communities of Warwick Gates, Whitnash and Bishop's Tachbrook. I believe that this site is completely unsuitable for members of the gypsy and travelling communities and would severely compromise peaceful and integrated co-existence between the site and the local community.

* Employment - Employment opportunities within this area extremely limited with the demise of AP, Fords, IBM and other firms there is not the work available for incomers. Many people already leave the area to work elsewhere. A large proportion of people living on Warwick Gates commute up and down the M40 or by rail as far away as London. The proposed site would be therefore provide little opportunity for the G&T community to pursue careers and obtain employment.

* Foul Sewer: There is currently no provision on or near the site for the disposal of foul sewage into an adopted foul and surface water sewer system. Septic tanks only collect the solids, they are designed so that in principal, the foul water is allowed to overflow, run off slowly and be filtered as it passes through the ground. Septic tanks need emptying. An average septic tank is normally adequate for a family, and requires emptying once a year. This cost is normally paid for by the resident. It has not been made clear how the costs on the proposed site would be managed. In fact it is not clear if there is anyone responsible for emptying the tank. Failure to empty the tank would result in worse pollution than caused by the foul water run-off. We'd have to add solid sewage run-off to the problem. The provisions identified are considered inadequate and present an environmental threat to the area.

* Locating the site so near to residential areas would have a seriously detrimental impact on house prices. The increased risk of crime rates would also result in an increase in house insurance premiums.

* Flooding - The proposed site has a history of flooding. The proposed Gypsy and Traveller site will therefore compromise the G&T families' capability to provide a safe and pleasant living environment/habitat. I believe that the Task Force believe that the flooding issues can be simply resolved through use of Sustainable Drainage Systems; the cost of implementing SDS on this type of site is significant and not appropriate when public expenditure must be curtailed in response to the global recession/economic climate. This could potentially lead to unjustified and ill-directed resentment from the local community towards the residents of the "planning approved" site on the basis of funding/spend by the local authority when other more pressing needs in the area are currently facing severe budget cuts.

* I understand that the Gypsy community have stated that they wish to have sites located on the outskirts of towns, near schools, close to major roads and near to medical facilities. Therefore it is clear for the reasons outlined above that this G&T community needs. It would appear that there are other locations which are much more suitable.

* While there are grants to councils towards the provision of Gypsy and Traveller sites, these are nowhere near enough to cover the costs. Most of this will have to be borne by local council tax payers.
* There are many people who use the local roads for walking, jogging, cycling, and horse riding. With the expected increase in traffic, as mentioned above, and the potential for an increased number of animals (e.g. dogs), these road users will be put at increased risk.
* This is an agricultural area. Since the local land is water-logged, movement of farm machinery often leaves the roads muddy. What would be considered normal traffic on a clean main road would be considered unsafe on our muddy roads, and the danger to road users will be compounded by movement of G&T site traffic.

The site is located on the banks of the Tachbrook - could be a chance of contamination given that proposed site may be used as a place of work

Located near to banks of the Tachbrook.If proposed GT site used as place of work, risk of contamination.

This site is located on the banks of the Tachbrook and this could lead to a potential for contamination given that the proposed Gt site may be used as a place of work
The site will have access onto a very busy main road.
Does not meet the requirement as laid out in the consultation document.

Not a suitable area for the provision.
it is unsuitable due to the traffic.

It would be great to be able to offer sessional youth work support to the young people on the sites. The Warwickshire Association of Youth Clubs would be interested in offering such support if funded by say the Community Levy

Alongside the noisy A452
No safe access onto the site
No utilities
No GP surgery
No school
No public transport
No integration with local community
Could not be integrated into the landscape successfully

I find it difficult to understand why a number of these sites especially GT06 / GT09 / GT015 all are sited close to the outskirts of Warwick Gates, with the consultation already going on with the local Plan, it seems to be that our community are taking the brunt of many local council initiatives. We have only recently moved to the area and am disappointed with the view that we have to blur the lines of the green belt and country side that surrounds these area's. I cannot understand based on the councils criteria that these sites meets those basic fundamental principles. I am especially upset that Warwick Gates seems to be focused around a lot of the changes and i hope the council rethinks the impact they will place on our community.

Continued overdevelopment of South Leamingtopn and a infrastructurte that cannot cope and will only get worse.

I wish to register our objections to the proposed traveller sites in South Warwickshire

I appreciate the wide variety of sites to be considered. I understand that no body wants the sites near them, although they come locally to most people anyway. I feel the sites that are furthest from established homes are the best. From my perspective, GT15 is an absolutely terrible option. The ones on Harbury Lane, whilst one would prefer they were not to be there, would be more palatable in this location. Ideally, GT01 is the option I would vote for if I had a choice.

see attached

I wish to register my objection to the traveller sites across South Warwickshire as I believe that the local community will be seriously impacted due to the excess cars, caravans etc

Sites for Gypsies and Travellers Consultation Document
29th July 2013
1. Meeting the Need for Sites for the Gypsy and Traveller Community
a) The Parish Council understands both the issues facing the Gypsy and
Traveller community as set out in Section 4 of the consultation
document and the District's legal obligation to provide for that need.
b) In order to meet those needs it is very important that the final sites
selected fully address the Issues and completely meet the site
requirements as set out in Section 7.
c) In summary with the level of information provided, the sites proposed
fall far short of meeting the site requirements and will therefore fail to
address the underlying issues to the extent required. Therefore the
Parish Council cannot support any of the sites within its boundary.
Namely GT03, GT05, GT06, GT09, GT10, and GT15.
d) Please refer to the attached report commissioned by the Parish Council
from its consultants LinkUK ref DM1292, dated 29th July which sets out
the areas of concern in more detail.
2. Comments on Consultation
a) It is a concern to the Parish Council that the Gypsy and Traveller Site
Document not listed as a "consultation document" on the WDC website.
It is listed in the supporting documentation list. It is also noted that it is
listed at the bottom of the New Local Plan page as "Other
consultations" but is not given equal billing with the RDS. Many
residents have said that they were not aware of the proposals or
consultation and this may be a factor.
b) The Parish Council is very concerned at the Gypsy and Traveller site
consultation document is misleading, as most of the photos are taken
at touring caravan sites and do not accurately portray typical visual
impact of a permanent traveller site. There are no photos depicting
mobile homes, commercial vehicles and plant which are all very typical
of this type of development. It is very important that consultation
documents represent the proposals accurately. Thought must be given
to how this rectified to give residents a realistic picture of what these
developments can look like so that consultees can make a realistic
assessment of visual impact.
c) The Parish Council is concerned that the consultation process is so
brief in comparison to the new local plan. Consequently, apart from
setting out the background and site selection requirements little has
been done so far to help residents understand what to potential
impacts on a local settled community are and how sites would
allocated and be taken up.
i) Are there specific Gypsy and Traveller Groups that have been
identified and are on a waiting list for sites?
ii) Wouldn't it be useful for community representatives to be given the
opportunity to meet representatives of these groups and the WDC
liaison officer?
1. The Salford University Study, commissioned by Warwick District
Council states in its Final Report Gypsy Traveller and Travelling
Showpeople Accommodation Needs Assessment (GTTSANA
Nov.2012) dated November 2012, states:
Policy A of 'Planning Policy for Traveller Sites' states that in
assembling the evidence base necessary to support their
planning approach, local planning authorities should: pay
particular attention to early and effective community
engagement with both settled and traveller communities
(including discussing travellers' accommodation needs with
travellers themselves, their representative bodies and local
support groups)
The event organised earlier this year by WDC was a tentative
start, but it was not held against the backdrop of specific sites.
2. It is therefore seen as a major negative that 8 months after the
publication there has been no engagement with the local
community on the specifics of the consultation.
d) Residents have expressed concerns to the Parish Council, fuelled by
the media including a recent TV documentary. The WDC consultation
has not assisted in reassuring residents about these concerns.
e) The consultation to date has focused entirely on planning issues of the
government requirements and site selection. There has been no focus
on the people issues outlined above. The Parish Council believes that
WDC should be going to far greater lengths during this consultation
process to help residents understand the reality of living close to a
Gypsy or Traveller Site. In doing this WDC may help to alleviate some
of the concerns expressed by residents.
3. Proposed Operating Model for Gypsy and Traveller Sites
a) No assurances are given about how sites would be managed day to
day. Each pitch is very large. Whilst a 5 pitch site would be allocated to
house 5 families, there appear to be no controls to prevent the
numbers on the site swelling to many times this number. It has been
said that planning enforcement can deal with this. However there could
be a continuous stream of visiting families pitching up on the plots that
are sized to take touring caravans and other vehicles along with a
permanent mobile home. Planning enforcement processes would not
necessarily be triggered and if they were, can take years to take effect.
b) There are also concerns that if the sites are managed entirely by
market forces, requirement to meet the provision of a permanent site
for all Gypsy families may not be met, due to the high level of rents that
may be charged. The Districts own study GTTSANA Nov.2012 points
to this.
7.14......One respondent in the survey commented on the general
issue of affordability, but also the lack of sites in the area: "I have
two sons and when they get married there are no sites round here.
Some of the travelling men who own sites want to charge too much
rent, that's why we're in a house. We need more council sites".
c) The districts proposed operating model of self management by a
Gypsy landlord is very weak in this regard and presents a high risk to
the successful long term management of a site and the WDC
objectives being met.
d) The Parish Council therefore objects strongly to the District preferred
self management operating model, and would require WDC to manage
to site(s) day to day, or to devolved the operation to a housing
associated or RSL, to ensure that rents are affordable and occupation
levels are maintained the consented levels.
4. Independent Assessment - Initial Feedback
a) The Parish Council has commissioned specialist consultants LinkUK to
undertake and independent assessment of the sites within the
boundary of Bishops Tachbrook Parish. The report is appended. The
Parish Council wishes to adopted all recommendations which can be
summarised as follows:
i) At this early stage there is insufficient evidence to make a valid
judgement on the suitability of the sites identified within the parish
boundary.
ii) Sites should be assessed and rated in accordance with the Issues
identified as affecting the Gypsy and Traveller Community and with
enhanced weighting given to the most concerning issues, access to
health and education
iii) Therefore is not possible to give further consideration to these sites
until the further studies and evidence highlighted has been made
available
b) The initial assessment by Link UK will be supplemented with a
Planning Consultant opinion. The Parish Council will be in receipt of
that report towards the end of August and will forward as a
supplementary submission.
5. Specific Concerns Identified So Far.
a) Impact on Infrastructure and Services
i) It is not set out in the proposals where children, living on any of the
proposed sites in the future, would go to school.
(1) Bishops Tachbrook Primary School is a single form entry school.
The Parish Council is extremely concerned the that special
education needs of the Gypsy and Traveller community, as set
out in Section 4 of the consultation document cannot be properly
met at a small school. Therefore one of the most critical
objectives in the provision of a place for permanent residence
will not be met.
(2) Because the significant additional support required will not be
funded by the County, (except for the minimal budget
supplement provided to those receiving free school meals,
which there is no guarantee will apply in this case) there is also
the potential for a drop in the educational standards across the
school.
(3) It is considered a basic right of all families with young children to
be able to walk safely to and from school. All of the sites
proposed within Bishops Tachbrook Parish do not meet this
requirement. If the ability to walk to school is not met by the
selected site(s) this will result in further road congestion around
the school. The proposals do not set out how this would be
mitigated.
(4) The Bishops Tachbrook Primary School, whose catchment is
the parish boundary, is over subscribed every year, with the
result that children already on catchment have to be turned
away. It is a concern that the further demand created for
insufficient school places will lead to tension between the settled
community and the Gypsy and Traveller community.
6. Further initial evidence on site suitability will be submitted to Warwick
District Council as supporting information following receipt from Bishop's
Tachbrook's planning consultant in late August 2013.
Appendix
Link UK Initial Assessment 29th July 2013
INTERIM REPORT BY
LINK SUPPORT SERVICES (UK) LTD
ON BEHALF OF
BISHOP'S TACHBROOK PARISH COUNCIL RELATING TO THE
INCLUSION OF SITES WITHIN THE PARISH BOUNDARIES AT REVISED
DEVELOPMENT PLAN CONSULTATION STAGE OF THE WARWICK
DISTRICT COUNCIL GYPSY AND TRAVELLER LOCAL PLAN.
SITES CONSIDERED IN THIS REPORT INCLUDE:
GT 03 Land at Barnwell Farm, Harbury Lane - 15 potential pitches
GT 05 Land at Tachbrook Hill Farm Banbury Rd - 15 potential pitches
GT 06 Land at Park Farm Spinney Farm - 15 potential pitches
GT 09 Land to the North East of the M40 AND South of Oakley Wood Rd
- 15 potential pitches
GT 10 Land adjacent to Tollgate House and the Guide Dogs National
Breeding Centre - 8 potential pitches
GT15 Land to East of Europa Way - 4 potential pitches
AUTHOR: DAVID McGRATH BA (HONS)
MANAGING DIRECTOR
LINK SUPPORT SERVICES (UK) LTD
29TH July 2013
Our Ref: DM1292
1. INTRODUCTION
1.1 Link Support Services (UK) Ltd (Link) has been instructed by Bishop's
Tachbrook Parish Council to carry out an interim assessment of the
Link Support Services (UK)
Ltd
Innellan House
Eaves Green Lane
Meriden
Warwickshire
CV7 7JL
01676 522775
07802 640159
Linkukltd@aol.com
appropriateness of six potential Gypsy/ Traveller sites within the Parish
Boundaries
1.2 Link is a VAT registered company, formed in 1994 and is led by the Managing
Director Mr David McGrath. Link provides a range of services to Local
Authorities and community groups in the UK. Services include: training for
elected members and senior officers (Planning, scrutiny and community
engagement) and specialist services relating to the evaluation of proposed
developments - often but not exclusively - related to the development of
traveller sites and strategies thereto. Our associate network includes a range
of legal and planning and other experts who have represented travellers,
organisations and community groups in their search for lawful, plan led
accommodations solutions whilst protecting the environment from
inappropriate development
1.3 The context for this report is that Warwick District (WDC) has published a
report in November 2012 which shows a need for 31 permanent pitches to be
provided over the life of the Local Plan (15 years), 25 within the first five years
and 6-8 further transit pitches over the Plan period. 'Areas of search' have
been selected by officers within which it is believed that there could be
potential for a Gypsy and Traveller site, outside the Green Belt, close to the
road network and within easy reach of local facilities (schools and doctors etc.).
The result of the council's research is published to allow for public consultation
and comment. Warwick District Council is now consulting widely on their
revised development strategy which includes potential site options for new
Gypsy and Traveller sites.
1.4 With regards to travelling show people, the recent GTAA has shown that
provision already exists in the district (meeting current and future needs) so no
new pitches are required within the life of the Local Plan
1.5 The full list of sites was produced by a 'call for sites' exercise. Six potential
permanent Gypsy and Traveller sites have been identified within the Parish
Council boundaries which are the subject of this report
1.6 This Report is produced on an interim basis to comply with the consultation
timescales and will constitute the substantive interim response by the Parish
Council. It has been produced through detailed discussions with Parish
Council members, a Registered Town and Country Planner (who specialises
in Gypsy and Traveller Planning matters) and is also based on available
research data. The final report of the Parish Council relating to this stage of
consultation will however be produced following a visits to all sites by our
Planning Consultant (on his return from annual leave) and we therefore
reserve the right to amend comments contained within the report in light of the
site visits and further scrutiny of the issues herein
1.7 A particularly relevant document that we will refer to in this report is the
Warwick District Council Local Plan Final Interim Sustainability Assessment
(SA) Report (June 2013) hereinafter referred to as WDCLPSA. This was
produced by Enfusion - environmental planning, management and
sustainability consultants acting for WDC
2. EXECUTIVE SUMMARY
2.1 Following our interim assessment we would recommend that the Parish
objects to all of the proposed traveller site options listed above
2.2 We have looked at each site individually and we are able to conclude that at
each proposed location there are significant and problematic site specific
issues which casts major doubt as to the viability of each site (e.g. flood risk,
poor access to transport and or services, noise et al). Without further
information from WDC as to levels of new or proposed infrastructure
investment and/ or quantification of site related risks along with mitigation
measures, the sites cannot currently be considered as viable. We also
recommend that key partners (e.g. English Heritage) should be involved in this
stage of the consultation process as a further key test of the viability of the
proposal. It is known, for example, that some of the sites affect the setting of
Listed Buildings, Parkland and a Scheduled Monument
2.3 There is also a large amount of 'unknowns' about many of the potential sites
(e.g. their ecological and archeolological value) and also whether it is indeed
possible for any site design to overcome the harm to the openness and
character of the rural and historic environment. Without this information a
precautionary principal is urged and the sites should be opposed
2.4 There is also no information as to the potential cumulative effects of locating a
number of sites close together (i.e. GT05, 06, 09 and GT15). This could
include the impact of new sites on the environment or services and the new
challenges that would be faced by the settled and travelling communities in
attempting to access these services
2.5 It is not possible, in our view, to come to any other reasonable conclusions
3. METHODOLOGY
3.1 Link Support Services has (a) discussed the sites with the Chairman of the
Parish Councillor and a representative of a residents group (b) reviewed
Council documentation produced relating to these sites and (c) reviewed
documentation produced by other organisations relating to these sites. To
produce the final version of interim report we will also (d) carry out a walking
and photographic survey of the six proposed sites and (e) produce a final
report which advises the Parish Council as to the potential for any of the
potential locations identified above to become a sustainable Gypsy and
Traveller site. The final report will supersede this report
3.2 There follows a summary of the key points relating to each site and our interim
recommendations. This document is not meant to be exhaustive and Link
reserves the right to add or amend information relating to future submissions,
challenges and appeals made on behalf of the Parish Council
3.3 Our starting point for the assessment of each site relates to selection criteria
published by Warwick District Council and the Preferred Options of the Local
Plan suggested the following draft policy which contains the criteria by which
sites would be assessed for suitability:
* Convenient access to a GP surgery, school, and public transport
* Avoiding areas with a high risk of flooding
* Safe access to the road network and provision for parking, turning and
servicing on site
* Avoiding areas where there is the potential for noise and other
disturbance
* Provision of utilities (running water, toilet facilities, waste disposal, etc)
* Avoiding areas where there could be adverse impact on important
features of the natural and historic environment; and
* Sites which can be integrated into the landscape without harming the
character of the area.
In addition
To fully accord with the provisions of 'Planning Policy for Traveller Sites',
additional criteria need to be incorporated so that the policy:
* promotes peaceful and integrated co-existence between the site and the
local community
* avoids placing undue pressure on local infrastructure and services
* 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.
3.4 Link Support Services would also contend that two factors in particular could be
given additional weight (positively or negatively) in the consideration of the
location of a potential traveller site. Many Councils (correctly in our view) place
greater emphasis on the need to locate sites which can access and address
serious health and educational inequalities often experienced in the travelling
communities. This translates as enhanced weighting for these factors. The
assessment and scoring system used - for example by Central Bedfordshire
Council - to identify sites has been revised to allow the presence of educational
facilities to attract additional weight. A similar case could be made for health
facilities
3.5 There follows a site by site interim evaluation of the potential sites as identified
above
4. SITE BY SITE INTERIM ANALYSIS. SITE GT 03
LAND AT BARNWELL FARM HARBURY LANE - 15 POTENTIAL
PITCHES - CLOSE TO B4455 (FOSSE WAY)
4.1 Overall conclusion
A fifteen pitch traveller site development is a relatively large proposition
and any potential developer should seek to ensure that optimal
conditions exist for such a development. In short this is NOT an ideal
traveller site location and it is recommended that this should be
OPPOSED by the Parish Council on the grounds shown in our overall
interim concluding comments for this section
Our comments relating to the site based on WDC's own assessment
criteria follow:
4.2 Convenient access to a GP surgery, school, and public transport
Although the site has good access to public transport leading into the
nearest town (having a bus stop adjacent to the site). Local services
are however approximately 4.8 kilometers away. It can be argued
therefore that the site affords little opportunity for walking (there are no
well defined footpaths to local schools for example) or cycling to local
services. It is therefore possible that the distance of the site to key
facilities and employment will promote car (and other vehicle)
dependence. A 15 pitch site could generate in the region of 100 plus
trips per day (business, personal, school) with some opportunity to
offset this through use of local bus services (in the event that the
services are available)
We note that
(a) The nearest Doctors surgery is in Harbury (4km)
(b) The nearest primary school is Harbury C of E Primary School (4km)
(c) The nearest secondary school is Campion (7km)
All parents will be aware that residing within the priority area does not
guarantee an offer of a place at that school. These effects are long term
and a substantial negative against the proposal
4.3 Concerns regarding accessibility to services is also noted in the Warwick
District Plan Final Interim SA Report (June 2013) (Hereinafter referred to
as WDCLPSA) which states
'The site is just under 3 miles away from the nearest local services and
community facilities and although the site has good access to public transport,
the distance to and from these services are considered to be quite far. The
effects are considered to be permanent but minor negative in nature'.
We would disagree that this is a 'minor negative' given the need to place
particular emphasis on the need for good access to health and educational
facilities to address significant health and educational inequalities often faced
by the travelling community. Our review of site reflects this fact
4.4 Avoiding areas with a high risk of flooding
It is known that
'Fifty per cent of the site is located on an area of high to medium flood risk
(Flood zones 2 and 3) and would pose a significant risk to caravans which are
considered to be particularly sensitive development to flooding. Development
should be directed away from areas of flood risk. There is the potential for a
significant short to medium term negative effect on SA objective 11 (climate
change adaptation -flood risk) depending on which areas of the site are used.
(WDCLPSA)
4.5 Our recommendation is that the proposal should not be advanced
further until a full Flood Risk Assessment is undertaken to (a) test the
viability of a site being located anywhere within the GT03 curtilage (b)
identify the level of mitigation required to ensure that any proposal can
be implemented within acceptable risk parameters and (c) whether
such mitigation constitutes an economically viable proposition (e.g.
mitigation vs cost)
4.6 Safe access to the road network and provision for parking,
turning and servicing on site
Avoiding areas where there is the potential for noise and other
disturbance
Provision of utilities (running water, toilet facilities, waste
disposal, etc)
We may wish to comment on these issues after our site visit although it is
acknowledged that given that detailed plans are not available it is difficult to
provide precise comment on these issues
4.7 Avoiding areas where there could be adverse impact on important
features of the natural and historic environment
It is known that
'There is a Scheduled Monument adjacent to the site and although
unlikely to be directly affected by the allocation, because of its
presence, there could be potential for archaeology on the site which
could be directly affected' WDCLPSA
The presence of nearby Chesterton Roman Town and the Fosseway are
major persuaders that any development should adopt a precautionary
principle regarding the potential destruction or erosion of a nationally regarded
Heritage Site and its environs. The Chesterton town site consists of 'a
defended enclosure and an extensive extramural area of roads, buildings and
boundaries. Occupation appears to run from the 1st to 4th century AD'
(Warwickshire Museum Time Trial). We recommend that support is not given
to this potential development until the precise impact on 'potential
archaeology' is understood
It is also strongly recommended that WDC seek a detailed dialogue with
English Heritage on this matter - even advertising the proposal as affecting
the setting of a scheduled monument . English Heritage (2 C) sets out their
requirements where they must be consulted in the event that
A development (is) likely to affect the site of a scheduled monument
(Schedule 5 paragraph (o) of the Town and Country Planning
(Development Management Procedure) (England) Order 2010)
It is our view that the site should not receive further consideration until this
consultation is complete as a further test of the viability of the potential site
(Ref. http://www.english-heritage.org.uk/publications/consult-planning-listedbuilding-
conservation-area-consent/eh-notification-checklist.pdf)
4.8 Sites which can be integrated into the landscape without harming
the character of the area.
The WDCLPSA notes that:
'The effects on SA objectives relating to the prudent use of land, landscape
and air, water & soil quality are considered to be a minor negative. This is
because the site is located on Greenfield land outside of main settlements in
the open countryside and it contains a site of industrial pollution where
emissions are regulated. It would be recommended that existing hedgerows
are maintained and that additional screening/ landscaping is inserted where
appropriate to help blend the allocation into the landscape.
4.9 It is also recommended that
'A survey of the activities on the industrial site is carried to determine levels of
pollutants and suggest appropriate mitigation.
We recommend that the Parish Council object to this facet of the development
on a precautionary basis until such time as detailed evidence is available as
to the levels of pollutants/ emissions and the cost and viability of any
associated mitigation proposals
We would also recommend that The Parish Council objects to this site option
given that there is the potential for the development to undermine the
character and openness of the rural environment. Any developer - even at
the earliest stages of consideration would need to suggest how this potential
harm could be mitigated and such proposals are not available
4.10 Will the proposed site:
Promote peaceful and integrated co-existence between the site and the
local community
There is currently no evidence to suggest that site occupants could not
peacefully co-exist with the settled community. We do, however, anticipate
widespread concern from the settled and travelling communities over a range
of issues which undermine the viability of the site (flood risk, pollutants,
access to services) as well as other issues such as the potential impact on
heritage assets
4.11 Avoid placing undue pressure on local infrastructure and services
This is currently unknown although given the location of the site (and the
likelihood of car dependency) this will contribute further to pressure on the
road infrastructure
4.12 Reflect 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.
This is unknown as no site specific proposals have been produced. The
Parish Council will wish to clarify whether it is WDC's intention to promote
'residential only' sites or whether an element of 'business use' or parking of
commercial vehicles associated with business use is envisaged (along with
the storage of plant, equipment and other materials)
4.13 Overall interim conclusions
The unknown levels of potential mitigation measures (and the viability of these
measures) regarding
I. Flooding
II. Archaeology and
III. Potential pollutants
Combined with the sub optimal provision of accessible and viable
IV. Health and
V. Educational provision and
VI. A lack of choice of modes of transport (supporting sustainability)
provides serious and significant barriers to the development of GT03 as a viable
traveller site. No further consideration should be given to this site without the
necessary evidential data to quantify the risks and costs associated with mitigation
of items I to lll Notwithstanding this items 1V - V1 weigh strongly against this
proposed site
5. SITE BY SITE INTERIM ANALYSIS. SITE GT 05
LAND AT TACHBROOK HILL FARM BANBURY ROAD - 15 POTENTIAL
PITCHES
5.1 Overall conclusion
A fifteen pitch traveller site development is a relatively large proposition and
any potential developer should seek to ensure that optimal conditions exist for
such a development. In short this is NOT an ideal traveller site location and it
is recommended that this should be OPPOSED by the Parish Council on the
grounds shown in our overall interim concluding comments for this section
Our comments relating to the site based on WDC's own assessment criteria
follow:
5.2 Convenient access to a GP surgery, school, and public transport
The WDCLPSA states that:
'The site is just under 3 miles away from local services and facilities and with
the lack of access to public transport and safe pedestrian walkways, the
negative effects are considered to be permanent in nature and therefore a
major negative'.
It is therefore highly likely that the distance of the site to key facilities and
employment will promote car (and other vehicle) dependence. A 15 pitch site
could generate in the region of 100 plus trips per day (business, personal,
school) with no opportunity to offset this through use of local bus services
We note that:
(a) The nearest Doctors surgery is in Bishop's Tachbrook (1.5km)
(b) The nearest primary school is Bishop's Tachbrook (1.5km)
(c) The nearest secondary school is Campion (7km)
Local knowledge suggests that Bishop's Tachbrook primary school is 'always
oversubscribed' and that often 'children within the catchment area are turned
down'. This school is also only a single form entry and it is likely that it would
not be able to provide for additional requirements generated by a new
development
All parents will be aware that residing within the priority area does not
guarantee an offer of a place at that school. These effects are long term and
a substantial negative against the proposal
We agree that this is a 'major negative' given the need to place particular
emphasis on the need for health and educational facilities to address
significant health and educational inequalities often faced by travellers.
5.3 The WDCLPSA states that:
'It would be recommended to insert strong transport requirements for this
particular site to ensure that the right level of improvement and upgrade is
achieved'
We recommend that the Parish Council does not support this proposal until
such time as clear, costed, proposals are shown which would mitigate this
'major negative' (Transport) AND identify how sufficient access to education
services could be guaranteed
5.4 Avoiding areas with a high risk of flooding
The site is not known to be in an area of 'high risk of flooding' although local
checks should be made to clarify whether there are any issues of surface
water flooding and whether a Flood Risk Assessment (mitigation etc) is
required
5.5 Safe access to the road network and provision for parking,
turning and servicing on site
Provision of utilities (running water, toilet facilities, waste disposal,
etc.)
We may wish to comment on these issues following our site visit although it is
acknowledged that given that detailed plans are not available it is difficult to
provide precise comment on this issues
5.6 Avoiding areas where there could be adverse impact on important
features of the natural and historic environment
The WDCLPSA states that:
'Although there are no Conservation areas or Scheduled Monuments on or
adjacent to the site, there is a listed building within the site. The allocation has
the potential to affect the setting of the Listed Building. In addition, the
potential for archaeology is unknown'
Our previous comment regarding the presence of nearby Chesterton Roman
Town and the Fosse Way apply and we remain committed to the need for the
WDC to carry out more detailed work to identify the potential for archaeology
and the impact thereon. We recommend that support is not given to this
potential development until the precise impact on 'potential archaeology' is
understood
With regards to the development having the 'potential to affect the setting of a
Listed Building'. It is also strongly recommended that WDC seek a detailed
dialogue with English Heritage on this matter - even advertising the proposal
as affecting the setting of a listed building. English Heritage (2 A) set out their
requirements where they must be consulted in the event that a:
Development which in the opinion of the Local Planning Authority affects the
setting of a grade 1 or 11* Listed Building
It is our view that the site should not receive further consideration until this
consultation is complete as a further test of the viability of the potential site
(Ref. http://www.english-heritage.org.uk/publications/consult-planning-listedbuilding-
conservation-area-consent/eh-notification-checklist.pdf)
5.7 Sites which can be integrated into the landscape without harming
the character of the area.
WDCLPSA notes that:
'There are no international, national or local nature conservation designations
on or adjacent to the site but the presence of protected species and the
ecological value of the site in not known at this stage. It would be
recommended that strong environmental policies are developed to protect and
encourage enhancement of the natural environment and include provision for
green infrastructure.
The ecological status of the site could change dramatically if detailed
evidence was available regarding protected species or even the overall
ecological value of the site. It is therefore recommended that the Parish
Council applies a precautionary principal and objects to this element of the
proposal until such time as a detailed ecological assessment is carried out
We would also recommend that The Parish Council objects to this site option
given that there is the potential for the development to undermine the
character and openness of the rural environment. There is the potential for
negative visual impact on the countryside surrounding one of the main routes
into Historic Warwick. Any developer - even at the earliest stages of
consideration would need to suggest how this potential harm could be
mitigated and such proposals are not available
5.8 Avoiding areas where there is the potential for noise and other
disturbance
WDCLPSA notes that:
'Part of the site is adjacent to the M40 (noise effects on sensitive residential
development)......and.... In addition, it is recommended that a
noise assessment is carried out to identify possible noise impacts and
suggest appropriate mitigation.
WDC will be aware that noise effects can be a significant obstacle for
development and this may be reflected in any Examination in Public. An
Inspector making a decision to reject a traveller site remarked:
'This approach is fundamentally flawed (i.e. that a proposal could not be
rejected on noise grounds) and flies in the face of the guidance given in TAN
11 Noise24. This requires the Noise Exposure Category (NEC) of the site to be
assessed. Two of the NECs carry an assumption against permitting
residential development. I see no justification for the view that residential
caravans should not be treated as noise sensitive development in the same
way as permanent dwellings or that their occupants should be allowed to be
exposed to higher levels of noise than considered acceptable for other sectors
of the community. Caravans are a form of housing, as often stressed, but
more vulnerable since usual noise mitigation measures cannot be built in to
them. Appeal Decision (APP/A6835/A/12/2172161),
The harm from noise therefore clearly needs to be assessed and quantified
and as such the proposal should be opposed until such data is available and
the harms (and acceptability or otherwise) known
It is also recommended that
'A survey of the activities on the industrial site is carried to determine levels of
pollutants and suggest appropriate mitigation.
5.9 Will the proposed site:
Promote peaceful and integrated co-existence between the site and the
local community
There is currently no evidence to suggest that site occupants could not
peacefully co-exist with the settled community. We do, however, anticipate
widespread concern from the settled and travelling communities over a range
of issues which undermine the viability of the site (noise, poor access to
transport/ local services) as well as other issues such as the potential impact
on heritage assets
5.10 Avoid placing undue pressure on local infrastructure and services
It is noted that the current consultation proposal include four Gypsy and
Traveller sites in close proximity i.e. GT05, GT06, GT09 and GT15 - with a
total of 49 pitches being proposed. We therefore have additional concerns
about the cumulative effects on sustainable transport; the need to travel; local
services and community facilities and other factors described hereto. We
therefore recommend that The Parish Council should object to the potential
cumulative effect of these proposals (in addition to site specific issues raised
in this report) until such time as information is provided by WDC as to how
individual and cumulative issues will be addressed
5.11 Reflect 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.
This is unknown as no site specific proposals have been produced. The
Parish Council will wish to clarify whether it is WDC's intention to promote
'residential only' sites or whether an element of 'business use' or parking of
commercial vehicles associated with business use is envisaged (along with
the storage of plant, equipment and other materials)
5.12 Overall interim conclusions
The level of potential mitigation measures required (and the viability of these
measures) regarding
VII. Transport
VIII. Archaeology and Ecology
IX. Noise pollution
Combined with the sub optimal provision of accessible and viable
X. Health and
XI. Educational provision and
XII. A lack of choice of modes of transport (supporting sustainability)
provides serious and significant barriers to the development of GT05 as a viable
traveller site. No further consideration should be given to this site without the
necessary evidential data to quantify the risks and costs associated with mitigation
of items Vll to lX. Notwithstanding this items X - Xll substantially undermine this
proposal
6. SITE BY SITE INTERIM ANALYSIS. SITE GT 06
LAND AT PARK FARM, SPINNEY FARM - 15 POTENTIAL PITCHES
6.1 Overall conclusion
As with the previous sites considered, it is noted that (a) a fifteen pitch
traveller site development is a relatively large proposition and (b) this site
forms one of a cluster of proposed sites in close proximity. As such, any
potential developer should seek to ensure that optimal conditions exist for
such a development both as a sustainable individual site and with regards to
wider sustainability issues regarding other potential nearby sites. In short this
site fails - we contend both tests given a number of factors (and a variety of
unknowns) which have yet to be addressed even at an early consultation
stage. It is therefore recommended that this site should be OPPOSED by the
Parish Council on the grounds shown in our overall interim concluding
comments for this section (below)
Our comments relating to the site based on WDC's own assessment criteria
follow:
6.2 Convenient access to a GP surgery, school, and public transport
WDCLPSA states that:
'With regard to the SA objectives relating to sustainable transport; the need to
travel and access to local services & community facilities, the effects are
considered to be major negative at this stage. This is due to the location of the
site being nearly 3 miles away from the nearest local services and community
facilities (school and medical) and that there is currently no access to public
transport or safe pedestrian walkways. In addition, the A452 adjacent the site
to the east, experiences high volumes of traffic'
It is therefore highly likely that the distance of the site to key facilities and
employment will promote car (and other vehicle) dependence in an area
already noted for 'high volumes of traffic'. A 15 pitch site could generate in the
region of 100 plus trips per day (business, personal, school) with no
opportunity to offset this through use of local bus services
We note that
(a) The nearest Doctors surgery is in Bishop's Tachbrook (2.5km)
(b) The nearest primary school is Bishop Tachbrook (2.5km)
(c) The nearest secondary school is Campion (4.5km)
Local knowledge suggests that Bishop's Tachbrook primary school is 'always
oversubscribed' and that often 'children within the catchment area are turned
down'. This school is only a single form entry and it is likely that it would not
be able to provide for additional requirements generated by a new
development
All parents will be aware that residing within the priority area does not
guarantee an offer of a place at that school. These effects are long term and
a substantial negative against the proposal
We agree that this is a 'major negative' given the need to place particular
emphasis on the need for health and educational facilities to address
significant health and educational inequalities often faced by travellers. This
is therefore a point of objection by the Parish Council
WDCLPSA states that:
'It would be recommended to insert strong transport requirements for this
particular site to ensure that the right level of improvement and upgrade is
achieved'
We recommend that the Parish Council does not support this proposal until
such time as clear, costed, proposals are shown which would mitigate this
'major negative' (Transport) AND identify how sufficient access to education
services could be guaranteed
6.3 Avoiding areas with a high risk of flooding
The site is not known to be in an area of 'high risk of flooding' although local
checks should be made to clarify whether there are any issues of surface
water flooding and whether a Flood Risk Assessment (mitigation etc) is
required
6.4 Safe access to the road network and provision for parking,
turning and servicing on site
Provision of utilities (running water, toilet facilities, waste disposal,
etc)
We may wish to comment on these facets following our site visit although it is
acknowledged that given that detailed plans are not available it is difficult to
provide precise comment on this issues
6.5 Avoiding areas where there could be adverse impact on important
features of the natural and historic environment
WDCLPSA states that:
'Although there are no listed buildings, Conservation areas or Scheduled
Monuments on or adjacent to the site, there is a Registered Historic Park and
Garden adjacent to the site. The allocation has the potential to affect the
landscapes' special character'
With regards to the development having the 'potential to affect the
landscape's special character', It is also strongly recommended that WDC
seek a detailed dialogue with English Heritage on this matter - even
advertising the proposal as affecting the setting of a historic landscape.
English Heritage (2 D) set out their requirements where they must be
consulted in the event that a:
'Development (is) likely to affect any garden or park of special historic interest
which is registered in accordance with section 8C of the Historic Buildings and
Ancient Monuments Act 1953 (register of gardens) and which is classified as
Grade I or Grade II* (Schedule 5 paragraph (p) of the Town and Country
Planning (Development Management Procedure) (England) Order 2010)
It is our view that the site should not receive further consideration until this
consultation is complete as a further test of the viability of the potential site
(Ref. http://www.english-heritage.org.uk/publications/consult-planning-listedbuilding-
conservation-area-consent/eh-notification-checklist.pdf)
6.6 Sites which can be integrated into the landscape without harming
the character of the area.
An associated issue is the impact of any development on the ecology and
archaeology of the area
WDCLPSA notes that:
'There are no international, national or local nature conservation designations
on or adjacent to the site but the presence of protected species and the
ecological value of the site in not known at this stage. It would be
recommended that strong environmental policies are developed to protect and
encourage enhancement of the natural environment and include provision for
green infrastructure.
As with the previous site, the ecological status of the site could change
dramatically if detailed evidence was available regarding protected species or
even the overall ecological value of the site. It is therefore recommended that
the Parish Council applies a precautionary principal and objects to this
element of the proposal until such time as a detailed ecological assessment is
carried out
It is our view that the site should not receive further consideration until this
consultation is complete as a further test of the viability of the potential site
6.7 Avoiding areas where there is the potential for noise and other
disturbance
WDCLPSA notes that:
'The site is adjacent to the Warwick by-pass (A452)and the M40 (noise effects
on sensitive residential development) and..... In addition, it is recommended
that a noise assessment is carried out to identify possible noise impacts and
suggest appropriate mitigation.
WDC will be aware that noise effects can be a significant obstacle for
development and this may be reflected in any Examination in Public (see
previous note to traveller site appeal decision.
The harm from noise therefore clearly needs to be assessed and quantified
and as such the proposal should be opposed until such data is available and
the harms (and acceptability or otherwise) known
It is also recommended that
'A survey of the activities on the industrial site is carried to determine levels of
pollutants and suggest appropriate mitigation.
This survey should be published and risks/ mitigation measures made clear
as a further test of the viability of the site
Will the proposed site:
6.8 Promote peaceful and integrated co-existence between the site
and the local community
There is currently no evidence to suggest that site occupants could not
peacefully co-exist with the settled community. We do, however, anticipate
widespread concern from the settled and travelling communities over a range
of issues which undermine the viability of the site (noise, poor access to
transport/ local services) as well as other issues such as the potential impact
on heritage assets
6.9 Avoid placing undue pressure on local infrastructure and services
It is noted that the current consultation proposal include four Gypsy and
Traveller sites in close proximity i.e. GT05, GT06, GT09 and GT15 - with a
total of 49 pitches being proposed. We therefore have additional concerns
about the cumulative effects on sustainable transport; the need to travel; local
services and community facilities and other factors described hereto. We
therefore recommend that The Parish Council should object to the potential
cumulative effect of these proposals (in addition to site specific issues raised
in this report) until such time as information is provided by WDC as to how
individual and cumulative issues will be addressed
6.10 Reflect 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.
This is unknown as no site specific proposals have been produced. The
Parish Council will wish to clarify whether it is WDC's intention to promote
'residential only' sites or whether an element of 'business use' or parking of
commercial vehicles associated with business use is envisaged (along with
the storage of plant, equipment and other materials)
6.11 Overall interim conclusions
The level of potential mitigation measures required regarding
XIII. Transport
XIV. Archaeology and Ecology
XV. Noise pollution
Combined with the sub optimal provision of accessible and viable
XVI. Health and
XVII. Educational provision and
XVIII. A lack of choice of modes of transport (supporting sustainability)
provides serious and significant barriers to the development of GT05 as a viable
traveller site. No further consideration should be given to this site without the
necessary evidential data to quantify the risks and costs associated with mitigation
of items Xlll to XV. A detailed assessment is also required as to the potential
cumulative effect of this site on services, infrastructure etc as described above.
Notwithstanding this items XVl - XVlll substantially undermine this proposal
We would also recommend that The Parish Council objects to this site option
given that there is the potential for the development to undermine the
character and openness of the rural environment. There is the potential for
negative visual impact on the countryside surrounding one of the main routes
into Historic Warwick. Any developer - even at the earliest stages of
consideration would need to suggest how this potential harm could be
mitigated and such proposals are not available
7. SITE BY SITE INTERIM ANALYSIS. SITE GT 09
LAND TO THE NORTH EAST OF THE M40 AND SOUTH OF OAKLEY
WOOD ROAD - 15 POTENTIAL PITCHES
7.1 Overall conclusion
As with sites GT05 and GT06 considered, it is noted that (a) a fifteen pitch
traveller site development is a relatively large proposition and (b) this site
forms one of a cluster of proposed sites in close proximity. As such, any
potential developer should seek to ensure that optimal conditions exist for
such a development both as a sustainable individual site and with regards to
wider sustainability issues regarding other potential nearby sites. In short this
site fails - we contend - both tests given a number of factors (and a variety of
unknowns) which have yet to addressed even at an early consultation stage.
It is therefore recommended that this site should be opposed by the Parish
Council on the grounds shown in our overall interim concluding comments for
this section (below)
Our comments relating to the site based on WDC's own assessment criteria
follow:
7.2 Convenient access to a GP surgery, school, and public transport
WDCLPSA states that:
'There is the potential for significant negative effects on sustainable transport
and access to local services and facilities as the site is nearly 2.5 miles away
from the nearest local service or community facility (schools and medical) and
that there is currently no access to public transport or safe pedestrian
walkways. There is also the potential for a negative effect on SA3 (reduce the
need to travel). In addition, at this stage, little detail is known about existing
traffic and transport issues and how the allocation will affect them '
It is therefore highly likely that the distance of the site to key facilities and
employment will promote car (and other vehicle) dependence in an area
already noted for 'high volumes of traffic'. A 15 pitch site could generate in the
region of 100 plus trips per day (business, personal, school) with no
opportunity to offset this through use of local bus services
We note that
(a) The nearest Doctors surgery is in Bishop's Tachbrook (2.5km)
(b) The nearest primary school is Bishop's Tachbrook (2.5km)
(c) The nearest secondary school is Campion (5.5km)
Local knowledge suggests that Bishop's Tachbrook primary school is 'always
oversubscribed' and that often 'children within the catchment area are turned
down'. This school is only a single form entry and it is likely that it would not
be able to provide for additional requirements generated by a new
development
All parents will be aware that residing within the priority area does not
guarantee an offer of a place at that school. These effects are long term and
a substantial negative against the proposal
We regard this is a 'major negative' given the need to place particular
emphasis on the need for health and educational facilities to address
significant health and educational inequalities often faced by travellers.
WDCLPSA states that:
'It would be recommended to insert strong transport requirements for this
particular site to ensure that the right level of improvement and upgrade is
achieved'
We recommend that the Parish Council does not support this proposal until
such time as clear, costed, proposals are shown which would mitigate this
'major negative' (Transport) AND identify how sufficient access to education
services could be guaranteed
7.3 Avoiding areas with a high risk of flooding
The site is not known to be in an area of 'high risk of flooding' although local
checks should be made to clarify whether there are any issues of surface
water flooding and whether a Flood Risk Assessment (mitigation etc) is
required
7.4 Safe access to the road network and provision for parking,
turning and servicing on site
Provision of utilities (running water, toilet facilities, waste disposal, etc)
We may wish to comment on these facets following our site visit although it is
acknowledged that given that detailed plans are not available it is difficult to
provide precise comment on this issues
7.5 Avoiding areas where there could be adverse impact on important
features of the natural and historic environment
WDCLPSA states that:
'There is a few listed buildings within the site. The allocation has the potential
to affect the setting of the Listed Buildings'
With regards to how the development has the 'potential to affect the setting of
the listed buildings', It is strongly recommended that WDC seek a detailed
dialogue with English Heritage on this matter - even advertising the proposal
as affecting the setting of a historic landscape. Listed buildings such as
Grays Mallorys House are important - historically, architecturally and in terms
of the local landscape - and English Heritage (2 A) set out their requirements
where they must be consulted in the event that a:
'Development which in the opinion of the local planning authority affects the
setting of a grade I or II* listed building'
It is our view that the site should not receive further consideration until this
consultation is complete as a further test of the viability of the potential site
(Ref. http://www.english-heritage.org.uk/publications/consult-planning-listedbuilding-
conservation-area-consent/eh-notification-checklist.pdf)
7.6 Sites which can be integrated into the landscape without harming
the character of the area.
An associated issue is the impact of any development on the ecology and
archaeology of the area
WDCLPSA notes that:
'In addition, the potential for archaeology is unknown'
and
'There are no international, national or local nature conservation designations
on or adjacent to the site but the presence of protected species and the
ecological value of the site in not known at this stage. It would be
recommended that strong environmental policies are developed to protect and
encourage enhancement of the natural environment and include provision for
green infrastructure.
The ecological or archaeological status of the site could change dramatically if
detailed evidence was available regarding potential archaeology, protected
species or even the overall ecological value of the site. It is therefore
recommended that the Parish Council applies a precautionary principal and
objects to this element of the proposal until such time as a detailed ecological
assessment is carried out
It is our view that the site should not receive further consideration until this
consultation is complete as a further test of the viability of the potential site
We would also recommend that The Parish Council objects to this site option
given that there is the potential for the development to undermine the
character and openness of the rural environment. There is the potential for
negative visual impact on the countryside surrounding one of the main routes
into Historic Warwick. Any developer - even at the earliest stages of
consideration would need to suggest how this potential harm could be
mitigated and such proposals are not available
7.7 Avoiding areas where there is the potential for noise and other
disturbance
WDCLPSA notes that:
'The site is adjacent to the Warwick by-pass (A452)and the M40 (noise effects
on sensitive residential development) and..... In addition, it is recommended
that a noise assessment is carried out to identify possible noise impacts and
suggest appropriate mitigation.
WDC will be aware that noise effects can be a significant obstacle for
development and this may be reflected in any Examination in Public (see
previous note to traveller site appeal decision.
The harm from noise therefore clearly needs to be assessed and quantified
and as such the proposal should be opposed until such data is available and
the harms (and acceptability or otherwise) known
It is also recommended that
'A survey of the activities on the industrial site is carried to determine levels of
pollutants and suggest appropriate mitigation.
These surveys should be carried out and the level and viability of mitigation
measures quantified before further consideration is given to these sites. This
should form one of the early grounds for objection by the Parish Council
7.8 Will the proposed site:
Promote peaceful and integrated co-existence between the site and the
local community
There is currently no evidence to suggest that site occupants could not
peacefully co-exist with the settled community. We do, however, anticipate
widespread concern from the settled and travelling communities over a range
of issues which undermine the viability of the site (noise, poor access to
transport/ local services) as well as other issues such as the potential impact
on heritage assets
7.9 Avoid placing undue pressure on local infrastructure and services
It is noted that the current consultation proposal include four Gypsy and
Traveller sites in close proximity i.e. GT05, GT06, GT09 and GT15 - with a
total of 49 pitches being proposed. We therefore have additional concerns
about the cumulative effects on sustainable transport; the need to travel; local
services and community facilities and other factors described hereto. We
therefore recommend that The Parish Council should object to the potential
cumulative effect of these proposals (in addition to site specific issues raised
in this report) until such time as information is provided by WDC as to how
individual and cumulative issues will be addressed
7.10 Reflect 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.
This is unknown as no site specific proposals have been produced. The
Parish Council will wish to clarify whether it is WDC's intention to promote
'residential only' sites or whether an element of 'business use' or parking of
commercial vehicles associated with business use is envisaged (along with
the storage of plant, equipment and other materials)
7.11 Overall interim conclusions
The level of potential mitigation measures required (and viability of such measures)
regarding
XIX. Transport
XX. Archaeology and Ecology
XXI. Noise pollution
Combined with the sub optimal provision of accessible and viable
XXII. Health and
XXIII. Educational provision and
XXIV. A lack of choice of modes of transport (supporting sustainability)
provides serious and significant barriers to the development of GT05 as a viable
traveller site. No further consideration should be given to this site without the
necessary evidential data to quantify the risks and costs associated with mitigation
of items XlX to XXl. Notwithstanding this items XXll - XXlV substantially undermine
this proposal as does the potential cumulative effect of other nearby suggested sites
8. SITE BY SITE INTERIM ANALYSIS. SITE GT 10
LAND ADJACENT TO TOLLGATE HOUSE AND THE GUIDE DOGS
NATIONAL BREEDING CENTRE - 8 POTENTIAL PITCHES
8.1 Overall conclusion
An eight pitch traveller site development is a medium sized proposition and
any potential developer should seek to ensure that optimal conditions exist for
such a development. In short this is NOT an ideal traveller site location and it
is recommended that this should be OPPOSED by the Parish Council on the
grounds shown in our overall interim concluding comments for this section
Our comments relating to the site based on WDC's own assessment criteria
follow:
8.2 Convenient access to a GP surgery, school, and public transport
WDCLPSA states that:
'There is the potential for significant negative effects on sustainable transport
and access to local services and facilities as the site is nearly 2.5 miles away
from the nearest local service or community facility (schools and medical) and
that there is currently no access to public transport or safe pedestrian
walkways. There is also the potential for a negative effect on SA3 (reduce the
need to travel). In addition, at this stage, little detail is known about existing
traffic and transport issues and how the allocation will affect them '
It is therefore highly likely that the distance of the site to key facilities and
employment will promote car (and other vehicle) dependence in an area
already noted for 'high volumes of traffic'. An 8 pitch site could generate in the
region of 50 plus trips per day (business, personal, school) with no opportunity
to offset this through use of local bus services
We note that
(a) The nearest Doctors surgery is in Bishop's Tachbrook (3.5km)
(b) The nearest primary school is Bishop's Tachbrook (3.5km)
(c) The nearest secondary school is Campion (7.5km)
Local knowledge suggests that Bishop's Tachbrook primary school is 'always
oversubscribed' and that often 'children within the catchment area are turned
down'. This school is only a single form entry and it is likely that it would not
be able to provide for additional requirements generated by a new
development
All parents will be aware that residing within the priority area does not
guarantee an offer of a place at that school. These effects are long term and
a substantial negative against the proposal
We regard this is a 'major negative' given the need to place particular
emphasis on the need for health and educational facilities to address
significant health and educational inequalities often faced by travellers.
WDCLPSA states that:
'It would be recommended to insert strong transport requirements for this
particular site to ensure that the right level of improvement and upgrade is
achieved'
We recommend that the Parish Council does not support this proposal until
such time as clear, costed, proposals are shown which would mitigate this
'major negative' (Transport) AND identify how sufficient access to education
services could be guaranteed
8.3 Avoiding areas with a high risk of flooding
The site is not known to be in an area of 'high risk of flooding' although local
checks should be made to clarify whether there are any issues of surface
water flooding and whether a Flood Risk Assessment (mitigation etc) is
required
8.4 Safe access to the road network and provision for parking,
turning and servicing on site and
Provision of utilities (running water, toilet facilities, waste disposal, etc)
Our site visit may comment on these facets although it is acknowledged that
given that detailed plans are not available it is difficult to provide precise
comment on this issue
8.5 Avoiding areas where there could be adverse impact on important
features of the natural and historic environment
WDCLPSA states that:
'Potential effects on historic environment are considered to be minor negative
at this stage. Although there are no listed buildings, Conservation areas or
Scheduled Monuments on the site, there is a Scheduled Monument and a few
listed buildings adjacent to the site'
We turn to how the development has the 'potential to affect the setting of the
listed buildings' we do not regard this as a minor negative. It is strongly
recommended that WDC seek a detailed dialogue with English Heritage on
this matter - even advertising the proposal as affecting the setting of a historic
landscape. English Heritage set out their requirements where they must be
consulted in the event that a:
'Development which in the opinion of the local planning authority affects the
setting of a grade I or II* listed building'
And where
'Development (is) likely to affect the site of a scheduled monument (Schedule
5 paragraph (o) of the Town and Country Planning (Development
Management Procedure) (England) Order 2010'
It is our view that the site should not receive further consideration until this
consultation is complete as a further test of the viability of the potential site
(Ref. http://www.english-heritage.org.uk/publications/consult-planning-listedbuilding-
conservation-area-consent/eh-notification-checklist.pdf)
8.6 Sites which can be integrated into the landscape without harming
the character of the area.
An associated issue is the impact of any development on the ecology and
archaeology of the area
WDCLPSA notes that:
'There are no international, national or local nature conservation designations
on or adjacent to the site but the presence of protected species and the
ecological value of the site in not known at this stage. It would be
recommended that strong environmental policies are developed to protect and
encourage enhancement of the natural environment and include provision for
green infrastructure.
In addition, we have found no published data regarding the presence or
absence of archaeology. We therefore conclude that the potential for
archaeology is unknown
As with the previous sites, the ecological or archaeological status of the site
could change dramatically if detailed evidence was available regarding
potential archaeology, protected species or even the overall ecological value
of the site. It is therefore recommended that the Parish Council applies a
precautionary principal and objects to this element of the proposal until such
time as a detailed ecological assessment is carried out
It is our view that the site should not receive further consideration until this
consultation is complete as a further test of the viability of the potential site
8.7 Avoiding areas where there is the potential for noise and other
disturbance
WDCLPSA notes that:
'The site is adjacent to the M40 (noise effects on sensitive residential
development) and..... In addition, it is recommended that a noise assessment
is carried out to identify possible noise impacts and suggest appropriate
mitigation.
WDC will be aware that noise effects can be a significant obstacle for
development and this may be reflected in any Examination in Public (see
previous note to traveller site appeal decision.
The harm from noise therefore clearly needs to be assessed and quantified
and as such the proposal should be opposed until such data is available and
the harms (and acceptability or otherwise) known
8.8 Guide Dogs National Breeding Centre
The potential site would also be located close to the Guide Dogs National
Breeding Centre. Where it can be supposed that a potential new
development would involve occupiers who have a culture of keeping and
breeding dogs (such as travellers) a full risk assessment would need to be
carried out to ensure the integrity of both sites (and any potential costs
thereto) - and their respective activities in relation to animals - could be
maintained. The Parish Council therefore maybe minded to object to the site
on this ground until such a risk assessment is carried out satisfactorily
Will the proposed site:
8.9 Promote peaceful and integrated co-existence between the site
and the local community
There is currently no evidence to suggest that site occupants could not
peacefully co-exist with the settled community. We do, however, anticipate
widespread concern from the settled and travelling communities over a range
of issues which undermine the viability of the site (noise, access to services)
as well as other issues such as the potential impact on heritage and
ecological assets
8.10 Avoid placing undue pressure on local infrastructure and services
This is currently unknown although given the location of the site (and the
likelihood of car dependency) this will contribute further to pressure on the
road infrastructure
8.11 Reflect 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.
This is unknown as no site specific proposals have been produced. The
Parish Council will wish to clarify whether it is WDC's intention to promote
'residential only' sites or whether an element of 'business use' or parking of
commercial vehicles associated with business use is envisaged (along with
the storage of plant, equipment and other materials)
8.12 Overall interim conclusions
The level of potential mitigation measures required (and viability of the those
measures) regarding
XXV. Transport
XXVI. Archaeology, historic buildings and Ecology
XXVII. Noise pollution
XXVIII. Potential site integrity issues (National Guide Dogs Breeding Centre)
Combined with the sub optimal provision of accessible and viable
XXIX. Health and
XXX. Educational provision and
XXXI. A lack of choice of modes of transport (supporting sustainability)provides
serious and significant barriers to the development of GT10 as a viable
traveller site. No further consideration should be given to this site without the
necessary evidential data to quantify the risks and costs associated with
mitigation of items XXV to XXVlll. Notwithstanding this items XXlX - XXXl
substantially undermine this proposal
We would also recommend that The Parish Council objects to this site option
given that there is the potential for the development to undermine the
character and openness of the rural environment. It is for the developer to
clearly demonstrate how this potential harm will be mitigated in any proposals
9. SITE BY SITE INTERIM ANALYSIS. SITE GT 15
LAND ADJACENT TO EAST OF EUROPA WAY - 4 POTENTIAL PITCHES
9.1 Overall conclusion
A four pitch traveller site development is a relatively modest proposition (albeit
future plans may include requests for expansion to accommodate family
growth) and therefore any potential developer should seek to ensure that
optimal conditions exist for such a development and any future associated
development/ expansion.
9.2 At first review, there are always factors which weigh in favour of a
smaller traveller site proposal such as less impact on the environment and
services. At GT15 it is also the case that the site enjoys
* Reasonable access to local services and
* There are no issues relating to the effects of the proposal on listed or
other historic assets
9.3 However, for such a site - even of modest proportions - to be viable,
key factors have to be present - we will argue - to provide the basis for a
subsequent planning applications or assessment via Examination in Public.
These factors are considered below and our comments relating to the site
based on WDC's own assessment criteria follow:
9.4 Convenient access to a GP surgery, school, and public transport
WDCLPSA states that:
'With regard to SA objectives relating to sustainable transport; the need to
travel; and access to local services & community facilities, the effects are
considered to be uncertain/ minor negative at this stage. This is because
although the site has good access to local services and facilities within 2
miles, it currently has no access to public transport or safe pedestrian
walkways and at this stage, little detail is known about existing traffic and
transport issues and how the allocation will affect them. Mitigation is provided
to a certain extent by national planning policy but the effectiveness of the
mitigation will depend on design and layout at the development management
level. It is recommended that there are strong public transport infrastructure
requirements for this site to ensure that the right level of improvement and
upgrade is achieved'.
It is therefore highly likely that the distance of the site to key facilities and
employment will promote car (and other vehicle) dependence in an area
already noted for 'high volumes of traffic'. A 4 pitch site could generate in the
region of 25 plus trips per day (business, personal, school) with no opportunity
to offset this through use of local bus services
We note that:
(a) The nearest Doctors surgery is in Bishop's Tachbrook (3km)
(b) The nearest primary school is Bishop's Tachbrook (3km)
(c) The nearest secondary school is Campion (4km)
Local knowledge suggests that Bishop's Tachbrook primary school is 'always
oversubscribed' and that often 'children within the catchment area are turned
down'. This school is only a single form entry and it is likely that it would not
be able to provide for additional requirements generated by even a modest
new development
All parents will be aware that residing within the priority area does not
guarantee an offer of a place at that school. These effects are long term and
a substantial negative against the proposal
We regard this is a 'major negative' given the need to place particular
emphasis on the need for health and educational facilities to address
significant health and educational inequalities often faced by travellers.
WDCLPSA states that:
'It would be recommended to insert strong transport requirements for this
particular site to ensure that the right level of improvement and upgrade is
achieved'
We recommend that the Parish Council does not support this proposal until
such time as clear, costed, proposals are shown which would mitigate this
'major negative' (Transport) AND identify how sufficient access to education
services could be guaranteed
9.5 Avoiding areas with a high risk of flooding
The site is known to be in an area of risk of flooding. From our interim
research it appears to be the case that just under half of the site is within a
flood risk area
(http://www.warwickdc.gov.uk/NR/rdonlyres/93E97855-F61C-4BF7-BF61-
3E4FBAF88771/0/ReducedLeamingtonandWarwickPropMapSeptember2010.
pdf)
WDC should therefore carry out a full Flood Risk Assessment to understand
the level, type and cost of mitigation required. The Parish Council should
object to this proposal also based on the potential for flood risk
9.6 Safe access to the road network and provision for parking,
turning and servicing on site and
Provision of utilities (running water, toilet facilities, waste disposal, etc)
Our site visit may wish to comment on these facets although it is
acknowledged that given that detailed plans are not available it is difficult to
provide precise comment on this issue
9.7 Avoiding areas where there could be adverse impact on important
features of the natural and historic environment
WDCLPSA states that:
'There are no listed buildings, Conservation Areas or Scheduled Monuments
on or adjacent to the site'
9.8 Sites which can be integrated into the landscape without harming
the character of the area.
An associated issue is the impact of any development on the ecology and
archaeology of the area
WDCLPSA notes that:
'There are no international, national or local nature conservation designations
on or adjacent to the site but the presence of protected species and the
ecological value of the site in not known at this stage. It would be
recommended that strong environmental policies are developed to protect and
encourage enhancement of the natural environment and include provision for
green infrastructure.
In addition, we have found no published data regarding the presence or
absence of archaeology. We therefore conclude that the potential for
archaeology is unknown
As with the previous sites, the ecological or archaeological status of the site
could change dramatically if detailed evidence was available regarding
potential archaeology, protected species or even the overall ecological value
of the site. It is therefore recommended that the Parish Council applies a
precautionary principal and objects to this element of the proposal until such
time as a detailed ecological assessment is carried out
It is our view that the site should not receive further consideration until this
consultation is complete as a further test of the viability of the potential site
9.9 With regards to 'Avoiding areas where there is the potential for
noise and other disturbance'
WDCLPSA notes that:
'The site is adjacent to the Warwick by-pass A452 (noise effects on sensitive
residential development) and..... In addition, it is recommended that a noise
assessment is carried out to identify possible noise impacts and suggest
appropriate mitigation.
WDC will be aware that noise effects can be a significant obstacle for
development and this may be reflected in any Examination in Public (see
previous note to traveller site appeal decision.
The harm from noise therefore clearly needs to be assessed and quantified
and as such the proposal should be opposed until such data is available and
the harms (and acceptability or otherwise) known
Will the proposed site:
9.10 Promote peaceful and integrated co-existence between the site
and the local community
There is currently no evidence to suggest that site occupants could not
peacefully co-exist with the settled community. We do, however, anticipate
widespread concern from the settled and travelling communities over a range
of issues which undermine the viability of the site (noise, access to services)
as well as other issues such as the potential impact on ecological assets and
the cumulative effects on infrastructure from other potential nearby sites
9.11 Avoid placing undue pressure on local infrastructure and services
This is currently unknown although given the location of the site (and the
likelihood of car dependency) this will contribute further to pressure on the
road infrastructure. This could have an enhanced negative effect if this was
combined with the potential effect of other nearby proposed Gypsy and
Traveller sites
9.12 Reflect 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.
This is unknown as no site specific proposals have been produced. The
Parish Council will wish to clarify whether it is WDC's intention to promote
'residential only' sites or whether an element of 'business use' or parking of
commercial vehicles associated with business use is envisaged (along with
the storage of plant, equipment and other materials)
Overall interim conclusions
The level of potential mitigation measures required regarding
XXXII. Flood Risk
XXXIII. Transport
XXXIV. Unknown archaeological and ecological status
XXXV. Noise pollution
Combined with the sub optimal provision of accessible and viable
XXXVI. Health and
XXXVII. Educational provision and
XXXVIII. A lack of choice of modes of transport (supporting sustainability)
provides serious and significant barriers to the development of GT15 as a
viable traveller site. No further consideration should be given to this site
without the necessary evidential data to quantify the risks and costs
associated with mitigation of items XXX11 to XXX1V. Notwithstanding this
items XXXV - XXXVI1 substantially undermine this proposal
It is noted that the current consultation proposal include four Gypsy and
Traveller sites in close proximity i.e. GT05, GT06, GT09 and GT15 - with a
total of 49 pitches being proposed. We therefore have additional concerns
about the cumulative effects on sustainable transport; the need to travel; local
services and community facilities and other factors described hereto. We
therefore recommend that The Parish Council should object to the cumulative
effect of these proposals in addition to site specific issues raised in this report
until such time as information is provided by WDC as to how individual and
cumulative issues will be addressed
We would also recommend that The Parish Council objects to this site option
given that there is the potential for the development to undermine the
character and openness of the rural environment. It is for the developer to
clearly demonstrate how this potential harm will be mitigated in any proposals

Dear Mr Elliott,

We write with reference to the consultation for gypsy and traveller sites currently taking place.

We have considered the potential sites that have been put forward by the Council. We are extremely concerned by the inclusion of Kite's Nest Lane as a possible site (GT13). AS you are undoubtedly aware, this site has been the subject of two planning applications for use as a Gypsy and Traveller site. WDC have now decided twice that development of this site is inappropriate. The Secretary of State has also deemed it unsuitable for any form of development of this kind; even one Gypsy pitch would be inappropriate.

This site is in Green Belt: it is therefore inappropriate development. The site has been found not to be in keeping with its surroundings, which is open countryside. It is down a narrow country lane, with no footpaths or easy access to a main road network. These, and many other reasons, which have been discussed in detail at two Planning Inquiries, make it completely unsuitable. Of equal concern, however, is the fact that this site has been included at all. Significant resource has been expended by WDC already and the site has now, on two separate occasions, been found to be unsuitable. It is clear to us, therefore, that the Kites Nest Lane site should not be under consideration at all and we suggest it is withdrawn immediately and object in the strongest terms to any form of development there.

We believe that WDC should be looking outside of the Green Belt for all of its sites. However, we understand that a large part of the District is Green Belt. If it is not possible to identify enough sites outside of the Green Belt, we would suggest using Green Belt sites which have already had buildings on them. An example of this given in the consultation would be the Oaklands Farm site (GT19).

We have commented on the sites with which we are familiar and given reasons as to why we feel these would be suitable below.

GT15: This site is close to amenities and could easily be landscaped to integrate into its surroundings. It would be possible to provide appropriate access to the site.

GT17 and GT18: Taken together these two sites would provide a substantial number of pitches. This land has previously had buildings on it for many years and could easily be converted to providing Gypsy pitches without burdening Warwickshire Green Belt with additional development. They have good access to the main road network, which we believe is a requirement of the Gypsies and Travellers. Utilities will already be set up and these sites are close to Warwick town for access to services. Several houses lie along the A46 so clearly there would be no noise issues and the current design of the land means there is plenty of room for pulling on to and off the sites (there may even be slip roads already in place).

GT20: This site would provide excellent access to main roads and would be large enough to provide substantial integration of a Gypsy site into the landscape. A significant number of pitches could be created here, allowing Gypsies the chance to live in their extremely large family groups, as they often wish to.

Despite the positive features of these four sites, we still feel that land outside of the Green Belt should be the focus of this search. WDC has stated previously that any Gypsy Site allocations it makes do not necessarily have to be in Green Belt and we would urge WDC to carefully consider its position with regards to protecting the Warwickshire Green Belt. Indeed, the Secretary of State has recently announced his intentions to further protect Green Belt from Gypsy and Traveller developments and WDC should also be looking to safeguard its Green Belt from any kind of development.

We can confirm that this as our formal response to the consultation, and trust that WDC will consider this as appropriate.

An intention to avoid areas where there could be adverse impact on important features of the natural and historic environment is to be welcomed (para 7.3) as this echo's the requirements of the NPPF.

The following brief observations relate to those sites with the potential to be inconsistent with this objective. Further more careful assessment should be considered to understand how the proposed G&T sites relate to the significance of the heritage assets affected and whether the G&T developments would harm that significance. As I have been unable to consider whether any undesignated assets of importance or wider historic landscape matters are affected (Warwickshire Historic Landscape Characterisation, WCC) you should consider such matters when/if assessing the sites further.

GT03 Roman settlement close by at Windmill Hill. Issue of setting and potential for related archaeology.
GT05 Circa 17C barn. Impact on significance?
GT06 Adjacent to Grade 1 Castel Park (please refer to my comments to you re RDS July 2013).
GT07 Adjacent to Baginton Castle, associated settlement remains, ponds and mill sites.
GT09 Close to Warwick Castle Park; and includes West Lodge and Greys Mallory listed buildings
GT10 Potential for undiscovered archaeology relating to Oakley Wood Camp.
GT12/16 Setting of Barford Conservation Area. Potential for undiscovered archaeology.
GT15 Consider historic association with Castle Park.

I look forward to a refined version in due course. Please do contact me to discuss further if that would help.

Dear Sir/Madam


Re: LETTER OF OBJECTION
Sites for Gypsies and Travellers (Local Plan Document June 2013)

I write to object to the plan to establish Gypsy and Traveller sites as outlined in the above document. I have detailed the reasons for my objection below.

Warwick District Council has not provided any evidence that these sites are actually needed or any evidence as to why so many sites are needed. In fact the documentation supplied on your own website 'Evidence of Local Needs and Historic Demand for Gypsy and Traveller sites in Warwick District' and 'Gypsy, Traveller and Travelling Showpeople Accommodation Needs Assessment: Warwick Final report' suggests that 2-3 TEMPORARY sites of 15 pitches for the WHOLE of Warwickshire would be sufficient to cater for the needs of Gypsies and Travellers.

I refer to sections 5.2 and 5.3 of 'Evidence of Local Needs and Historic Demand for Gypsy and Traveller sites in Warwick District:'

Section 5.2 states the "figures demonstrate that, even when organised events are included, the average number of days spent in the district is low. The average number of days per visit overall is 6.2 and the average number of vans per encampment at any time is 8.7.

Section 5.3 states "All gypsies and travellers recorded were transitory and either moving from one part of the country to another, visiting family locally or attending an organised event, after which they left the district."

Section 5.5 includes a table of responses provided by 8 Gypsies and Travellers in which they were asked whether they would prefer a permanent or temporary site. Only 2 of the 8 responses indicated that they would like a permanent site.

So why are you proposing mainly permanent sites of at least 15 pitches when the above evidence quite clearly shows that permanent sites of this size are not needed.

I refer again to section 5.5 which states "The district council's own records comprise questionnaires completed or partially completed by gypsy and traveller groups when they arrived in the district. Since February 2008, eight such questionnaires, all from Irish travellers, have been collected. It is very difficult to get them completed since there is reluctance on the part of the travelling community to give information and distrust of council representatives. Information is also difficult to obtain for each of the families or individuals travelling together and sometimes one person will answer on behalf of the entire group. The questions posed assess the welfare needs of the individual, but some questions are pertinent to their more general needs. One of the questions asked relates to the desirability of a permanent site and where this would best be located for this specific group of travellers."

Q1. Why has WDC spent considerable time, money and resources formulating a plan based on evidence that is not statistically robust as it is based on responses provided by only eight people. This plan should be dismissed on these grounds alone.

Q2. Why has WDC spent considerable time, money and resources formulating a plan to benefit a group of people who clearly are not interested as they are unwilling to co-operate enough to even complete a questionnaire?

In section 5.6 it states "Advice obtained from the Gypsy and Traveller Officer at Warwickshire County Council based on the above information, indicates that a transient site would need to be made available, of an adequate size for ten vans to ensure that there would be sufficient space to accommodate a figure higher than the average number of vans recorded historically in the district at any one time."

This document concludes "From the data collected, it can be concluded that demand is low and transitory in nature. Even given the highest average number of days spent in the district this is no higher than 12 days. The average number of vans per visit is less than 9. To ensure that a site is provided of sufficient size to accommodate more than this average and accommodate the majority of encampments, it is concluded that there is a need for a transitory site to accommodate 15 vans. It is not considered necessary to accommodate the highest number of vans that has been recorded as these are extreme events and not a regular occurrence."

Q3. Why has WDC spent considerable time, money and resources producing a plan that proposes mainly permanent sites when the advice of your own Gypsy and Traveller Officer is that only ONE TRANSIENT site is required.

I refer to section 3.5 of the document entitled 'Gypsy, Traveller and Travelling Showpeople Accommodation Needs Assessment: Warwick Final report.' This includes a table that presents an estimation of the size of the Gypsy, Traveller and Travelling Showpeople population and 'states using the best information available we estimate that there are at least 124 individuals or thirty-three households in the study area' i.e. Warwick District.

This document is based on a study sample of only 43 families. Again this is not statistically robust.

Q4. Why has WDC spent considerable time, money and resources formulating a plan that proposes 31 sites when the current population of Gypsies and Travellers is so small?

Statistics from the 2006 Irish census in the Republic or Ireland also does not support the need for so many sites. In the census only 22,369 people identified themselves as Irish Travellers. Of these, only 1,460 lived in urban areas, a clear indication that Irish Travellers do not actually want to live in rural locations. Yet despite this, the majority of proposed sites are in rural locations.

From the location of the proposed sites, it is also clear that Warwickshire District Council has not consulted with Stratford-Upon-Avon District Council. You are proposing six sites within the small parish of Bishops Tachbrook which does not take into account the fact that due to the amount of identified green belt land within the Stratford-Upon-Avon district; the majority of their 52 proposed sites will have to be located to the north west of their district which borders very close to the parish of Bishops Tachbrook.

This plan also does not take into account Warwickshire District Council's own Local Plan - Revised Development Strategy Document June 2013 which proposes 12,000 new homes, the majority of which are located South of Warwick and Whitnash. The impact of this will be a significant increase in traffic and noise pollution in the very locations where you are proposing to put the Gypsy and Traveller sites.

With reference to all the above information I have provided I request that Warwick District Council provide evidence to justify both the location and number of proposed sites.

Site GT03 Land at Barnwell Farm, Harbury Lane
Site GT04 - Land at Harbury Lane, Fosse Way

Road Safety/Road Access - The area of the Fosse Way close to these two sites has already been identified as a dangerous road. Road users are warned of this by signs that inform them of how many people have been killed on the road and speed cameras have been installed in an attempt to slow traffic down. Road users will often travel at high speed and take risks due to the relative straightness of the road. An increase in slow moving traffic such as caravans on this road will only result in more accidents. The intersection of Harbury Lane and the Fosse way is particularly bad and traffic will back up here at peak times of the day.

The volume of traffic south of Warwick and Whitnash where this site is located will also increase greatly as outlined in the Local Plan - Revised Development Strategy Document June 2013

This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required, "Safe access to the road network and provision for parking, turning and servicing on site;"

Visual Aesthetics - These two sites will be clearly visible from the Chesterton Windmill. This site is visited daily by members of the local community and visitors to the area who enjoy this peaceful site with wonderful views of open fields. This wonderful view changes with the seasons meaning the site is visited all year round.

This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required, "Sites, which can be integrated into the landscape without harming the character of the area."

The view from Chesterton Windmill also looks out over the remains of a Roman settlement.

This site does not meet the criteria laid out in Section 3.5 of the Local Plan - Revised Development Strategy Document June 2013 where a specific principle under the key element of Environment is to protect high quality landscapes, heritage assets and other areas of significance.

Site GT05 - Land at Tachbrook Hill Farm, Banbury Road

Road Safety/Road Access - The Banbury Road is a very busy road and at peak times, traffic will back up and it can be very difficult to make a right hand turn onto this road from either the Oakley Wood Road or Mallory Road. Adding slow moving traffic such as caravans onto this road will increase the risk of incidents and add to the current traffic problems.

Today whilst travelling along the A46, I found myself in a long queue of traffic, travelling at less than 10mp for approximately 15 minutes. The reason for the build-up of traffic was three traditional style Gypsy caravans and horses on the road.

The volume of traffic south of Warwick and Whitnash where this site is located will also increase greatly as outlined in the Local Plan - Revised Development Strategy Document June 2013.

There is also no pedestrian access to this site.
This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required, "Safe access to the road network and provision for parking, turning and servicing on site;"

Noise Pollution - The south of Bishops Tachbrook village suffers from noise pollution from the M40. This site would lie even closer to the M40 so would suffer from even worse noise pollution.

Noise pollution as a whole will also increase greatly in this area due to the impact of the Local Plan - Revised Development Strategy Document June 2012 that proposes thousands of new homes within the same parish of Bishops Tachbrook.

This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required. "Avoiding areas where there is the potential for noise and other disturbance;"

Visual Impact - Mallory Road is the main road into the older original section of Bishops Tachbrook village.

Banbury Road is the main road used by visitors approaching from junction 14 or 15 into Warwick which is a historical town attracting visitors from all over the world.

This site does not meet the criteria laid out in Section 7.3 of the document, that states the following is required "Sites, which can be integrated into the landscape without harming the character of the area."

Schools - Bishops Tachbrook nursery and primary school run at full capacity and already have a waiting list. With six Gypsy and Traveller sites proposed for this small area, it would be impossible for the school to take on the significant number of extra students that would come from these sites.

This site does not meet the criteria laid out in Section 7.4 of the document that states the following is required to fully comply with provisions for sites "avoids placing undue pressure on local infrastructure and services;"

Site GT06 Land at Park Farm, Spinney Farm

Road Safety/Road Access - This site is situated very close to the Banbury Road, Warwick bypass and junction 14 of the M40. All of these roads are extremely busy especially at peak times of the day when drivers experience long tailbacks. There is also no pedestrian access to this site.

The volume of traffic south of Warwick and Whitnash where this site is located will also increase greatly as outlined in the Local Plan - Revised Development Strategy Document June 2013

The site does not meet the criteria laid out in Section 7.3 of the document that states the following is required. "Safe access to the road network and provision for parking, turning and servicing on site;"

Noise Pollution - This site would suffer from noise pollution due to its close proximity to junction 14 of the M40.

Noise pollution as a whole will also increase greatly in this area due to the impact of the Local Plan - Revised Development Strategy Document June 2012 that proposes thousands of new homes south of Warwick and Whitnash resulting in a substantial increase in the volume of traffic in the area.

This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required. "Avoiding areas where there is the potential for noise and other disturbance;"

Visual Impact - The Banbury Road is the access road to the historic town of Warwick.

This site does not meet the criteria laid out in Section 7.3 of the document that states that the following is required. "Sites which can be integrated into the landscape without harming the character of the area;"

Schools - Bishops Tachbrook nursery and primary school run at full capacity and already have a waiting list. With six Gypsy and Traveller sites proposed for this small area, it would be impossible for the school to take on the significant number of extra students that would come from these sites.

This site does not meet the criteria laid out in Section 7.4 of the document that states the following is required to fully comply with provisions for sites. "avoids placing undue pressure on local infrastructure and services;"

Site GT09 Land to the north east of M40 and south of Oakley Wood

Road Safety/Road Access - This site is surrounded by the M40 and Warwick Bypass (A452), all of which are very busy roads and there is no pedestrian access to the site.

The volume of traffic where this site is located will also increase greatly as a result of the Local Plan - Revised Development Strategy Document June 2013 which proposes 12,000 new homes south of Warwick and Whitnash, many of which we are told are required for people who will work in Coventry and therefore travel on these roads on a daily basis.

This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required. "Safe access to the road network and provision for parking, turning and servicing on site;"

Noise Pollution - This site would suffer from noise pollution due to its close proximity to junction 14 of the M40.

Noise pollution as a whole will also increase greatly in this area due to the impact of the Local Plan - Revised Development Strategy Document June 2012 that proposes thousands of new homes south of Warwick and Whitnash resulting in a substantial increase in the volume of traffic in the area.

This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required. "Avoiding areas where there is the potential for noise and other disturbance;"

Visual Impact - The Banbury Road is the access road to the historic town of Warwick.

This site does not meet the criteria laid out in Section 7.3 of the document that states that the following is required. "Sites which can be integrated into the landscape without harming the character of the area.;"

Schools - Bishops Tachbrook nursery and primary school run at full capacity and already have a waiting list. With six Gypsy and Traveller sites proposed for this small area, it would be impossible for the school to take on the significant number of extra students that would come from these sites.

This site does not meet the criteria laid out in Section 7.4 of the document that states the following is required to fully comply with provisions for sites. "avoids placing undue pressure on local infrastructure and services;"

Site GT10 Land at Tollgate House and Guide Dogs National Breeding Center

Road Safety/Road Access - This site is bordered by both the M40 and the Banbury Road. There is also no pedestrian access to the site.

The volume of traffic in the area where this site is located will also increase greatly due to thousands of new homes proposed to be built south of Warwick and Whitnash as outlined in the Local Plan - Revised Development Strategy Document June 2013.

This site proposed does not meet the criteria laid out in Section 7.3 of the document that states that the following is required. "Safe access to the road network and provision for parking, turning and servicing on site;"

Noise Pollution - The site would suffer noise pollution from the M40. Noise pollution as a whole will also increase greatly in this area due to the impact of the Local Plan - Revised Development Strategy Document June 2012 that proposes thousands of new homes south of Warwick and Whitnash resulting in a substantial increase in the volume of traffic in the area.

This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required. "Avoiding areas where there is the potential for noise and other disturbance;"

Visual Impact - The Banbury Road is the access road to the historic town of Warwick.

This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required. "Sites, which can be integrated into the landscape without harming the character of the area.;"

Business Impact - This site holds the national breeding centre for guide dogs. There is a risk of their breeding dogs being introduced to and infected by diseases carried by pets belonging to the Gypsy and Travelling communities.

Site GT15 Land to east of Europa Way

Road Safety/Road Access - This site is located near to Europa Way. This is a very busy road and at peak times experiences long tail backs in both directions. This road is so busy that there is a proposal to turn this into a dual carriageway road. There is also no pedestrian access to this site.

The volume of traffic where this site is located will also increase greatly as identified in the Local Plan - Revised Development Strategy Document June 2013 which proposes thousands of new homes in the area south of Warwick and Whitnash bringing with it a huge increase in the volume of traffic in the area.


This site does not meet the criteria laid out in Section 7.3 of the document that states the following is required, "Safe access to the road network and provision for parking, turning and servicing on site;"

Environment - This site is located close to the Tachbrook and as the sites are also designated as places of work, there is the risk of pollution from this site into the Tachbrook.

I request that you register my objection to the above sites and review your current Local Plan.

Please acknowledge receipt of my letter by return post and keep me informed of this matter.

Reference: Site GT02 - Land abutting the Fosse Way at its junction with the B425

For the following reasons:-

1. Convenient access to a GP surgery, school and public transport;
This site is in excess of 1.5miles from any GP surgery. The proposed site is outside of the catchment area of Harbury Surgery and the nearest surgery is the Croft Medical Centre in Sydenham which is 3.3 miles away which I understand is full. The next surgery is the Cubbington Road Surgery which is 4.7 miles distant and is not served by direct public transport so there is no convenient access to a surgery.
The position with regard to schooling is similar with Radford Primary School being almost fully subscribed and if the additional hundred houses are built in the village it will be full. This is outside of the Harbury catchment area and Harbury Primary School has had recent issues with too many children already.
The public transport whilst satisfactory is largely irrelevant as the residents are unlikely to use anything other than their own transport. There is a bus stop on the B425 however there is no pedestrian links from that to the potential site.

2. Safe access to the road network and provision for parking, turning and servicing on site;
The proposed 15 pitch site will contain up to 50 vehicles and generate hundreds of traffic movements daily. It is on the junction of two major roads and access into the traffic flow will possibly need highway improvements. It is possibly unwise to introduce even more traffic turns at this major junction and it will certainly add significantly to existing peak time delays. GT02 is sited on the junction of two main roads with high traffic flows and the Fosse Way in particular sees fast traffic despite the nearby speed camera and is a designated High Risk Route by the County Council.

3. Avoiding areas where there is the potential for noise and disturbance
This site is adjacent the Fosse Way a very busy and noisy main road.

4. Provision of utilities (running water, toilet facilities waste disposal etc);
The proposed site has no mains sewerage, drainage or gas so fails to meet the criteria. Also the electricity supply is a limited rural line and will possibly need to be upgraded to meet the very considerable increase in demand.

5. Avoiding areas where there could be an adverse impact on important, features of the natural and historic environment;
This choice of site overlooks the fact that at this point the Fosse Way, as the original Roman road built nearly 2000 years ago is known, is on its original alignment and there is likely to be considerable archaeological remains in the area which will be destroyed by the development. There was also a tollhouse at this point in the 17th and 18th centuries and remains have been found. Nearby there are traditional historic Woodlands which contain rare species so this criteria is not met.

6. Sites which can be integrated into the landscape without harming the character of the area.
The proposed site will cover 0.8 hectare (8000 m²) which is four times the size of the Exhibition Centre and if the Enfusion (consultants) recommendation to include working space is adopted this would possibly increase to 6 times the area of the Exhibition Centre. There will be a large variety of caravans and vehicles on the site so, being in the bottom of the valley, it cannot be integrated into the landscape without harming the visual appearance and character of the area.

7. Promotes peaceful and integrated co-existence between the site and the local community;
In this respect the local community forms two distinct sections. There is a very small community of some 20 houses within half a mile of the site along the Fosse Way and the far greater community in the village of Radford Semele over 1.5 miles away. It will be difficult to integrate the residents into the local Fosse Way community as with up to 120 residents on site rather than integrate they will actually absorb the local community. This does not meet the criteria of a peaceful and integrated co-existence.

8. Avoids placing undue pressure on local infrastructure and services;
The proposed site has no mains sewerage, drainage or gas so fails to meet the criteria. Also the electricity supply is a limited rural line and will possibly need to be upgraded to meet the very considerable increase in demand.

Identified Gypsy & Traveller Site GT03 land at Barnwell Farm Harbury Lane

This site fails to meet the councils Local Plan Requirements & its preferred options because-
The GP Surgeries in Bishops Tachbrook & Whitnash & Harbury are at capacity and would be unable to cope with an influx of new patients.
The primary school in Bishops Tachbrook & Harbury are already oversubscribed & the Catholic Primary in Whitnash, St Joseph's has even had to turn away Catholics with siblings already at the school as it has such a high application rate.
Also the educational needs of many of these children will mean that should a place be found at a local school they will need additional help to catch up, and this should be provided. Is the council going to supply additional funds to help support these children's needs? Given that the parents of many of these children are unable to read & write themselves they are not in a position to help children with their own learning and this identifies yet another pressure point. As an adult not being able to read & write seriously narrows down the type of work you would be able to apply for, there are no employers within in the village of Bishops Tachbrook or Harbury therefore there is no immediate local economy for them to join with. Most villagers have to commute to work.
There is no Dental care in Bishops Tachbrook.
There are no pavements between the proposed site and the nearest village and this would be a great danger especially during peak travel hours and school run times.
There are no bus stops and no safe place for a bus stop to be put in.
This would force more traffic through the village of Bishops Tachbrook & Whitnash & Additional traffic at major road junctions would put too much strain on an already busy junction onto a road where cars are travelling at speed.
Most of this plot does not have any Provision of Utilities
Given the proximity of 50mph roads next to this site what are the provisions for the safety and security of both people & animals? For instance a horse on the Banbury Road especially a loose one could end in fatalities.
.
It states in your Sites for Gypsies & Travellers page 9 last bullet point on section 7.4 the site should reflect the extent to which traditional lifestyles ( whereby some travellers live & work from the same location hereby omitting many travel to work journeys) can contribute to sustainability. Bishops Tachbrook & Whitnash & Harbury would not be able to offer any traditional forms of income for travellers or gypsies. Next to this statement is an image of a draught horse. We are not a horse based community so farrier's would not be able to make a living here. Also my understanding is that traditional forms of employment also include door to door sales and this would be in stark contrast to advice given by police not to buy from door to door sales people. I fail to see how our community can support the traditional lifestyle of travellers.

The proposed location is not in an area that can be integrated into the landscape without harming the character of the area which is stipulated as a Site Requirement within the WDC Consultation Document.
There is a potential visual impact on the approach to historic Warwick. This will damage the Tourist Industry which accounts for a large proportion of business transactions for both Large and Small & Medium Enterprises alike.
Therefore a site in this location will put undue pressure on local infrastructure & services.


I picked up the council's document "Sites for Gypsies & Travellers" Local Plan helping shape the district.
How is it those 15 sites are all placed south of Warwick & Leamington? The small village of Bishops Tachbrook has 6 of these within a mile of it, 2 are on its immediate doorstep. Potentially all of these sites could be approved and the very nature of our community and how the approach to our village would look would be irrevocably changed & the effect would be devastating to our way of life. This is not acceptable nor a reasonable request for the council to make.
There is no statement from the Gypsy Council of Great Britain or any other organising body on behalf of the Gypsy & Traveller community, within your brochure/document, that they wish to join our community in Warwickshire or anywhere else. Odd that. Perhaps this is because they have no desire to permanently live here? What evidence does the council have that the gypsy & traveller community wish to use these sites as a permanently settled site with a fixed maximum number of 15 Pitches? You also do not state how many people are able to live within a pitch or who is responsible for the site. Due diligence has not taken place here. I appreciate that you state the Regional Spatial Strategy & commissioned Salford University to produce a report but you have failed to put any meaningful back up data into this document. Therefore I have to question the validity of the study as you have not put it in the information you are handing out. Where is the proof that so many sites are needed? Much needed data is missing here & the council are remiss in leaving it out.
You also state that the Gypsy & Traveller Accommodation Assessment shows a need for 31 pitches, 25 within the first five years & a further 6-8 transit pitches over the Plan period. Yet the brochure you have produced is only showing 19 of these. Why are you not identifying where all these sites will potentially be? Are you planning to use these larger identified areas to put up multiple sites? Please be clear & honest!

Your brochure has not been laid out in a way that makes for easy & understandable reading. For instance sites GT05 & GT09 in reality face each other on opposite sides of the Banbury Road yet in your document the numbers on the map are shown as far away from each other as possible and are shown in map form pages apart from each other & at different scales & angles. This also occurs for site GT06 which is opposite GT09. You are failing to make your documentation easy to read & this is inexcusable.
Also the images you are using on your front cover, page 3 & page 4 are clearly stock images of holiday camping sites. They are not permanent sites and they are certainly not Gypsy & Traveller sites. Why is the council not using real images from existing successful sites to give an honest & truthful photographic representation of how these sites will look?

I attended the public meeting at Whitnash Primary School recently regarding the Local Plan. I have never attended a public meeting before & went with the idea that WDC & our local councillors would be working for the benefit of our community. Unfortunately when I left the meeting & on reading the documents I felt very disillusioned. The lead spokesperson for the council gave a long and drawn out introduction implying that we were all prejudiced against the traveller community. I found it offensive, ill advised and very condescending. Where I appreciate all the hard work & effort that council employees put in and I appreciate that the directives regarding The Gypsy & Traveller sites are coming from 10 Downing Street and not Local council I found the attitude of the councils representatives quite staggering. The gentleman representing The Highways Agency had clearly not received any training in how to speak to people. He was interrupted at one point by a lady at the back of the hall who asked a question relevant to the comment he had just made. The gentleman from the Highways agency then lost his temper and threatened not to give us any information if he was interrupted again. I found this to be highly unprofessional and suggest that that gentleman needs to learn the difference between a heckle and a pertinent question. And for the record that lady asked 3 questions, none of them were answered.
I also thought I was attending a public meeting but it appeared to be that the vast majority of people who were handed the microphone were councillors. I am very glad they were there but surely this was a place for the general public to have the chance to speak and to ask some questions supported by councillors?
Many people left that meeting about halfway through as they felt their voice was not being heard by the council. I found the whole experience depressing and frustrating. The gentlemen from the council set out their stall as a "you & us" situation and they seem to of forgotten that actually we are all supposed to be on the same side! We are able to understand directives from Downing Street and we should be questioning decisions that are projected onto our lives. Surely this is democracy? That meeting felt like the council had attended just to tick the box and that what they were suggesting should just be signed off. I am truly appalled.

After reading with trepidation about the huge housing developments proposed for the South Leamington area, the Residents / Rate Payers and Electorate and are now being told to expect 10 permanent Traveller sites in what can only be see as an over the top planning action by the elected councillors of WDC!
Most of the sites appear to be unsuitable for Travellers and far to large for 15 families; a 1/4 of an Acre per family, I only wish my children could have grown up with a full sized football pitch to play on!

The sites proposed at locations 3,4,5,6,9,10,15 are remote from any main amenities, such as shops bus routes and very little in the way of pedestrian access. Also accessing onto very busy A & B roads that carry high volumes of rush hour traffic, including school traffic into Warwick each week day. Some of the sites would result in employment loss i.e. Fosse Exhibition centre & Guide Dogs Breeding Centre. Others sites would impinge on the local historic views e.g. approach to Warwick & Chesterton Windmill, others are prone to winter flooding e.g. Tachbrook, all would put a strain on local middle schools and Doctors Surgeries.
Yes we do worry about increased crime and falling house prices, so the way to limit this is to spread the load more evenly across the district. There must be more suitable locations North, East & West of the Town? But apart from the one site proposal in Cubbington North Leamington is unscathed yet again, because the proposed housing developments have also passed it by? The residents in South Leamington area can only be left to wonder how many serving councillors live it the seemingly protected North Leamington area???
But take heed, councillors are employed because you were elected by the local voters, but if these proposals go through then at the next local election you wont be getting too many votes from South of the River! You were elected to benefit all of the local areas not damage some and favour others.............................. If the Government is bullying you into this Traveller site fiasco then SPREAD THE LOAD FAIRLY AND EVENLY thought the district!

From a very concerned local resident and rate payer over the past 39 years.

Dear Sir/Madam

My apologies for sending this as two emails, I had not realised that responses on the draft gypsy and traveller site consultation were to be sent to the same email address as general comments on the new local plan.

As explained in my earlier email, I hope you will still consider this feedback even though it has been submitted after the deadline. I am currently visiting family in Finland and have had to cope with two unexpected collapses of my father this afternoon which necessarily distracted me from responding before the deadline. I did, however, want to share my thoughts on the new local plan hence sending this email. Please would you confirm whether you will take my email into consideration as part of the new local plan consultation.

I understand that the proposed gypsy and traveller sites include a number in the environs of Bishops Tachbrook (sites 5, 6, 9, 15, 3 and 10). I fail to see how these sites meet with the criteria required for candidate sites, for example being able to integrate a permanent site into the landscape without harming the character of the area, convenient access to public transport, providing safe access to the road network, placing undue pressure on the local infrastructure and services and avoiding areas where there is the potential for noise and other disturbance. All these sites are too remote from major settlement areas.

The Bishops Tachbrook area has a strong rural character that must be preserved. The village is already being compromised by traffic that runs through it as a rat run to the M40. As outlined in my earlier email there are already road safety issues in the village so any new settlement (of any type) that increases the traffic through the village (to the motorway or to Leamington Spa) should be avoided. The public transport service is very limited so alternative options are not practical and many of the proposed sites do not offer pedestrian access so inhabitants will inevitably resort to using cars.

My recommendation is that sites which are closer to existing services (e.g. GP services and village schools) that could accommodate the additional demand should be sought and that the impact on the local rural road network be seriously considered. Any sites which will compromise the rural character of immediate area, specifically those listed above, should be excluded from the list of proposed sites. I appreciate this means that more rurally based councils will find it harder to find appropriate sites for gypsies and travellers, however this does not mean that the natural environment and character of the areas within its care should be compromised.

General Observations

WDC should have identified brownfield sites within the existing urban areas of Kenilworth, Warwick and Leamington for Gypsies and Travellers. These sites would be more suitable and sustainable, and would enable better integration in to the local community. Despite such sites existing, they are all being proposed for redevelopment for more valuable uses. WDC should be requiring Gypsy and Traveller sites are delivered within the proposed major new housing developments in Kenilworth, Warwick and Leamington. This would ensure that the sites could be properly designed in a sustainable fashion and be fully integrated into a local community which will provide facilities such as a school, a doctors surgery and shops which are accessible on foot, on bike, by bus and by car.

Ecology and Environment - all of the sites have some ecological value and environmental issues which does not appear to have been assessed.

WDC should revisit its Greenbelt Policy and release sites to the north of Warwick and Leamington which would reduce the pressure to allocate land for all forms of development during the new Local Plan period to the south of the District.

WDC should consider allocating an area of land to the south of Warwick and Leamington including The Asps and Sites 5, 6, 9, 10 as Greenbelt to provide a 'buffer' to the proposed developments to the south of Warwick and Leamington and/or to extend the proposed Bishops Tachbrook Country Park as far as the Banbury Road near to Warwick Castle Park. This would ensure the villages in the south of the District retain their identity and are not 'swallowed up' by Warwick and Leamington over time.

I support the area of search at GT11 (Hampton Road). This is a sustainable site with good access to GPs and both primary and secondary schools. There is adequate separation from the settled community to avoid issues of noise from the site affecting the settled community, whilst the site is close enough to minimise isolation and potentially promote a better understanding between the two communities. However, the western end of the site is too close to the A46 and noise levels are high. Trailers cannot be soundproofed to the same level as houses so this part of the area will not provide reasonable accommodation for the travelling community.

Other sites offering reasonable access to existing facilities, particularly primary schools, include GT12 and GT05, particularly the northern end of GT05. In the case of GT12 the difficulty of crossing the
A429 Barford bypass should be considered, however.

I object to the site at GT20 (Junction 15, M40) because the high level of noise from the M40 will adversely impact on the amenity of residents of any site here.

Similar comments can be made for large parts of GT09

The Fosse Way sites (GT03 and GT04) appear to have nothing to recommend them in terms of access to facilities. The level of isolation of the sites is also unlikely to promote inclusion. GT06 suffers from similar problems.

GT15 (Europa Way) relates well to the proposed areas of growth and might be a suitable site in the long term, although its size and shape makes the provision of internal open space with good casual surveillance difficult. Noise from Europa Way could also be a problem.

I am writing in response to the proposed Gypsy and Traveller sites in the parish of Bishops Tachbrook.


6/20 of the proposed sites are situated in and around our beautifully peaceful village. A village which has very few resources among which are a church, a small grocers shop, a hairdressers a sports and social club and a small primary school. We have a mobile library and a mobile chip shop on occasions.


Due to our limited resources within the village most locals commute outside of the village to work. This begs the question as to where the gypsy and travelling community are going to find work locally?

The school is almost always over subscribed. It's a single form entry and is always at full capacity. We question that the school has enough resources to cope with additional pupils from the Gypsy & Traveller community if they are allowed to set up camp within our village. The school relies on help from parents who give up their time to come in and help teachers and read with pupils. With over 81% of gypsy and traveller children's parents being illiterate I question who will provide the extra support that the children will need if their own parents are unable to provide that support.

Local Secondary schools are also over subscribed, leaving us with concerns that there will not be adequate provision for the current population of the parish.

The local doctor's surgery again is very small and only open for five half days and as it's already difficult to get an appointment I question how additional families would fare and again this would put the surgery under undue pressure.

As there would currently be no sewage, water, electricity or gas to the proposed sites the cost to connect them up will be huge, as well as putting the existing services under strain they will not be of sufficient size to take the extra load.


As my family live near the fields at the top of the village where there are Bats I feel concerned that any plans to build or site travellers would deter the bats from their natural habitat.

There is also a very limited public transport option.

GT03 is very remote and not in reach of major amenities.

GT04 again is very remote.

GT05 has access onto a very busy road, with cars travelling at speed. This would be dangerous to introduce caravans turning into the site, and pedestrian access is dangerous. I would argue that to even build a footpath alongside that road would be dangerous and there is no footpath to reach any facilities. This site would also have a negative visual impact on the approach to historic Warwick and therefore effect local business dependent on tourists in a negative way. There are also listed buildings on that site in need of protection.

GT06 very remote and again no pedestrian access.

GT09 has no pedestrian access and again a negative visual impact onto visitors to Warwick.

GT10 is close to the Blind National Breeding Centre and I would question the risk of disease from un vaccinated pets and animals belonging to the gypsies.

GT15 is on the banks of the Tachbrook. As most travellers seem to be able to earn an income on site I would question that the proposed site could cause a chance of pollution to the brook which is unacceptable.

In general all these sites have no adequate bus stops, and are on busy roads.
No path or pavement to walk anywhere and cycling is dangerous on busy commuter routes.
Children cannot be allowed to stand on a busy road to wait for transport to school.
Whilst I appreciate that the council is under an obligation to provide some permanent pitches I strongly feel that the sites chosen are unsuitable.

The sites would provide undue strain on local resources that are already stretched to capacity. At a recent meeting a fellow villager asked a planning officer where the occupiers of the proposed thousands of new build homes would work - an answer could not be given.

Please do not hesitate to contact either myself or my husband should you require any further verification of our objections.

Dear Sir/Madam,
I am writing to make my objections to the Gypsy and Traveller Site (G&TS) options clear.
It is clear that when considering G&TS's the following must be considered:
Convenient access to a GP surgery, school and public transport
In 2007, 2.7% of children of Gypsy/Romany origin and 8.4 % of traveller children of Irish heritage achieved 5 or more A* to C grades or equivalent exams including English and Mathematics in England compared to a national average of 45.4%. 8% of Gypsy and Traveller mothers have experienced the death of a child compared to less than 1% of the settled community. This could put a major strain on the already overworked education and medical facilities already available in the area.
The Catholic Primary in Whitnash, St Josephs' has had to turn away Catholics with siblings already at the school as it has such a high application rate. Is the council going to supply additional funds to help support these children's needs? Given that the parents of many of these children are unable to read & write themselves they are not in a position to help children with their own learning and this identifies yet another pressure point. As an adult not being able to read & write seriously narrows down the type of work you would be able to apply for, there are limited employers within in the village of Bishops Tachbrook therefore there is no immediate local economy for them to join with.
Avoiding areas with a high risk of flooding
Field on the corner of Mallory Road, Banbury Road floods on each side whenever there is a significant rainfall. Sites GT05, GT06, GT09 and GT10 are all prone to flooding.
Provision of utilities
Who would be expected to provide this? Sites GT05, GT06, GT09 and GT10 do not have adequate provision of utilities such as sewerage, drainage, gas and water.
Safe access to the road network and provision for parking, turning and servicing on site
Sites GT05,GT06, GT09 and GT10 are all on very major roads with no means of pedestrian access. There are no bus routes and they are all fast moving roads.
Avoiding areas where there is the potential for noise and other disturbance
Banbury Road is the main road off the M40 for people travelling from both the North and the South. GT05, GT06, GT09 and GT10 are all bordering the M40 meaning that these sites will be very noisy for occupants. GT05 is in extremely close proximity to residents of Bishops Tachbrook and so any noise from this site would have a major effect on current residents.
Avoiding areas where there could be adverse impact on important features of the natural and historic environment
St Chads church in Bishops Tachbrook has many historical features. It is mentioned in the Domesday Book. GT05 and GT09 are both situated on the approach to Bishops Tachbrook and would be the first visual sight that visitors would see of the village.
Sites which can be integrated into the landscape without harming the character of the area.
It is difficult to think of any area at all that would meet this criteria. The character of the area around GT05, GT09 and GT10 is agricultural farm land. I fail to see how a G&TS would integrate into this landscape without harming the character of the area.
Promotes peaceful and integrated co-existence between the site and local community
I would suggest this is highly unlikely due to the level of local disagreement with the proposed sites, in particular GT05, GT09 and GT10. I have concerns over the level of noise that any sites may incur, both from the inhabitants and also the local community expressing their objections. Local residents have discussed various methods of protest if these plans are to go ahead. Various residents have offered financial assistance regarding legal advice. The press and local MP's have been engaged and shown their support.
Avoids placing undue pressure on local infrastructure and services
Will additional funding be provided to the village school to support with the proposed number of children likely to attend? If not will a new school be built to support in this area? Will this cause a change in the catchment areas for the school? It would be unfair for tax paying residents to be moved out of the catchment area to accommodate these new developments.
The school in Bishops Tachbrook is single form entry and is already oversubscribed. G&TS of 5,10 or 15 are likely to provide homes for 10,20 or 30 children. A small school which is always at capacity is unlikely to be able to provide the infrastructure required to support the needs of the proposed sites. The school does not have the resource to support children that have received very little if any formal education. They will struggle to integrate into the local school environment.
The school also relies on the parent teacher working relationship meaning that parents support the school by giving up their time to help teach and read with pupils. It is known that 81% of Gypsy and Traveller children's parents are illiterate. This will mean no support for the school. It will also mean that these children will require even more support from existing parents. The extra support that these children will need will put the current children at a disadvantage. The school is simply not equipped to deal with the needs of these children.
There are already concerns that the secondary schools in the area are oversubscribed and that there is not adequate provision for the current population of the parish. Any additional strain on these numbers will only make the situation worse.
There is a grade 1 listed church and a sports and social club built through local fund raising. There is a small local shop, a hairdresser and one public house. That is it.
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
I would suggest that it is a small minority of Gypsy and Travellers that live and work from the same location. I would be interested to see the evidence to show how a Gypsy and Traveller site can support local sustainability in this area.
Specific sites
GT05, GT09- Vehicle access is onto a very busy main road, with vehicles travelling at speed. To introduce caravans and mobile homes turning into the site would be dangerous. Additional traffic at the junction of Mallory Road & Banbury Road would put too much strain on an already busy junction onto a road where cars are travelling at speed, because of the north and southbound approaches to junction 13 of the M40. This is not an easy junction to get out of especially if you have to move slowly due to pulling a trailer or caravan.
Given the proximity of 50mph roads next to this site what are the provisions for the safety and security of both people & animals? For instance a horse on the Banbury Road especially a loose one could end in fatalities.
The potential visual impact would be devastating on the approach to the Historical Warwick town and could discourage visitors and tourists. There are listed buildings on this site in need of protection. The proposed location is not in an area that can be integrated into the landscape without harming the character of the area which is stipulated as a Site Requirement within the WDC Consultation Document. It would be the first thing that people see when travelling into the village from the M40
GT06 - Very remote from main centres and no means of pedestrian access
GT10 - Close to the Guide Dogs for the Blind National Breeding Centre. The risk of disease from any unvaccinated animals belonging to Gypsies and Travellers could be devastating. Given the proximity of 50mph roads next to this site what are the provisions for the safety and security of both people & animals? For instance a horse on the Banbury Road especially a loose one could end in fatalities. As could loose dogs.
Vehicle access is onto a very busy main road, with vehicles travelling at speed. To introduce caravans and mobile homes turning into the site would be dangerous.
The proposed location is not in an area that can be integrated into the landscape without harming the character of the area which is stipulated as a Site Requirement within the WDC Consultation Document.
GT15 - site located on the banks of the Tachbrook. There could be a chance of contamination, given that the proposed site may be used as a place of work. Europa Way is an already congested road and adding further traffic to this mix could be devastating.
Sites GT05, GT06, GT09 and GT10 are currently homes to many forms of farm and wildlife animals. They are also working farm land.
Other considerations
6 out of the 20 sites have been proposed around the small unique village of Bishops Tachbrook.
Are the sites identified in and around Bishops Tachbrook too remote from the main infrastructure of Leamington Spa or Warwick to be suitable for this type of development?
On behalf of Warwick District Council, Salford University has determined that there is a requirement for 25 pitches initially expanding to 31. Why the need for so many propsed sites then?
Who will monitor the sites. It is my understanding that the sites will be operated by Gypsy and Travellers and not Warwick District Council. If this is the case how can concerns such as noise pollution land pollution and overcrowding be controlled?
Recommendations state that the size of each site must be between 5 and 15 pitches but does not specify how many people can populate this sites. What plans have been put in place to ensure that what happened at Dale Farm does not happen again. This was where a legitimate site expanded?
What about the effect on house prices in the general area around these sites?
What will be the visual impact on Bishops Tachbrook village and surrounding area. Will it have an impact on tourism in the area?
All proposed sites are on busy roads where it would be a danger for any children to wait for transport to school.
Why are 15 of the proposed sites in the south of Warwick & Leamington? The small village of Bishops Tachbrook has 6 of these proposals within a mile of it, 3 are on its immediate doorstep. Potentially all of these sites could be approved and the very nature of our community and how the approach to our village would look would be irrevocably changed. The effect on Bishops Tachbrook would be devastating to our way of life. This is not acceptable nor a reasonable request for the council to make.
There is no statement from the Gypsy Council of Great Britain or any other organising body on behalf of the Gypsy & Traveller community, within your brochure/document, that they wish to join our community in Warwickshire or anywhere else. Perhaps this is because they have no desire to permanently live here? What evidence does the council have that the Gypsy & Traveller community wish to use these sites as a permanently settled site with a fixed maximum number of 15 Pitches? You also do not state how many people are able to live within a pitch or who is responsible for the site. Due diligence has not taken place here. I appreciate that you state the Regional Spatial Strategy & commissioned Salford University have produced a report but you have failed to put any meaningful back up data into this document . Therefore I have to question the validity of the study as you have not put it in the information you are handing out. Where is the proof that so many sites are needed? Much needed data is missing here & the council are remiss in leaving it out.
You also state that the Gypsy & Traveller Accommodation Assessment shows a need for 31 pitches, 25 within the first five years & a further 6-8 transit pitches over the Plan period. Yet the brochure you have produced is only showing 19 of these. Why are you not identifying where all these sites will potentially be? Are you planning to use these larger identified areas to put up multiple sites? Please be clear & honest!
Sites GT05, GT06, GT09, GT10 are all next to each other meaning that of all these sites are successful there would be a huge Gypsy encampment in a small area.
The images you are using on your front cover, page 3 & page 4 are clearly stock images of holiday camping sites. They are not permanent sites and they are certainly not Gypsy & Traveller sites. Why is the council not using real images from existing successful sites to give an honest & truthful photographic representation of how these sites will look?
Proposals
Has the area next to the police site on the west side of Europa Way in between GT06 and GT15 been considered. This could have access onto one of 4 roads and would have a high Police presence.
A further alternative site and one that is a much more suitable at addressing the issues that are set out in Section 4 of the consultation document is on the opposite side of Stratford Road, Warwick to Aylesford School. This site is located within walking distance of medical, educational and recreational facilities.
It is located on a straight section of road with good sight lines and a 40 mph speed limit. It is served by bus routes and has wide pedestrian footpaths. This site is also set back from the road so would provide some protection from any negative visual impact.
Other comments
The instructions for this plan are very unclear. I have been advised that a separate letter needs to be submitted for each proposed site but I can not see anywhere that this is mentioned for email responses, this is unclear. If that is the case I have grave concerns that this consultation has not achieved its legal goal of "improving the efficiency, transparency and public involvement in large-scale projects or laws and policies" as people do not know how to respond in the correct manner.
I request to know the name of the authorised Gypsy site shown in your brochure.
Whilst I appreciate that WDC are under instruction to provide sites I would suggest that the proposed sites around the Bishops Tachbrook area are in the wrong places. This community is already stretched to capacity. I fail to see how the G &T could contribute to our small community.