INTRODUCTION

Public Health Warwickshire welcomes the opportunity to respond to the Warwick District consultation on sites for gypsies and travellers, preferred options. Having reviewed the document, Public Health Warwickshire have summarised the key messages, background and local context, health and social inequalities and recommendations in relation to gypsies and travellers and the links and key public health considerations that should be taken into account within the consultation process.


KEY MESSAGES

In general:

1. The health status of Gypsies and Travellers (G&Ts) in the UK is much poorer than that of the general population and also poorer than that of non-Travellers living in socially deprived areas.
2. G&Ts have low health expectations, poor access to, and uptake of health services, especially of primary and social care.
3. G&Ts' health and wellbeing are determined largely by wider socio-economic factors, such as: inappropriate accommodation and living conditions; social and economic exclusion and racism; inadequate education and cultural differences.
4. Two interventions have proven beneficial to G&Ts' health and wellbeing:
* Local provision of legal, regulated, well organised and managed accommodation sites (especially permanent, but also transit);
* Use of local outreach teams (OT) and initiatives to provide health care and education on site, including G&Ts involvement and participation.
5. Local authorities have a legal and moral obligation to ensure social and health equity for their populations, including support for minority and disadvantaged groups. Development of well managed G&Ts sites is in line with the national policies and priorities.
6. Considering the Warwickshire G&Ts' population, the shortage of legal camps and existing unauthorised encampments, a need for more authorised sites (especially short-term/transit) has been identified.
7. Unauthorised encampments pose a significant threat to both G&Ts' and local communities in terms of social cohesion, education, health and wellbeing as well as unnecessary resource consumption.
8. Most of the public concerns are related to perceptions rather than evidence however, existing evidence suggest that G&T sites are not a threat to the local community and bring significant benefits to the travelling communities.
9. Evidence suggests that longer term programmes and interventions are more beneficial for the social integration, health and wellbeing, education and reducing inequalities in G&Ts. However, transit/short-term sites can offer opportunities for health promotion and diseases prevention, especially if coordinated with a travellers' liaison and the local primary and social care services.
10. The decision and planning developments should incorporate appropriate communication, awareness raising with local people and gaining community support.

BACKGROUND AND LOCAL CONTEXT
There is a huge shortage of LA Sites and even less transit sites which has left over 25,000 people displaced, with nowhere to stop legally or safely. G&Ts are usually forced to stop on common land or on roadsides, most often without sanitation, waste disposal/collection, clean drinking water or electricity. Being forced onto inappropriate stopping places usually creates social tension between local people and Travellers, with road-siders being blamed for an increase of crime and fly-tipping.

The present legislation, including. the Housing Act 2004 and the Planning and Compulsory Purchase Act 2004, places a legal and moral duty on LAs to assess the accommodation needs of G&Ts and to include specific sites and criteria in Local Development Frameworks. The need for more such sites is supported by a range of evidence, also suggesting that cost of non-provision (both financially and morally) provides a strong case for persuading local politicians and members of local community that there is no option but to consider carefully planned new sites.

Current situation in Warwickshire
The exact number of G&Ts within Warwickshire is difficult to quantify. The Warwickshire Gypsy and Traveller Accommodation Assessment has found the following:
* There are 4 authorised GRTs sites in Warwickshire: Alvecote, Griff, Pathlow, Woodside.
* There are 2 unauthorised developments.
* There are a large number of unauthorised encampments (115 encampments/599 families (299 children) so far in 2013).
* Access to facilities and services is restricted for households on unauthorised encampments.
* A countywide floating support service.
* An estimated additional transit site need: 40 in Warwickshire (Warwick 15, Startford-upon-Avon 10, Rugby 5, North Warwickshire 5 and Nuneaton and Bedworth 5).

Findings from the accommodation assessment needs surveys, conducted both in the North and South of the County show:
* Household size is significantly larger with a significant minority of the sample (12%) households over 60 years of age and young families being the predominant household type.
* A third of school age children does not regularly attend school or receive home education. Children on unauthorised encampments and socially rented sites had the poorest attendance.
* The majority of respondents (nearly ¾) felt they were 'local' to the area they were residing in.
* The G&Ts are largely sedentary. Feeling settled and poor health were the main reasons that were cited for not travelling.
* Self-employment was a major source of income, including: gardening/tree work, UPVC and guttering and scrap.
* Nearly a fifth of respondents wanted to see the development of more transit/short-stay sites. Interest was shown from households from all types. For G&Ts in authorised/settled accommodation the creation of more authorised short stay sites would enable an increase in family visits and help to maintain the tradition of travelling. Such sites should be around 10 pitches in size with a large number of people expecting to use the site for between 1-4 weeks.


Gypsies and Travellers - HEALTH AND SOCIAL INEQUALITIES
The literature specific to the Gypsy and Traveller population indicates that, as a group, their health overall is much poorer than that of the general population and also poorer than that of non-Travellers living in socially deprived areas (Parry et al., 2004). The continuous instability and trauma caused by frequent evictions, discrimination, racism and harassment, often becomes part of their way of life, leading to chronic physical and mental health problems. They have poor health expectations and make limited use of health care provision (Van Cleemput et al., 2007; Parry et al., 2007).

In an report from the Institute for Public Policy Research (IPPR), Crawley (2004) emphasised the appalling inequalities experienced by Gypsies and Travellers in relation to health and education. A range of evidence is showing:

1. G&Ts die earlier than the rest of the population, having one of the lowest life expectancies in the UK as well as the highest rates of infant mortality. They experience poorer health, including: high rates of infectious diseases, increasing problem of substance and alcohol abuse among unemployed and disaffected young people, high suicide rates, depression and anxiety, poor maternal and women's health, poor children's health (accidents, injuries, infections, premature death), poor dental and oral health and high levels of multi-morbidity.

2. G&Ts are less likely to receive effective, continuous healthcare including: access to primary care and community care services, maternal and child care, screening and immunisation, and end-of-life and palliative care. Barriers to health care include: racism and discrimination, cultural beliefs, illiteracy, negative experiences, traditional role of the family, inadequate health service provision, and no fixed abode.

3. Children's educational achievements are worse and declining further still due to: lack of access to pre-school, out-of-school and leisure services for children and young people, extremely low participation in secondary education (discrimination, abusive behaviour on the part of school staff and other students are cited as reasons for leaving education at an early age), un-quantified but substantial negative psychological impact on children who experience repeated brutal evictions, family tensions associated with insecure lifestyles, and an unending stream of overt hostility from the wider population.

4. G&Ts have low employment rates and high poverty, accelerated criminalisation at a young age, leading rapidly to custody, lack of access to culturally appropriate support services for people in the most vulnerable situations, such as women experiencing domestic violence, poor sanitation, bad conditions and poor access to clean water.


RECOMMENDATIONS

There is an evidence based need:

1. To develop appropriate, authorised, well planned and managed permanent and transit accommodation sites, in agreement with the local community.
2. To raise awareness of the cultural needs of G&Ts communities among health and other social care service providers as well as the police and the public.
3. For assertive outreach work in order to improve health outcomes for G&Ts. The value of community outreach health projects undertaken in partnership with voluntary sector and local Gypsy and Traveller agencies has been recognised. Evaluations are overwhelmingly positive and indicate significant health gains. However, the majority of projects run for between one and three years with a risk that the health improvement will be lost once they come to an end.
4. For targeted on-site services to children (immunisation, psychological and developmental support), pregnant women (immunisations, screening, psychological support) and to increase male engagement in preventative health care.
5. To provide G&Ts with information and communications in accessible format and with appropriate content.

Thank you for your letter dated 3rd February 2014 regarding the above.

We have looked at the documents and there appear to be no proposals close to the Gateway site. Therefore we have no further comments to make.

The original site list was a total waste of time and resource - conducted in what can only be described as an incompetent manner.
The alternative sites which followed was marginally more enlightened however the assessments were inconsistent and the final "gradings" is mostly poorly justified and certainly inconsistent.

Some of the sites are so blatantly unsuitable that they should never have made it through to any lists, never mind the Preferred Options consultation - eg GT16 in the June consultation and GTalt12 in the PO consultation.

WDC's intention to limit sites to 10 pitches is misguided and short-sighted. We should be minimising the number of locations impacted by this requirement and hence should align with NATIONAL GUIDANCE of 10-15 pitches per site and hence minimise "establishment costs" per pitch.

More attention should be paid to integrating the G&T requirement into the larger land allocations across the district at a very early stage of planning, including within Siskin Drive and Gateway schemes - which are apparently to be removed from Greenbelt designation and hence remove the major objection to date...

The criteria do not appear to have been objectively applied to each of the sites. There are many examples of the same criteria being used for some sites and against others - eg NOISE and proximity to major roads!

Regards proposed Site GT04 - Land at Harbury Lane/Fosse Way

Objections to this site are
1. The proposed site is adjacent to a very busy junction (Fosse Way/Harbury Lane) where in the morning & evening traffic peak traffic backs up in all directions up to half a mile.
2. The junction is now the site of a Road Traffic Collision at least once a week
3. The view from Chesterton Windmill northwards will be spoilt by the proposed site.
4. Doctors surgery is over a mile away
5. Harbury school up to capacity

Suggested better site GT 20 by the M40 as this has better access with New Dispensary Surgery and schools nearby

If GT04 is adopted then think Section 106 monies (i.e. Warwick DC) should be used to fund the installation of traffic lights at the Fosse Way/Harbury Lane junction.

I am writing to object to proposals by Warwick District Council to site permanent Gypsy and Traveller sites near Barford, and suggest the Council considers the former Ford Foundry Car Park in Leamington Spa as a particularly suitable alternative site. The car park is discrete, relatively secure, close to employment opportunities, transit services, shops, schools, Health and Hospital facilities, and Catholic Churches.
In the 2011 census, Gypsy or Irish Travellers (over the age of 16) had the highest proportion of no qualifications for any ethnic group at 60%, higher than for England and Wales as a whole (23%). They also had the lowest proportion of people rating their general health as 'very good' or 'good' at 70% compared to 81% of the overall population of England and Wales. Proximity to good schools for all ages, adult education and health care services are essential if Gypsies and Travellers are to enjoy a more settled lifestyle and the benefits therefrom.
"Religion is of great importance to many Gypsies and Travellers, in terms of their daily lives and through rituals and gatherings. Irish Travellers are often devout Roman Catholics and their children attend Catholic schools. Many go on pilgrimages to Lourdes or in Ireland. Large numbers of Romany Gypsies are now Born-again Christians. They find love and solidarity in the Church and in meeting up with others from across Europe at large Christian conventions." [Bristol City Council's, Gypsies and Travellers - The Truth].
"The Government believes that everyone should have the opportunity of a decent home. Decent homes are a key element of any thriving, sustainable community. This is true for the settled and Gypsy and Traveller communities alike." [HMG, Department for Communities and Local Government, 'Designing Gypsy and Traveller Sites Good Practice Guide'].
"Warwick District Council is required by the National Planning Policy Framework (NPPF) and the Housing Act 2004 to meet the accommodation needs of the population within their area. This includes the needs of the Gypsy and Traveller community and that of Travelling Show People.
To meet this need Warwick District Council (WDC) is committed to allocating sustainable and affordable sites to meet the permanent residential needs of this District's Gypsy and Traveller Community and Travelling Show People through the Local Plan process." [http://www.warwickdc.gov.uk/info/20416/evidence_base/733/gypsy_and_traveller_site_allocations]
Given WDC's commitment to meet "permanent residential needs" I am at a loss to understand why a very small group of itinerant, nomadic people loosely referred to as Gypsies and Travellers, who apparently, in general, contribute less to local or national GDP than the majority of people, being the lowest proportion of economically active at 47%, compared with 63% for England and Wales as a whole, should be given special treatment with the provision of transit camps at which they can stop, do a little bit of business, dump their trash and move on. This seems to be completely at odds with the Government's belief, and WDC's obligations and commitment. Moreover, considering HMG, Department for Communities and Local Government, 'Designing Gypsy and Traveller Sites Good Practice Guide', against the identified sites near Barford, there is a significant mismatch with the Government's advice.
"Gypsy and Traveller families often wish to have small compact and well-managed sites located in areas where they have historically resided and have a network of local family support. Local authorities have in the past tended to provide accommodation in inappropriate areas and the sites have therefore not always been used to their full potential. As with the settled community, Gypsy families prefer clean well-managed sites where there is no fear of retribution from problem families and they can enjoy a peaceful coexistence. [...]. Caution should be used when seeking locations for sites to ensure that they are based on need in a particular area and not the availability of inappropriate land for alternative uses. Traditionally, Gypsy sites have been located on land which is inappropriate for alternative uses and this, in itself, has caused problems both for the Gypsy community and for Site Managers."
Is it racist to say that Gypsy and Traveller camps frequently cause an increase in crime and mess, or is it a statistically supportable statement of fact?
Is the Government's decree to Local Authorities to provide more caravan pitches for Gypsies and Travellers predicated on the view that with more authorised sites there will be less of a problem with land occupied illegally? Is this a policy of appeasement of lawlessness or perhaps a sop to wealthy land owners?
Surely, if people want to spend their lives travelling around in caravans then they must operate within the law and rely on finding people willing to accommodate them - not expect special favours from the state. This politically correct initiative is not only flawed in principle but allows little room for local flexibility where councils are told to find additional sites, even though neighbouring authorities may have surplus sites.
Councils may say that they are forced to carry out the Government's bidding, but that does not excuse genuine consultation and democracy. Simply writing to villagers, and providing displays and meetings, asking how they would feel about a Gypsy and Traveller camp on their patch is only valid if the respondents are acknowledged and their views genuinely considered, even to the extent that it may mean a significant change of plans.
Many decent concerned residents see Gypsies and Travellers as a threat to their peaceful way of life, expressing genuine concern over the impact on crime rates and on the local environment. Is simply expressing such concerns, of itself, unreasonable or racist?
Across Britain there is a grotesque game being played between bureaucrats attempting to force through new sites, against objectors feeling obliged to hire lawyers to make sure submissions do not breach some thought crime which could result in them being disregarded.
Is it racist to say Gypsy and Traveller camps may cause an increase in crime and mess? Not to say that all Gypsies and Travellers are the same - there appears to be an elaborate calibrated class structure with Romany Gypsies looking down on Irish Tinkers who in turn have little time for New Age travellers. It is not right to suggest that all Gypsies and Travellers are criminal or that none of them work for a living.
There is an old fashioned romance for Gypsies which can still exist in reality sometimes, with brightly coloured Gypsy wagons drawn by ponies, and people who undertake honest temporary work for local farmers.
But are there not others who are a complete menace to those in proximity to them? Rather than insulting those who warn of problems, the Government and local authorities should address peoples' concerns.
Obviously, my opinion is epistemological, based on a cursory review of information available through the Internet and observing such people across the country, including, latterly at 'Tournament Fields' [previously an RAF Station and now a housing and business development area], just off the Stratford Road heading southwest out of Warwick.
From the latest (2011) census data just 24% [>14,000] of the 58,000 Gypsy and / or Irish Travellers live in caravans or other mobile or temporary structures. The "Gypsy and Traveller caravan count - January 2011" records:
* The total number of Gypsy and Traveller caravans in England remained broadly level at 18,383 caravans, an increase of 46 caravans since January 2010.
* A total of 6,942 caravans were on authorised public sites, a slight increase of 72 (1%) caravans since the January 2010 an average of 22.2 caravans per site.
* The number of caravans on authorised private sites was 8,332, an increase of 484 (6%) caravans since the January 2010 count - an average of 4.5 caravans per site.
* Caravans on unauthorised developments, on land owned by Gypsies and Travellers, decreased by 195 (8%) to 2,200 since the January 2010 count.
* Caravans on unauthorised encampments, on land not owned by Gypsies and Travellers, decreased by 315 (26%) to 909 since the January 2010 count.
* The average occupancy of an unauthorised encampment is 4.9 caravans per site compared with 3.6 caravans on unauthorised sites on land owned by Gypsies or Travellers.
* Overall, the January 2011 count indicates that 17% of Gypsy and Traveller caravans in England were on unauthorised land and 83% were on authorised land.
* Overall, the count indicates an increase of around 2,500 Gypsy and Traveller caravans in England and Wales since 2005, with a reduced overall percentage on authorised sites and an increase in those on unauthorised sites, despite a significant increase in provision.
Considering Gypsy or Irish Travellers living in England and Wales[1]
The Office of National Statistics analysis of 2011 Census data in response to which 58,000 people selected the Gypsy or Irish Traveller ethnicity option or wrote the same under the 'Other White' category (excluding people who identify as Roma), made Gypsy or Irish Traveller the smallest ethnic group (surveyed) at 0.1% of the England and Wales population. As an ethnic group, they are recognised under the Equality Act 2010 and considered by government and charities to be a vulnerable marginalised group who suffer from poor outcomes.
A higher proportion of Gypsy or Irish Travellers are under the age of 20 (39%) compared with England and Wales overall (24%) with a lower median age of 26, compared with 39 overall.
99% were born in Europe (including 88% in the UK). Their main language is English (or Welsh in Wales) at 91%, similar to that for England and Wales (92%).
20,500 households identified as Gypsy or Irish Traveller and 60% were one-family households. For all households, 45% had dependent children, above the average for England and Wales (29%).
Nearly a quarter, 24% of Gypsy or Irish Travellers, lived in caravans or other mobile or temporary structures, well above the average for England and Wales as a whole at 0.3%. Whole house or bungalow was the most common type of accommodation at 61%. They were more than twice as likely to live in social housing as the overall population of England and Wales (41% compared with 16%) and less likely to own their accommodation outright (21% compared with 26%).
Gypsy or Irish Travellers had the lowest proportion of people rating their general health as 'very good' or 'good' at 70% compared to 81% of the overall population of England and Wales.
Gypsy or Irish Travellers (over the age of 16) had the highest proportion of no qualifications for any ethnic group at 60%, higher than for England and Wales as a whole (23%).
Just under half of Gypsy or Irish Travellers were economically active; the lowest proportion of economically active at 47%, compared with 63% for England and Wales as a whole. Over half of those who were economically active were employed (51% compared to 75% for the total of England and Wales) and 20% were unemployed (compared to 7% for the whole of England and Wales). They had the highest proportion of self employed out of the ethnic groups at 26% compared to 14% for England and Wales. Just over half were economically inactive; the most common reason was looking after the home or family (27%) which was higher than that for England and Wales (11%).
For Gypsy or Irish Travellers (16 and over) in employment, elementary occupations (such as farm workers, process plant workers or service staff) were the most common type of employment at 22% (11% for England and Wales). The second highest occupation was skilled trades at 19% such as agricultural, electric and building trades, higher than England and Wales and all other ethnic groups.
Gypsies and Travellers seem to carry what some might call, 'myths and stereotypes' which may give rise to the prejudices and fears which even some rational people have with regard to the location of camps. Let's consider the debate more closely:
"Travellers are thieves and criminals"
The response from Gypsy and Traveller advocates is to say that in every community there are individuals who engage in criminal activity, but this should not be grounds for making sweeping assumptions - why should all Gypsies and Travellers be associated with anti-social or criminal behaviour? Just because some Gypsies and Travellers are thieves and criminals, doesn't mean they all are - does it? Campaigners on behalf of Gypsies and Travellers claim there is no evidence of higher crime rates amongst Gypsies and Travellers. Perhaps unintentionally, however, such a claim seems to accept that there is evidence of crime rates amongst Gypsies and Travellers at least at the National Average, a view Police, Local Authorities and the victims of crime at the hands of Gypsies and Travellers might be inclined to agree with. It may be coincidental that when caravans park up in an area, reported crime seems to increase,
One bad apple...
The fear and trepidation as well as the social impact and damage on small communities of even just one determined, itinerant criminal, whether stealing from gardens and outbuildings or breaking into houses and business premises, terrorising individuals, can be harrowing to the point of catastrophic. The impact of organised groups taking valuable metals from roof tops, or more dangerously, cable theft, can be financially injurious, often with the brunt of the impact being felt by Churches, Schools, Local Authority and Business premises. The impact on individuals can be life threatening when cables are stolen from road lighting and signaling systems, or railway premises. The impact on the neighbourhood from adverse news and crime statistics discourages visitors from visiting, particularly damaging in an area where employment and economic viability are heavily dependent on tourism and business start-up and innovation.
It is a matter of fact that settled communities, especially relatively 'comfortable' rural and semi-rural communities, have very low or even negligible crime rates. The visitation of just one or two criminals on such areas can have a devastating impact on people as well as crime rates, and when those events coincide with the presence of Gypsies and Travellers it's hardly surprising that people and authorities might jump to conclusions. The juxtaposition of social itinerant transit facilities adjacent to more affluent neighbourhoods is a recipe for disaster - the potential for harm to the community and a consequential increase in crime rates seems inevitable even to the most charitable mind. Sometimes temptation is just too great, and with the provision of transit facilities, where people can stop, do a little business, and move on, perhaps into the jurisdictions of others, can only serve to fuel the untouchable feeling and behaviour of criminal elements. Furthermore, as groups come and go, not settling permanently, the constant feeling of trepidation caused by the natural human reaction to strangers, renders life uncomfortable.
A low crime rate and social amenability is so much a feature of the Barford area that is was recently rated one of the best places to live in Britain, an accolade it would be unlikely to retain if the crime rate rose, and unsightly and unhealthy dumping became a significant problem.
Does Warwick District council really want to site Gypsies and Travellers at Barford, ranked in the top 10 places to live in the Midlands category of The Sunday Times' annual 101 Best Places to Live in Britain? The guide combines crime rates, house prices and school performances to select places with the best quality of life, good local shops and attractive outdoor spaces.
Warwickshire and particularly Barford has a crime rate significantly below the National Average; introducing even a small number of statistically evident criminals into the area is likely to have a detrimental affect on crime rates, and the peace of mind and security of the neighbourhood and its populous.
Advocates say that constantly referring to encampments as "illegal" furthers the perception that travellers are to blame for everything that goes wrong in the neighbourhoods they live in. But then again, squatting at the side of the road or on private land isn't always legal; if it were legal, then how is it that the law moves them on? Making sites 'legal' on its own will not change the anti-social, and even criminal behaviour of determined villains, regardless of their ethnicity.
Campaigners cite the statistic of Gypsies and Travellers in the prison population, saying there are few in prison, however, a cursory review of Police and Court records will reveal another interesting statistic - the frequency with which Gypsies and Travellers fail to answer summonses, submit to arrest warrants and show up in court. When they do answer charges, the prospect they face may be a guilty verdict, but not necessarily a custodial sentence, and there is also anecdotal evidence that, despite alleged prejudices by the Police towards Gypsies and Travellers, Police tend not to prosecute Gypsies and Travellers for minor offences due to the fact that their itinerant lifestyle means they will simply move on.
Campaigners speculate that it may be that ostracising Travellers from the Settled Community has the effect of pushing them to the margins of society and makes them more vulnerable to poverty and anti-social influences. If that was the case, would Gypsies and Travellers not prefer to settle, and object to the provision of what are effectively transit camps.
They leave rubbish everywhere and destroy the countryside.
Humankind produces huge amounts of waste every day. In every community, there are people who are concerned about doing their part for a clean environment, and those who do not care. Press reports of Gypsy Travellers which fuel the stereotype that they destroy the places they stay always outnumber the very rare reports to the contrary - good neighbours rarely make the news.
Even though site residents pay rent and taxes, they do not enjoy the same rights as people in settled housing. Many sites remain poorly serviced, lack proper sanitation, and waste disposal facilities which leaves residents living in squalid conditions they can do nothing to change.
However, there are also a number of sites which are very well managed and cared for by Travellers and local authorities but that doesn't seem worth highlighting in the press.
Gypsy Travellers do not seek out places to live where they are in poverty without access to basic facilities such as water, electricity, and sanitation. Lack of temporary and permanent sites leaves them with no place to go and pushes many families to resort to the only option available - unauthorised encampments. Those then fan the flames of an already tense relationship between Travellers and the settled community resulting in stress and evictions.
Everyone has the right to an adequate standard of living, as enshrined in the Universal Declaration of Human Rights. They are also entitled to culturally appropriate housing that matches their lifestyle.
Due to the lack of interaction between the communities, the media is often the only source of information. Sadly, many journalists are passionate about pursuing negative portrayals of Travellers.
Evidence provided to Select Committee on the importance of site location:
"What is working [in Ireland] are small sites. And they are not placed under flyovers or pylons, or beside sewers, canals or tips; they are placed on proper positioned land, bang within the middle of a settled community, and they are working."
"We would make a strong plea for safeguards to be put in place to ensure that future site development is not located in polluted or hazardous locations, as... many sites are. Not only does this have a negative impact on Gypsies and Travellers health and access to services but it has a profound impact on how they feel they are perceived and treated by the wider community, likewise such locations reinforce the prejudiced perceptions that many in the settled community have of Gypsies and Travellers, such locations are therefore a major impediment to social inclusion.
[1] http://www.ons.gov.uk/ons/rel/census/2011-census-analysis/what-does-the-2011-census-tell-us-about-the-characteristics-of-gypsy-or-irish-travellers-in-england-and-wales-/sty-gypsy-or-irish-travellers.html
I could go on, but I think you get my drift.

Thank you for taking my thoughts into consideration.

CONSULTATION ON GYPSY & TRAVELLER SITES FOR WARWICK DISTRICT

1. CPRE Warwickshire responded to the Options consultation in 2013. At that stage in the process, CPRE supported two locations in principle, which we considered would meet the practical need for about 25 pitches. These locations were
* Siskin Drive, SE of Coventry (adjacent or close to existing Coventry City Council official site)
* Harbury Lane, at Hobson's Choice (preferably where containers are now stored)

2. These two locations are unfortunately not listed among those put forward during the 2013 consultation. The 2014 Preferred Options consultation document at table 5.1 lists sites stated to have been advanced by respondents in 2013, but neither of these is included in the table. CPRE doubts that the need is for as many as 25 pitches by 2017, as stated by the District Council. Gypsies and travellers often hold land in other Districts, which is not made know in the needs surveys; and there is a risk of double-counting between Districts.

3. The comments on sites below assume this figure of 25 pitches; 30 could be provided if necessary at the locations we suggest.

4. CPRE Warwickshire in summary supports the following locations:

* Hobson's Choice, Harbury Lane, SE of Whitnash 15 pitches
* Siskin Drive, by Coventry Airport, S of Coventry City Council official site 10 pitches
* Birmingham Road, Budbrooke up to 5 pitches
GT04 Land at Harbury Lane/Fosse Way

5. This location is supported and was advanced by CPRE in 2013. We do not support the exact location, which would appear to take over or be alongside Leamington Football Club. This would be an exposed position not easily screened. We support the site on the map extract for GT04 called 'Hobson's Choice'. This is surrounded by a high earth bund, and is used currently for container storage. It lies behind Harbury Lane scrapyard and the old airfield hangar used for indoor go-karting. It would be very suitable for up to 15 pitches and would have no adverse effect on the surrounding environment. As Warwick District Council is willing to consider compulsory purchase of land, this site should be examined closely. The container storage activity need not be at this location and industrial land for it could be found elsewhere.

Siskin Drive, E of Coventry Airport

6. The failure to examine the Siskin Drive area further, and the rejection of it in the 2014 document without explanation, is regrettable. The established existence of the Coventry City Council official site at Siskin Drive, with no adverse environmental or social effects, indicates the general suitability of this area east of Coventry Airport. From the point of view of gypsies and travellers the site is also suitable as it has good road access and does not involve use of minor roads, and there are no private houses nearby. While the local authority boundaries at Siskin Drive are complex (Coventry, Warwick and Rugby all meet here), it should be possible for a Warwick District Council site to be located adjacent to or near the Coventry City Council site.

GT19 Birmingham Road, Budbrooke

7. This has had gypsy occupation in the past. The proximity of other buildings here and the non-agricultural nature of the land adjacent to the A4141 Birmingham Road makes this a potentially acceptable location, but only after the two sites listed above have been developed.


Response on other sites included in the 'Preferred' list (Consultation paper section 9) and on those not supported (Section 10, alternative sites)

GT12 W of Barford Bypass N of Shepham Lane

8. This is open countryside along the western side of the A429 Barford Bypass. It would be very visible, difficult to access and damaging to the setting of Barford. It should be dropped.

Gtalt01 Banbury Road, Warwickshire

9. A gypsy site on the historic road approach to Warwick town centre is not acceptable. This is still a classic rural approach to the historic town. The existing permission for caravans (non-gypsy) and the building of the access does not justify allowing this approach to be degraded by an unattractive and intrusive land use. The site is not being used at present and is better left empty so as to protect the historic approach and the setting of Warwick Castle Park.

GT02 Land at Fosse Way / A425

10. This is a large open landscape, between Radford Hill and North Fosse Farm. It is wholly unsuitable as a gypsy site, being very visible agricultural land. It is partly Grade 3a land and is next to a local wildlife site - the wood known as Parlour Spinney.

GT05 Tachbrook Hill Farm, Bishops Tachbrook

11. This is open farmland between the Banbury Road and Bishops Tachbrook village. With the M40 to the SW, the road is busy with traffic on and off the motorway. The junction between the Banbury Road and Mallory Road is not particularly safe; its rural location makes any junction widening or lighting highly damaging to the character of the immediate area.



Gtalt12 Land SE of Barford Bypass, Barford

12. This appears to have no merit at all as a site. The grounds for objection to GT12 (see above) apply equally to this site.

GT06 Park Farm, Banbury Road, Warwick

13. This is a large area of farmland at Park Farm, on the rural approach to the historic town of Warwick. It would be visible and harm this important setting to Warwick. It would be close to Warwick Castle Park. Similar reasons for objection apply to those listed above for Gtalt01, Banbury Road, Warwick.

GT08 Depot W of Cubbington Heath Farm, Cubbington

14. This location is only worth considering if HS2 is built on the line proposed, as it would then be degraded and could be acceptable as a gypsy site.

GT11 Hampton Road, south of Warwick Racecourse

15. The land north of Henley Road and east of A46 Warwick Bypass is part of Warwick's historic setting. Development of South West Warwick stops at the Henley Road. Urban development should not be allowed to cross it.

GTalt02 Woodyard, Cubbington Road, Rugby Road, Cubbington

16. This would be very harmful to the future of CubbingtonWood, which is replanted Ancient Woodland. The consultation document notes, "North Cubbington Wood is one of the prime cases for woodland restoration for the Princethorpe project which is a complex of woods and hedgerows, currently a Warwickshire Wildlife Trust Living landscape project funded by SITA Trust." A gypsy site here would harm the woodland's restoration and make it less attractive for visitors.

Gtalt03 Henley Road, Hampton-on-the-Hill

17. This site is being promoted by the owner. It would be very harmful to the openness of the Green Belt and to the current rural approach to Warwick from Henley-in-Arden if it were to be developed as a gypsy site. The consultation document fails to describe the appearance of this land or its prominence. It is where the Henley road comes over a crest and Warwick is seen on the skyline. It is too prominent a position to be considered.

WDC Local Plan Gypsies & Travellers Preferred Options Consultation


The JPC accepts that allocations must be made for the G&T community within the WDC New Local Plan - rather than relying on sites coming forward through the conventional planning process and we also understand the importance of G&T issues in the Local Plan process, however the JPC believes that any such allocation must be made on a fully democratic and objective basis.

When the June 2013 consultation was staged we were unimpressed with the level of detail provided and very disappointed at the lack of local knowledge and erroneous justifications for selected sites. It can be no surprise that local communities erupted in response to such ill thought-out blight on our district.

Given the levels of residents' responses it is surprising that the Preferred Options consultation has now followed with a similar level of erroneous information and even less quantifiable justification for the Preferred Option choices.

We find the presentation of material confusing at best given that much of the important evidence is buried on the website as "Further Evidence" and "Background" and much that is there is either erroneous and/or conflicting with the March 2014 PO document. At another level we and the vast majority of our residents who have commented found the "Drop-In Sessions" with just a couple of posters and scattered booklets to be a singularly poor way to disseminate information especially as the staff provided had minimal technical knowledge of the subject matter and made it clear that they would not be collating comment made on the day.

We are also concerned at WDC's apparent willingness to rely on the Compulsory Purchase approach given the associated costs and delays which will render most sites non-viable financially and non-deliverable in the terms required. Furthermore success of the CPO process has yet to be established as evidenced by the 2012 Mid Suffolk DC case when the Inspector found insufficient evidence to support CPO on the grounds of "public interest".

We would question WDC's election to limit site sizes to a maximum of 10 pitches, with some considerably less, as this means that site provision must then blight more communities and settlements than is reasonably necessary. If site size limitation is in order to facilitate management and policing this surely gives credence to many residents' concerns about crime and disorder in or near such sites.

Reduction in site size (or more specifically pitch numbers on individual sites) loses economies of scale in terms of establishment costs, management costs and land take whilst directly impacting a greater number of the general population.

National guidance suggests sites of 5-15 to be preferable and this would suggest that our required 31 pitches could reasonably be accommodated in two or at most three sites.

The JPC would suggest that any or all proposed sites could be best accommodated and assimilated in areas which are not current settlements and that they should be properly planned, at a very early stage, into much larger schemes preferably incorporating residential and employment development.

We find the cursory dismissal of such an approach (Page 12, end of section 5) totally unsatisfactory and unacceptable.

The JPC also believes that the Siskin Drive and Gateway area should be vigorously explored to create a site with a mechanism to accommodate the G&T community within an evolving area where they could best integrate with their surroundings.

Whilst reviewing WDC's commentaries on sites in the original and the current consultation we have found that they are erratic and inconsistent. Criteria are sometimes used to support a choice/site and at other times the same criteria are used in a converse manner. The way in which the supporting Sustainability and Sites Assessments have been used to arrive at the Preferred Options is opaque in the extreme and certainly the interpretation of the Sustainability Assessments based on colour coding appears to be minimally objective.

Examples of inconsistencies relate to noise impacts, site prominence in the landscape, flooding, agricultural land value/viability, proximity of services and pedestrian access/safety. Latterly, especially with the "GTalt" sites, there seems to be an inordinate reference to "surface flooding".

The paperwork provided and the public consultations staged also seem to take no or little account of the cost implications inherent in the various Preferred Option choices and we believe this should be a significant factor when making a final selection given the inherent importance of economic viability.

In consideration of the above the JPC has conducted an objective assessment of all the sites which have come forward under these consultations, as well as our lay skills permit, and concludes that not all of the selected Preferred Options are indeed the best sites of those presented.

The findings are presented in spreadsheet format showing support where we believe it to be appropriate. Where we draw different conclusions we offer rebuttal and further comments as seems appropriate and helpful.

The spreadsheet details are as follows:

* Column 1 - Site identification number and PO indication and JPC support or otherwise
* Column 2 - Précis of WDC comments
* Column 3 - JPC commentary
* Column 4 - Sites which JPC consider could reasonably be progressed (where sites cannot be integrated into "larger schemes").

Inevitably the JPC has been much exercised by contact from residents concerning sites proposed within our JPC parishes and we must comment that these sites seem to have been singularly poorly selected. This situation is not helped by the fact that they seem to have come forward accompanied by blatantly incorrect supporting information, viz:
* Repeated reference to Barford doctors' surgery - when the last part-time surgery closed over 30 years ago
* Inclusion of the Barford Bypass flood compensation pond area as site GT16
* Inclusion of Barford Community Orchard and Riverside Walk in GTalt12
* Inclusion of spillage/reed ponds within GT12 in March 2014
* Confusion over the maps for GT12 And GT16 in June 2013
* Confusion over the map of GT12 in March 2014
* Confusion over the map of GTalt12 in March 2014

On a purely local basis it seems bizarre and is certainly unacceptable to blight Barford, recently judged amongst the best 10 places in the Midlands (and number 57 nationally) to live, with the Preferred Options selection of such obviously poor sites. Should the Barford sites persist we are sure that residents will support the landowner in challenging Compulsory Purchase, increasing costs and delay to all concerned and further impacting deliverability.

We are also reminded that there is a duty to co-operate across boundaries and would draw your attention to the site which Stratford DC have at Blackhill, immediately adjacent to Sherbourne parish.

We hope that you will take this letter and the associated spreadsheet in the constructive manner in which it is intended, in order to assist in achieving the best possible solution for both the settled and travelling communities.

see attached

see attached

see attached

see attached

see attached

see attached

see attached

see attached

see attached

see attached

see attached

see attached

see attached

9. Summary of Preferred Option Sites
GT19 (p.42) - OBJECT
Against the Council's own criteria in section 6.1, GT19 fails on the following points.
1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.

Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.
7 Sites which can be integrated into the landscape without harming the character of the area. Site development will accord with national guidance on site design and facility provision FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
10 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
In addition, the commentary and treatment for this site is very one-sided. Firstly this is true as a standalone because factors mentioned in the full site assessment are omitted from the policy document. Secondly there is great inconsistency in the commentary on factors across different sites, which seriously undermines the soundness and confidence in the Council's approach.
For example (referring to the commentary on page 42):
"Site area reduced to avoid other existing uses and retain viability of remaining unit" There is no proof or even indication that this will be the case

"Possible use of existing access points" There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.
How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?
"Services available on site as currently used by Caravan and Camping Club" This is spun as a factor supporting GT19 as a Preferred Site. How does this compare with the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?
"Urban feel" This is subjective. Please explain what the Council means by this?
"A habitat buffer would be required"
Why it is not mentioned that the site is adjacent to Grand Union Canal Local Wildlife Site?
"Subject to agreement with the landowner, this site could be delivered within 5 years."
As the site is not readily available, why is this a Preferred Site?
The following key points have not been mentioned in the commentary within Section 9 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
1) The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this, why has GT19 therefore been proposed as a preferred site?
2) Possible flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly.
3) Part of the site is within high flood risk Zone 3. The proposed site is 0.3 acres in size. With part being within a high flood risk Zone- why does it therefore remain a preferred option?
4) Ecological factors being adjacent to the canal, and the Council's own plans show that this land has a high sensitivity to housing development.
5) Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
6) GT19 is adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
7) The Council recently rejected the proposed development of a similar site owned by Mr Arkwright further west along the Birmingham Road. What is the difference between that site and this one?
8) Reference to the site being located within the Green Belt have been included - however the reference that it has been "previously developed land" is misleading. The previous use of the land was for agricultural purposes.

On top of all this Site GT19 is located in the Green Belt. The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, and the Council has failed to demonstrate any "exceptional" circumstances. It should simply not be promoting any Green Belt site above any non Green Belt site. I am aware of correspondence from a Warwick DC officer in the consultation round in July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable because the need can be clearly met from non Green Belt sites.
Site GT19 is clearly unsuitable for this use. There are fundamental questions outlined above that I would like a response from Council officers on please.
Please respond to this point about the Green Belt and other questions that have been asked above.
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
GT19 - there is no mention that Mr Butler, the current owner of GT19, is not prepared to sell the land to the Council. A fact which he has told all Hatton Park Residents - and was confirmed by Clare Sawdon in the recent Hatton Park Action Group meeting of March 2014.
By comparison Sites GT02, GT05, GT06, GT08 and GTalt12, all in the Alternative Sites list, all say "the land owner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward."
This, rather than sound planning reasons, seems to be the principal factor in the Council's site selection process. You are not fully or fairly representing the situation by omitting this information in this case.
Please could Council officers explain this inconsistency? Please can Council officers explain the selection process between Preferred and Alternative sites?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
GT19 - Within the Detailed Gypsy and Traveller Site Assessments it has been noted that "the site is adjacent to the Grand Union Canal Local Wildlife Site." This comment has not been included within Section 7 and the site remains a preferred option.
By comparison there are numerous other cases where the sites' proximity to a LWS has been included within the commentaries in Section 7.
Please could Council officers explain this inconsistency?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
GT19 - "Services available on site as currently used by Caravan and Camping Club " has been presented as a positive factor.
By comparison:
GTalt22 - "As a Caravan and Camping Club site, this use would not be suitable"
Please could Council officers explain this?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
A fundamental flaw in this draft policy is that there is no explanation of why some 'green' sites are in Preferred Sites and others are Alternative Sites.
Could Council officers please explain this shortlisting process, and provide copies of scoring sheets?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
We are aware that the Council recently rejected the proposed development of a similar site between the canal and Birmingham Road owned by Mr Arkwright, closeby to the west along the Birmingham Road.

How does the Council reconcile the refusal of this proposal with listing GT19, a similar nearby site, as a Preferred Site?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
Given the congestion, how does the Council think that the movement of large vehicles into and out of the site will be managed?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
1. Ecological factors are important as the site is adjacent to the canal, and occupation / development of this site will impact on the visual amenity of the Grand Union Canal.
2. The Council's own plans show that this land has a high sensitivity to housing development.
3. The Grand Union Canal Local Wildlife Site is adjacent to the site.

Why was point 3 not mentioned in Section 7 of this document? Why is GT19 proposed as a Preferred Site given this sensitivity?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
There is the possibility of flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly. Part of the site is within high flood risk Zone 3 (the proposed site is only 0.3 acres in size).

With part being within a high flood risk Zone- why has GT19 therefore been proposed as a preferred site?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this.
Why has GT19 therefore been proposed as a preferred site?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states:
"Services available on site as currently used by Caravan and Camping Club"
This is seemingly presented as a factor supporting GT19 as a Preferred Site.
Please explain to me the treatment of this factor compared to the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states as a supporting factor:
"Possible use of existing access points"
1. There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.
2. How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states:
"Site area reduced to avoid other existing uses and retain viability of remaining unit"
There is no proof or even indication that this will be the case
What evidence is the Council using to make this statement? Please respond.
7. Sites Summary Table
GT19 - OBJECT
Against the Council's own criteria in section 6.1, GT19 fails on the following points.
1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.

Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.

7 Sites which can be integrated into the landscape without harming the character of the area. Site development will accord with national guidance on site design and facility provision FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.

8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
10 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
Why is GT19 a Preferred Site? Please respond.
7. Sites Summary Table
OBJECT
As a general point, but with specific regard to site GT19. the commentary and treatment are very one-sided:
1. As a standalone because factors mentioned in the full site assessment for GT19 are omitted from the policy document - this misrepresents the site characteristics
2. There is great inconsistency in the commentary on factors across different sites. For example the phrase "Services available on site as currently used by Caravan and Camping Club" is used as a supporting factor in GT19 but a negative factor for GTalt22.
How can this be? This seriously undermines the soundness and confidence in the Council's approach
3. Warwick District - Context
3.6 - OBJECT
The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, not "special". This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should simply not be promoting any Green Belt site above any non Green Belt site.
I am aware of correspondence from a Warwick DC officer in the consultation round in July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable.
3. Warwick District - Context
3.5 - OBJECT
The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, not "special". This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should simply not be promoting any Green Belt site above any non Green Belt site.
I am aware of correspondence from a Warwick DC officer in the consultation round in July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable.

WDC Local Plan Gypsies & Travellers Preferred Options Consultation


The JPC accepts that allocations must be made for the G&T community within the WDC New Local Plan - rather than relying on sites coming forward through the conventional planning process and we also understand the importance of G&T issues in the Local Plan process, however the JPC believes that any such allocation must be made on a fully democratic and objective basis.

When the June 2013 consultation was staged we were unimpressed with the level of detail provided and very disappointed at the lack of local knowledge and erroneous justifications for selected sites. It can be no surprise that local communities erupted in response to such ill thought-out blight on our district.

Given the levels of residents' responses it is surprising that the Preferred Options consultation has now followed with a similar level of erroneous information and even less quantifiable justification for the Preferred Option choices.

We find the presentation of material confusing at best given that much of the important evidence is buried on the website as "Further Evidence" and "Background" and much that is there is either erroneous and/or conflicting with the March 2014 PO document. At another level we and the vast majority of our residents who have commented found the "Drop-In Sessions" with just a couple of posters and scattered booklets to be a singularly poor way to disseminate information especially as the staff provided had minimal technical knowledge of the subject matter and made it clear that they would not be collating comment made on the day.

We are also concerned at WDC's apparent willingness to rely on the Compulsory Purchase approach given the associated costs and delays which will render most sites non-viable financially and non-deliverable in the terms required. Furthermore success of the CPO process has yet to be established as evidenced by the 2012 Mid Suffolk DC case when the Inspector found insufficient evidence to support CPO on the grounds of "public interest".

We would question WDC's election to limit site sizes to a maximum of 10 pitches, with some considerably less, as this means that site provision must then blight more communities and settlements than is reasonably necessary. If site size limitation is in order to facilitate management and policing this surely gives credence to many residents' concerns about crime and disorder in or near such sites.

Reduction in site size (or more specifically pitch numbers on individual sites) loses economies of scale in terms of establishment costs, management costs and land take whilst directly impacting a greater number of the general population.

National guidance suggests sites of 5-15 to be preferable and this would suggest that our required 31 pitches could reasonably be accommodated in two or at most three sites.

The JPC would suggest that any or all proposed sites could be best accommodated and assimilated in areas which are not current settlements and that they should be properly planned, at a very early stage, into much larger schemes preferably incorporating residential and employment development.

We find the cursory dismissal of such an approach (Page 12, end of section 5) totally unsatisfactory and unacceptable.

The JPC also believes that the Siskin Drive and Gateway area should be vigorously explored to create a site with a mechanism to accommodate the G&T community within an evolving area where they could best integrate with their surroundings.

Whilst reviewing WDC's commentaries on sites in the original and the current consultation we have found that they are erratic and inconsistent. Criteria are sometimes used to support a choice/site and at other times the same criteria are used in a converse manner. The way in which the supporting Sustainability and Sites Assessments have been used to arrive at the Preferred Options is opaque in the extreme and certainly the interpretation of the Sustainability Assessments based on colour coding appears to be minimally objective.

Examples of inconsistencies relate to noise impacts, site prominence in the landscape, flooding, agricultural land value/viability, proximity of services and pedestrian access/safety. Latterly, especially with the "GTalt" sites, there seems to be an inordinate reference to "surface flooding".

The paperwork provided and the public consultations staged also seem to take no or little account of the cost implications inherent in the various Preferred Option choices and we believe this should be a significant factor when making a final selection given the inherent importance of economic viability.

In consideration of the above the JPC has conducted an objective assessment of all the sites which have come forward under these consultations, as well as our lay skills permit, and concludes that not all of the selected Preferred Options are indeed the best sites of those presented.

The findings are presented in spreadsheet format showing support where we believe it to be appropriate. Where we draw different conclusions we offer rebuttal and further comments as seems appropriate and helpful.

The spreadsheet details are as follows:

* Column 1 - Site identification number and PO indication and JPC support or otherwise
* Column 2 - Précis of WDC comments
* Column 3 - JPC commentary
* Column 4 - Sites which JPC consider could reasonably be progressed (where sites cannot be integrated into "larger schemes").

Inevitably the JPC has been much exercised by contact from residents concerning sites proposed within our JPC parishes and we must comment that these sites seem to have been singularly poorly selected. This situation is not helped by the fact that they seem to have come forward accompanied by blatantly incorrect supporting information, viz:
* Repeated reference to Barford doctors' surgery - when the last part-time surgery closed over 30 years ago
* Inclusion of the Barford Bypass flood compensation pond area as site GT16
* Inclusion of Barford Community Orchard and Riverside Walk in GTalt12
* Inclusion of spillage/reed ponds within GT12 in March 2014
* Confusion over the maps for GT12 And GT16 in June 2013
* Confusion over the map of GT12 in March 2014
* Confusion over the map of GTalt12 in March 2014

On a purely local basis it seems bizarre and is certainly unacceptable to blight Barford, recently judged amongst the best 10 places in the Midlands (and number 57 nationally) to live, with the Preferred Options selection of such obviously poor sites. Should the Barford sites persist we are sure that residents will support the landowner in challenging Compulsory Purchase, increasing costs and delay to all concerned and further impacting deliverability.

We are also reminded that there is a duty to co-operate across boundaries and would draw your attention to the site which Stratford DC have at Blackhill, immediately adjacent to Sherbourne parish.

We hope that you will take this letter and the associated spreadsheet in the constructive manner in which it is intended, in order to assist in achieving the best possible solution for both the settled and travelling communities.

Preferred Site GT04 for Gypsies and Travellers (G&T)

We wish to object to the Gypsy and Traveller preferred site GT04 Land at Harbury Lane, Fosse Way.

My reasons are as follows;

1. The National Planning Policy Framework (March 2012) (NPPF) requires that the assessment of site suitability should be consistent with other planning requests. WDC will recall that I attempted to obtain planning permission for a further extension to our property. This was rejected because it would have an "adverse impact on the character of the area". How can WDC now say that the construction of a site for 10 -20 caravans would not similarly have an adverse impact in the character of the area. This would be entirely inconsistent and therefore against NPPF and would be discrimination against me.

2. GT04 does not comply with the planning criteria laid out in the NPPF nor PPFTS nor indeed the criteria laid out WDC's own consultation documents for Gypsy & Traveller sites. In no way does GT04 comply with planning policy whereby sites should provide satisfactory access to nearby services and quality of life. Specifically:-

- Accessibility to shops and local services: GT04 does not meet the NPPF guidelines nor those of Dept. or Communities and Local Government (CLG) Planning Policy for Travellers sites (PPFTS) (March 2012) recommended 5-10mins walk on a pavement. There is no pavement on Harbury Lane and the width of the road and proximity of hedgerows would prevent the construction of one. The cost of building a pavement would be very high. But even if a pavement were in place, it would still be a 40-45 minute walk to the nearest shop and local services

- the published Planning policy for Gypsy & Traveller sites requires that schools / GP surgeries are a 5-10 minute walk away. Those closest to GT04 are at least a 45 minute walk away along unlit roads with no pavement. The nearest GP surgery is three miles away and that surgery is at capacity. Also not only are the nearest primary, junior and senior school 40 + minutes away on foot but they are all already at capacity.

-Proximity to local community: GT04 does not meet the NPPF or PPFTS guidelines recommendation for sites to be on at least the edge of a community to encourage integration. Indeed GT04 is of all the current 5 preferred sites furthest from any community and services

- The NPPF and PPFTS make it very clear that the size of sites should not be disproportionate to the local community. However WDC propose to Establishing 5-10 pitches at GT04 which using the GTAA figures of 1.6 caravans per pitch and four individuals per caravan would give a population of between 32 and 64 individuals in area where the local community consists of 8 residential properties, with 16 adults and 4 children. The scale of the proposed GT04 development is therefore clearly and grossly disproportionate to the local community and this is therefore contradictory to the NPPF & PPFTS guidelines and recommendations.

- GT04 does not meet the NPPF or PPFTS guidelines and recommendations for access to good local transport. There is a limited bus service along Harbury lane and there are no bus pull ins or indeed anywhere for people to stand whilst waiting for a bus. Both potential passengers and car drivers would be placed at significant risk.

- It follows from the above that GT04 does meet the NPPF and PPFTS guidelines and recommendations for availability of good infrastructure. This includes roads, pavement, street lighting, broadband, cell phone reception. Harbury lane is a narrow and already very busy and dangerous road. It has no pavement. There is no street lighting along it between the boundary with Whitnash and Harbury Village. The infrastructure at GT04 is poor and would require considerable investment to rectify.

3. Other planning issues:

The area is prone to flooding with Harbury Lane and surrounding fields are often under water. GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based (there is solid clay less than 300mm from the surface) and will therefore require connection to mains sewerage which does not exist in Harbury Lane. Simply it would not be possible to provide satisfactory drainage for 60 individuals.

-GT04 is located on Harbury Lane and close to the cross road with the Fosse Way which is a high risk travel route with high volumes of traffic and an increasing number of accidents. Speed cameras and warning signs highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to school if indeed such transport exists
- when WDC granted planning permission for the chicken farm at Barnwell farm (200m from GT04), the applicants documents contained detailed aroma maps. These clearly show that GT04 is within the zone of the densest aerial discharges from the Barnwell Chicken farm. Not only is the odour extremely unpleasant but the proximity to GT04 raises serious environmental and health concerns for its potential residents. We understand that this was a primary reason that the potential G&T site at Barnwell farm was previously rejected.
- another environmental issue is that GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and which would make GT04 an unpleasant place to live but also an unhealthy one.

- GT04 is an area of good quality farmland fully utilised for livestock and arable farming.

- GT04 will lack of Integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire and will have an adverse visual impact from Harbury and The Fosse Way (Roman Road).

- the development of GT04 would mean that that private vehicles would have to be used to access shops and local services thus adding to traffic on an already busy and dangerous road but also causing unnecessary environmental damage.

- The site will damage wildlife habitat -in recent years we have had a strong growth in the population of birds of prey (kestrels, Buzzards and owls) and also Muntjac deer. A permanent residential presence is sure to scare these animals away.

4. Alternative Sites

I believe there are more suitable sites that have not been raised by WDC.
These areas of Land are as follows;
a. Land off Poiseden way and Spartan close. Travellers regularly use this area.
b. Land off Dobson Lane Whitnash. Located at the back of the cemetery and Whitnash school.
Both the sites are walking distance from schools and other essential local amenities.

Sites for Gypsies and Travellers - Preferred Options

I refer to your letter of 17th March 2014.

The Parish Council have now had an opportunity to discuss the above proposals and wish to submit the following comments.

It is noted that areas of land off Leicester Lane, Cubbington (ref. GTalt07) and Welsh Road, Cubbington (ref. GTalt10) have been discounted but that the depot area off Leicester Lane, Cubbington to the west of Cubbington Heath Farm (ref. GT08) and land off Rugby Road, Cubbington (ref. GTalt02) have been classified as 'Amber' sites and shortlisted as they could be made suitable if major changes were made. It is understood that these two areas are not deemed to be Preferred Options which will be brought forward during the life of the Local Plan.

As was pointed out in my letter of 10th July 2013 to you, the depot site is owned by the Cubbington Freeholders charity. The Parish Council strongly support the concerns raised by the Freeholders who are anxious to ensure that the charity are able to continue with the extremely valuable financial support that they have been able to provide to local organisations over many years. Their work is invaluable to the well-being of the local community and the Parish Council are opposed to any action being taken which would be detrimental to the interests of the Freeholders and, through them, the community and our local organisations.

The National Planning Policy Framework (NPPF), which sets out guidance on the government's aims in respect of sites for travellers, states that sites must enable occupants to access education, health, welfare and employment infrastructure and that local planning authorities must have due regard to the protection of local amenity and local environment. It is not clear what access to education, health and welfare would be available to the gypsy and traveller community in respect of the depot area. It is also questionable as to whether the site is an appropriate location given the highway safety issues that may result from accessing and egressing this site on to the A445. The Parish Council believe that this site is not sustainable in terms of access to public transport and health facilities. Currently there is no bus service accessible from the site and the nearest doctors' surgery is in Lillington.

In addition, the Parish Council also believe that the use of this area of land for a gypsy and traveller site would potentially create noise and disturbance to the nearby residents. The use of the area for this purpose would also have a detrimental impact on the wildlife and would, therefore, be in contravention of the NPPF guidance.

There is a suggestion that, as a result of a previous use of the land, it could be heavily contaminated and there would be significant expense in making it safe for residential use. It would require treatment before it was suitable for occupation.

For these reasons, the Parish Council, continue to oppose strongly the suggestion that the land could become a site for travellers and gypsies.

With regards to the area off Rugby Road (ref. GTalt02), the Parish Council are concerned that the possible future use of this land would involve incorporating an area of North Cubbington Wood. This is ancient woodland which is already under severe threat as a result of the HS2 proposals. The Parish Council believe that the site is unsuitable taking into account the criteria that sites identified for use must not have an adverse impact on important features of the natural and historic environment. The site also does not have convenient access to a GP surgery and public transport which would be in contravention of the National Planning Policy Framework referred to above.

The Parish Council are aware that if any of the sites which have been deemed suitable for further public consultation and comment are then rejected, the sites currently classified as 'Amber' could well come under consideration. We are anxious, therefore, that our comments should be taken into consideration with a view to these two 'Amber' sites in Cubbington being discounted.

Allied to this issue, we would question why it is necessary to provide sites within the district when there is, we understand, a site in the Ryton area which is underused? An explanation regarding this point would be appreciated please.

New Local Plan - Permanent Gypsy site selection
GT12 / GTalt 12

As a local resident in Wasperton we wish to object to the possible choice of this site on the basis of safety, lack of local facilities and loss of valuable farming land.

1. The main road past the site is the major route to the Cotswolds. The site is on a long sweeping bend where most traffic travels above the legal speed limit of 60mph, even past the second Barford turning. This stretch of road is highly tempting to impetuous drivers who often overtake slower vehicles travelling at 50pmh. The only safe solution will be to build it as a dual carriageway.
2. The possible solution could be to put up traffic lights or a large pull-off stretch but then the Traveller will be faced with towing a long vehicle across the heavy stream of traffic with all the inherent dangers.
3. Travellers wishing to visit Barford, say to take children to school, will have to cross this major road with all the dangers of attempting to slow the traffic.
4. Vehicles and trailers exiting GT12 turning either right or left will face the danger of being rammed unless lights are installed.
5. Personally speaking we have been involved with three similar incidents when turning into Wasperton with drivers overtaking double lines to gain additional road space. Sight lines will be similarly restricted opposite the suggested GT12 site.
6. This site will require efficient drainage and a soak-away which will also require regular servicing. Can we trust the travelling community to commission this work or will seepage occur into the River Avon which is very close by?

7. The local plan suggests that there is a Doctors surgery in Barford. This is not correct, the nearest we believe is in Wellesbourne.
8. The local facilities are confined to a local shop in Barford and shops in Wellesbourne. The latter Town is currently been expanded with 1600 houses on the airfield and would be highly suitable for a traveller site as the Town sits in open countryside where traffic has to travel at slower speeds (4 Roundabouts currently on the main road).
9. The Local school in Barford is already at a maximum capacity and is located on a restricted site. Any further expansion will require the local authorities to relocate at considerable expence.
10. This GT12 site sits in the middle of highly productive farming land which has already been badly affected by the essential building of the Barford Bypass. This choice will have a detrimental effect on the local economy.

In conclusion, and certainly not on a NIBI basis, The choice of a site should surely be measured against just how well the Travelling community will fit into the local environment without endangering life and limb or that very environment itself. GT12 is in a dangerous position which will require considerable cost to make safe. It has not got local facilities to hand and will damage local industry. There must be a simpler and better solution to this issue and we look to you, our local government, to provide a sensible answer.

Preferred Site GT04 for Gypsies and Travellers (G&T)

We wish to object to the Gypsy and Traveller preferred site GT04 Land at Harbury Lane, Fosse Way.

My reasons are as follows;

1. The National Planning Policy Framework (March 2012) (NPPF) requires that the assessment of site suitability should be consistent with other planning requests. WDC will recall that I attempted to obtain planning permission for a further extension to our property. This was rejected because it would have an "adverse impact on the character of the area". How can WDC now say that the construction of a site for 10 -20 caravans would not similarly have an adverse impact in the character of the area. This would be entirely inconsistent and therefore against NPPF and would be discrimination against me.

2. GT04 does not comply with the planning criteria laid out in the NPPF nor PPFTS nor indeed the criteria laid out WDC's own consultation documents for Gypsy & Traveller sites. In no way does GT04 comply with planning policy whereby sites should provide satisfactory access to nearby services and quality of life. Specifically:-

- Accessibility to shops and local services: GT04 does not meet the NPPF guidelines nor those of Dept. or Communities and Local Government (CLG) Planning Policy for Travellers sites (PPFTS) (March 2012) recommended 5-10mins walk on a pavement. There is no pavement on Harbury Lane and the width of the road and proximity of hedgerows would prevent the construction of one. The cost of building a pavement would be very high. But even if a pavement were in place, it would still be a 40-45 minute walk to the nearest shop and local services

- the published Planning policy for Gypsy & Traveller sites requires that schools / GP surgeries are a 5-10 minute walk away. Those closest to GT04 are at least a 45 minute walk away along unlit roads with no pavement. The nearest GP surgery is three miles away and that surgery is at capacity. Also not only are the nearest primary, junior and senior school 40 + minutes away on foot but they are all already at capacity.

-Proximity to local community: GT04 does not meet the NPPF or PPFTS guidelines recommendation for sites to be on at least the edge of a community to encourage integration. Indeed GT04 is of all the current 5 preferred sites furthest from any community and services

- The NPPF and PPFTS make it very clear that the size of sites should not be disproportionate to the local community. However WDC propose to Establishing 5-10 pitches at GT04 which using the GTAA figures of 1.6 caravans per pitch and four individuals per caravan would give a population of between 32 and 64 individuals in area where the local community consists of 8 residential properties, with 16 adults and 4 children. The scale of the proposed GT04 development is therefore clearly and grossly disproportionate to the local community and this is therefore contradictory to the NPPF & PPFTS guidelines and recommendations.

- GT04 does not meet the NPPF or PPFTS guidelines and recommendations for access to good local transport. There is a limited bus service along Harbury lane and there are no bus pull ins or indeed anywhere for people to stand whilst waiting for a bus. Both potential passengers and car drivers would be placed at significant risk.

- It follows from the above that GT04 does meet the NPPF and PPFTS guidelines and recommendations for availability of good infrastructure. This includes roads, pavement, street lighting, broadband, cell phone reception. Harbury lane is a narrow and already very busy and dangerous road. It has no pavement. There is no street lighting along it between the boundary with Whitnash and Harbury Village. The infrastructure at GT04 is poor and would require considerable investment to rectify.

3. Other planning issues:

The area is prone to flooding with Harbury Lane and surrounding fields are often under water. GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based (there is solid clay less than 300mm from the surface) and will therefore require connection to mains sewerage which does not exist in Harbury Lane. Simply it would not be possible to provide satisfactory drainage for 60 individuals.

-GT04 is located on Harbury Lane and close to the cross road with the Fosse Way which is a high risk travel route with high volumes of traffic and an increasing number of accidents. Speed cameras and warning signs highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to school if indeed such transport exists
- when WDC granted planning permission for the chicken farm at Barnwell farm (200m from GT04), the applicants documents contained detailed aroma maps. These clearly show that GT04 is within the zone of the densest aerial discharges from the Barnwell Chicken farm. Not only is the odour extremely unpleasant but the proximity to GT04 raises serious environmental and health concerns for its potential residents. We understand that this was a primary reason that the potential G&T site at Barnwell farm was previously rejected.
- another environmental issue is that GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and which would make GT04 an unpleasant place to live but also an unhealthy one.

- GT04 is an area of good quality farmland fully utilised for livestock and arable farming.

- GT04 will lack of Integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire and will have an adverse visual impact from Harbury and The Fosse Way (Roman Road).

- the development of GT04 would mean that that private vehicles would have to be used to access shops and local services thus adding to traffic on an already busy and dangerous road but also causing unnecessary environmental damage.

- The site will damage wildlife habitat -in recent years we have had a strong growth in the population of birds of prey (kestrels, Buzzards and owls) and also Muntjac deer. A permanent residential presence is sure to scare these animals away.

4. Alternative Sites

I believe there are more suitable sites that have not been raised by WDC.
These areas of Land are as follows;
a. Land off Poiseden way and Spartan close. Travellers regularly use this area.
b. Land off Dobson Lane Whitnash. Located at the back of the cemetery and Whitnash school.
Both the sites are walking distance from schools and other essential local amenities.