Whilst many will be relieved that this provision may be provided outside WDC area it is NOT REALISTIC to believe that it will stop the informal camps such as we continually suffer in this area.

Gtalt01
I make the following comments on this site.
* It has previously been granted planning permission as a touring caravan site which is a similar use in many respects to the proposed use as a gypsy and traveller site for permanent residence, and therefore with careful adaption it can conceivably be suitable for the proposed purpose.
* Re-engineering of the highway has been completed already allowing the site to be established quickly to help deal with the need identified.
* With appropriate screening this site can be established without causing a high visual impact. This is particularly important when considering the historic setting of Warwick Castle and also that this route into historic Warwick is not compromised.
* There is access on foot into Warwick which offers a range of services and amenities, adding to the site's sustainability, however the footpath would need to be improved to provide pushchair and wheel chair access.

GT15
I object to this site being considered as a gypsy and traveller site, for the following reasons:
* Whilst sight lines appear adequate, constructing as safe access for large articulated vehicles onto the very busy Europa Way will be expensive.
* It is proposed that Europa Way will be widened into a dual carriageway. This is likely to reduce the usable area of the proposed site.
* The establishment of vehicular access and hard-standings for park homes and the storage of touring caravans with require the removal of significant amounts of the existing vegetation. This will open up views into the site from both the historic footpath from Bishop's Tachbrook to Warwick and also from the proposed Country Park, south of Harbury Lane. This will create negative visual impacts across the rural landscape of the Tachbrook Valley.
* There will be an unknown impact on the ecology of the Tachbrook which is an important wildlife corridor linking with the Avon.

Alternative Options

GT05
I believe this site should be removed from any further consideration as a site for development as a permanent gypsy and traveller site, for the following reasons.
* A safe access cannot be constructed from the Banbury Road onto the site. This is a fast road with adequate site lines and is has a poor record for accidents.
* There is not adequate access on foot to village amenities.
* The owner is known to be unwilling to sell and I do not support compulsory purchase in these circumstances, for the reasons given below.
* This site has high landscape value according the resent WCC Landscape Ecology and Geology report completed on behalf of the District Council in support of the New Local Plan process and therefore it would be wrong for this to be developed
* The site is highly visible from a long section of Banbury Road and also Mallory Road
* There are potential negative impacts on the listed Tachbrook Hill Farm House and also Greys Mallory house.


GT06
I also believe this site should be removed from any further consideration as a gypsy and traveller site.
* It is rated as amber and therefore has a number of unresolved issues associated with it.
* Both the owner of the proposed site, and the owner of the adjacent site that could provide access are known to be unwilling to sell. Therefore compulsory purchase would be required which I object to in principle for the reasons given below but also because CPO would be a long and lengthy route to acquisition of the site, delaying significantly the delivery of the pitches required.
* The proposed site has a very open aspect and therefore would create a visual impact on the route into historic Warwick
* There is no suitable access onto the site. The creation of the access will exacerbate visual impact and require the removal of a significant length of hedgerows damaging the natural habitat for animals and plants.
* There is no access on foot to key services and amenities. The nearest bus stop is 1/2 mile away but there is not footpath meaning residents would have to walk to the bus stop along a busy road. Therefore this site is not sustainable.
Compulsory Purchase
I object to the use of a CPO to acquire any site against the owner's wishes, for the following reasons:
* The CPO process is long and protracted. This will lead to a long delay in making the necessary pitches available.
* It seems to me that it is immoral, oppressive and draconian that a private owner of a piece of land can be forced to sell that land to the district council so that it can then be sold onto a landlord for commercial gain. CPO should be reserved only for infrastructure projects that are critical for a region or sub region.
Proposed Operating Model
* Any site that is delivered for permanent use by gypsy and travellers should either be operated by the district council or a specialist housing association. The district's intension sell sites onto private landlords for their operation is a high risk strategy and is not acceptable, because the resolution of any poor practices or planning breaches would be long and protracted and would lead to tension arising will the local settled community and this would undermine the district's objectives.

The policies set out in the March 2014 Preferred Options should be refined to improve the decision making process and to help towards arriving at a successful outcome - and one that can be seen as "sound" when subject to Examination in Public.

Policy 1 - to distribute the sites evenly across the District.
This is not only in the interests of the existing settled communities, but more importantly of the G & T family groups themselves.
They will benefit, from not being "bunched " in the southern area which covers only a fifth of the District. G & T groups should not be put in a position where they are in competition with each other for services, schooling or business opportunities.
Most of the proposed sites are remote from Coventry, Kenilworth and northern section of the Fosse Way where much of their traditional activities have been centred.

Policy 2 - only one site should be allocated to any given parish. This make sense in terms of acceptance by the local community, and encouraging the possibilities for positive social contacts with the newcomers. Local services and resources like schools and doctors surgeries, have a much better chance of coping if only one G & T group has to be taken care of.

Policy 3 - sites to be limited to between 5 and 7 pitches - original government advice was 5 to 15 pitches per site, but in para 2.1.2 the report states that "advice has been amended and the lower end of this scale is now recommended". However the Preferred Options ignores this policy by listing 13 of the 15 "preferred"sites to take 15 pitches.

Considering these 3 policies and applying them to the Preferred Options, the following conclusions emerge:-

2.1 Only one site to be in the parish of Bishop's Tachbrook. In this case GTalt01 Brookside Willows is the least worst but should be limited to 5 pitches.

2.2 It is difficult to understand why GT06 at Park Farm is designated AMBER - it is flat and could be easily accessed from the M40 slip road - so if Gtalt01 fails, then this site should be the next in line for this parish.

3.1 The possible selection of GT04 should not be contingent on the football club being relocated. It is highly questionable whether the football club would be better off on a new site - there are many strong reasons for not moving it. But the point here is that the original GT04 meets many of the criteria in para 6; and within that larger extent a suitable site could be identified, probably with access onto the Fosse.

4.1 GT08 in Cubbington should be reinstated as GREEN and "preferred". It's on previously developed land and meets nearly all the criteria.

5.1 Likewise GT01 at Siskin Drive should be reinstated. In the event that Gateway does get the go-ahead, a condition must be that that this large area must provide G & T site as an alternative to GT01.

6.1 At least one small site has to be found in the green belt in the west of the District - see Policies 1 and 2 above. But GT19 looks wrong for reasons of access and proximity of local businesses- and should be regraded as RED.


Site Size

It has become clear through the consultation period that each pitch on a designated site should be sufficient to allow for at least 2 caravans, parking and turning space for several vehicles and outside washing /toilet facilities. The area quoted is 500 sq. m.per pitch. In terms of this space requirement and the noise and activity that will arise, it is understandable that the recommendation is for small sites. The target should therefore be to select sites for 5 -7 pitches rather than 10 to 15.


Conclusion

For WDC to plan for 5 sites spread around the District @ 5 pitches each. To allow for 31 pitches post 2021, one other alternative site for future development to be listed OR 2/3 of the 5 sites to be earmarked for expansion up to 7 pitches.

See attached