Too much attention has been paid to the Greenbelt paradigm - given that G&T need is seen to be exceptional enough to trigger POSITIVE DISCRIMINATION in planning it should also be exceptional enough to more imaginatively explore options within the Greenbelt.

There is no clear evidence that criteria are weighted according to their importance - eg the Greenbelt seems to be over-dominating in making decisions, as is access to major roads. More attention should be paid to impact on landscape, impact on agricultural economies and the safety for pedestrian access to and from the sites.

Given the distribution and size of sites proposed by Warwick District Council significant cumulative effects on the settled community in Stratford-on-Avon District are considered to be unlikely. However it is suggested that Policy PO3 is amended to recognise the need to consider the potential for cumulative effects on the settled community when determining future planning applications.
This is consistent with 'Planning Policy for Traveller Sites' (DCLG, March 2012). This states in part that: "local planning authorities should ensure that their policies: a) promote peaceful and integrated co-existence between the site and local community and f) avoid placing undue pressure on local infrastructure and services".
Whilst the anticipated impacts of the preferred sites on Stratford-on-Avon are likely to be minor, the Council's position may change should the next version of the document bring forward a greater number of sites that cumulatively would have a more significant impact on the settled community in Stratford-on-Avon District.

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.

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