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WARWICK GYPSIES AND TRAVELLERS SITES - PREFERRED OPTIONS CONSULTATION
We write on behalf of Taylor Wimpey UK Ltd in respect of the Warwick District Council Gypsies and Travellers Preferred Options consultation document. Whilst there is an identified need to be met for Gypsies and Travellers either living in or passing through the area, it is imperative that the preferred sites are located where they embrace opportunities for community cohesion and maximise the accessibility of services for all.
Preferred site at land north of Westham Lane, Barford (site GT12)
We note that, despite our previous representations, site GT12 has now been recognised as a preferred site by the Council for meeting the Gypsy and Traveller need over the Plan period. In our view the assessment has remained silent on a critical issue in relation to this site, namely its location on the opposite side of the bypass to the village and subsequent separation from many of the services and facilities on which its residents will be reliant.
As noted in our previous representations, the A429 opened in February 2007 and is considered to clearly mark the western edge of Barford settlement in its current form. It is considered that the A429 has a significant impact on the ability of any sites to the west of it to meet the aims for future Gypsy and Traveller site provision as set out in the Planning Policy for Traveller sites (March 2012) document produced by DCLG. Whilst the DCLG guidance has been referred to in paragraph 1.2 of the Preferred Options consultation document we would draw particular attention to the following specific requirements, namely that the Local Planning Authorities should:
* promote peaceful and integrated co-existence between the site and the local community;
* ensure that children can attend school on a regular basis; and
* provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there or on others as a result of new development (Para. 11).
Taking the above points in turn, there are significant concerns as to how the allocation of the land covered by site GT12 can achieve 'integrated co-existence' with the existing community whilst being separated both physically and visually from the existing residents of Barford. Furthermore, the WARWICK GYPSIES AND TRAVELLERS SITES - PREFERRED OPTIONS CONSULTATION
We write on behalf of Taylor Wimpey UK Ltd in respect of the Warwick District Council Gypsies and Travellers Preferred Options consultation document. Whilst there is an identified need to be met for Gypsies and Travellers either living in or passing through the area, it is imperative that the preferred sites are located where they embrace opportunities for community cohesion and maximise the accessibility of services for all.
Preferred site at land north of Westham Lane, Barford (site GT12)
We note that, despite our previous representations, site GT12 has now been recognised as a preferred site by the Council for meeting the Gypsy and Traveller need over the Plan period. In our view the assessment has remained silent on a critical issue in relation to this site, namely its location on the opposite side of the bypass to the village and subsequent separation from many of the services and facilities on which its residents will be reliant.
As noted in our previous representations, the A429 opened in February 2007 and is considered to clearly mark the western edge of Barford settlement in its current form. It is considered that the A429 has a significant impact on the ability of any sites to the west of it to meet the aims for future Gypsy and Traveller site provision as set out in the Planning Policy for Traveller sites (March 2012) document produced by DCLG. Whilst the DCLG guidance has been referred to in paragraph 1.2 of the Preferred Options consultation document we would draw particular attention to the following specific requirements, namely that the Local Planning Authorities should:
* promote peaceful and integrated co-existence between the site and the local community;
* ensure that children can attend school on a regular basis; and
* provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there or on others as a result of new development (Para. 11).
Taking the above points in turn, there are significant concerns as to how the allocation of the land covered by site GT12 can achieve 'integrated co-existence' with the existing community whilst being separated both physically and visually from the existing residents of Barford. Furthermore, the opportunities to safely access services and facilities in the village - including Barford Church of England Primary School - will inevitably be negatively impacted on and due to the nature of the road may be unsafe. This is referred to in the Preferred Options consultation document on page 38 where it states that, '... there may be some safety issues in crossing the Barford by-pass to access these (local facilities).' Given the number of the sites that the Council has to choose from it is not considered appropriate than one of the preferred sites has such a fundamental issue with its delivery, particularly as the time at which children in particular are most likely to be crossing the road - to travel to and from school - will coincide with periods of peak traffic flow.
It is also noted that there is a mixture of an earth bund and a fence structure on the eastern side of the A429, which has been designed to both reduce the visual impact of the road and also limit the noise impact from vehicles utilising the bypass on residents. It is a significant concern that any development of a Gypsy and Traveller site to the west of the A429 would not benefit from this structure and the environmental quality of any sites to the west of the A429 must be considered in this regard. Given the reference to this issue in section 7 of the detailed site assessment it is assumed that a likely method for responding to this issue would be to mirror the noise attenuation barrier on the eastern side of the by-pass. Nevertheless, this would have a significant impact on views across the area to the east of the by-pass and thus is not without disbenefits.
This potential noise attenuation feature is also relevant when considering paragraph 24 of the Planning Policy for Traveller sites document, which states that in considering planning applications sites should not be enclosed '... with so much hard landscaping, high walls or fences, that the impression may be given that the site and its occupants are deliberately isolated from the rest of the community.' It is considered that this site would be contrary to this site-level consideration at the application stage due to the distinct isolation as discussed above and should therefore not be favoured as an allocation by the Council.
Summary
Given the above, it is considered that the Council should ensure that there are opportunities to achieve community cohesion and access essential services for the travelling community on any sites included as future allocations. These matters should in our view restrict development of a Gypsy and Traveller site on the land to the west of the by-pass in Barford (site GT12).
We trust the enclosed representations are clear. If however you have any queries or wish to discuss the above in any further detail, please do not hesitate to contact me.

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Having reviewed the list of Preferred Options for permanent gypsy sites I would like to make the following comments.

The most appropriate site is clearly GTalt01 Brookside Willows on the Banbury Road. This already meets the majority of the conditions for a suitable site; partially developed with existing planning permission for caravans, well screened which benefits both the community and the travellers, safe access on to the main road which is important for movement of towed caravans, and close to the local amenities.

The site east of Birmingham Road at Budbrooke (GT19) should also be considered as it offers suitable conditions for a limited number of pitches, is partially developed for use of caravans, and therefore has access points and existing services.

Land at Harbury Lane/Fosse Way (GT04), Leamington Football Club should be discounted as it is a successful and well supported club that has been developed with considerable effort by the local community. Moving it could have serious consequences for its' continued existence.

Land north of Westham Lane, Barford (GT12) is too close to existing housing and should be discounted on the basis of not promoting peaceful and integrated co-existence between the site and local community.

Land east of Europa Way (GT15) is close to a busy road, therefore access would be dangerous and the noise due to traffic would be excessive.

I therefore recommend that you provide traveller sites at GTalt01 and GT19 as part of your Local Plan.

Sites for Gypsies & Travellers
Preferred options for consultation
The District Council's preferred option is set out in PO1 Meeting the requirement for Permanent pitches. The intention is to provide 31 pitches on permanent sites.
The preferred option selects
GT04 Harbury Lane/Fosse Way up to 10 pitches
GT12 Westham Lane, Barford up to 8 pitches
GT15 East of Europa Way up to 5 pitches
GT19 Birmingham Road, Budbrooke up to 5 pitches
GTalt01 Brookside Willows Banbury Road up to 10 pitches
Total 38 pitches
Conclusion of my response

To provide 31 pitches I consider the best arrangement to be

1. GT04 Harbury Lane land north of the Football club (see section 4) 6 pitches
2. GT12 Land south of Westham Lane, Barford (see section 4) 0 pitches
GT12 land north of Westham Lane within new housing, as single pitches 3 pitches
3. GT19 Birmingham Road, Budbrooke (see section 4) 3 pitches
4. GTalt01 Brookside Willows, Banbury Road (see section 4) 6 pitches
5. GT08 Land north of Depot near Cubbington Heath Farm (see section 5) 7 pitches
6. Riverside House affordable homes, in single pitches (see section 2) 3 pitches
7. Soans Sydenham affordable homes , in single pitches (see section 2) 3 pitches

TOTAL 31 pitches
1. Criteria for selection of sites.
The selection of sites for permanent pitches should be in line with the DCLG Designing Gypsy and Traveller Sites , Good Practice Guide dated May 2008 and which is still current.
Chapter 3 examines Location of sites and recommends, in paras 3.1 & 3.2

3.1 Selecting the right location for a site is a key element in supporting good community relations and maximising its success. As with any other form of housing, poorly located sites, with no easy access to major roads or public transport services, will have a detrimental effect on the ability of residents to:
* Seek or retain employment
* Attend school, further education or training
* Obtain access to health services and shopping facilities.
3.2 Easy access to local services, and to social contact with other residents in the community, should help deal with the myths and stereotypes which can cause community tension and instead encourage a greater sense of community with shared interests.

The Guide also lists as important
* a safe environment for the residents
* Promotion of integrated co-existence between the site and local community
* Easy access to General Practitioner and other health services
* Near to a bus route, shops and schools
* Ground conditions and levels of land
* Not in areas of flood risk.
.
The Guide also strongly states
3. 7 Where possible, sites should be developed near to housing for the settled community as part of mainstream residential developments. As one way of helping to address shortages of site provision local authorities and registered social landlords can consider the feasibility and scope for providing a site for Gypsies and Travellers within their negotiations to provide affordable housing as part of significant new build developments. Even where smaller scale developments are planned they could consider including a small scale site of three to four pitches which are known to work well for single extended families.

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."204]

None of the preferred option sites meet the criteria of 3.7. This is understandable since it is clear that the majority of the public do not want the travelling community anywhere and the District Council does not really want to provide them. This is due to the reputation that the travellers have for abusing other people's property, leaving dirt and damage behind and assumed increased minor crime. Sometimes those fears are real.

As a result, the travelling community as a whole prefer to live as a separate community, in large groups away from urban locations, so sustaining the mistrust between them and the settled community. As well as this, the larger the group, the bigger the perceived threat. It would seem advisable therefore, to dilute any possible effect to the minimum by keeping the number of pitches on a site as low as possible with a range of sites with a different number of pitches to provide sufficient flexibility to meet the needs of the tenants.
2. Small groups of single sites
However, paragraph 3.7 does indicate that some benefit could be gained if, in new affordable housing schemes, a housing association included a small number of single plot sites.

So it is suggested that you consider, on the 2 affordable housing sites recently included in the publication draft of the local plan, Orbit/Deeley at Sydenham and Riverside House redevelopment sites, that, within each of those developments, 3 separate single plots are slipped in between the normal affordable housing. Each plot would have a normal access to the street, a small bungalow amenity building and space for caravans and vehicle parking designed to fit in with the normal housing. They could look to be a natural part of the housing development, similar to a normal house where the owner parks their caravan in their garden next to a bungalow. As a permanent site, it could be offered to those who are not tied to a large group, who might choose to value getting involved in a wider community and could get close to, but not next door to other members of their family group in much the same way that the settled community does. For the children of those families it would give them a wider educational opportunity to reach their potential, rather than being obliged to be constrained to traditional traveller's ways. For the potential wage earner it would give a wider choice of employment opportunities. For the settled community neighbours, the chances of problems are reduced by the dissipation of the number of sites.

The Guidance gives an example in Annex 3b, Small Scale site in urban locations, with a plot about 10m by 20m (200m2) as compared with the 500m2 per pitch suggested for a set of pitches with internal roads. Services and drainage would cost less, being part of a larger development, so this arrangement is probably the least expensive cost per pitch to provide.
3. The operational management method for Gypsies & Travellers Permanent sites.
The District Council's proposed operating model is ownership and operation by an individual traveller landlord. This is unlikely to be a trouble free arrangement and cannot be relied on to permanently meet the established need, nor maintain a well-run site. Since providing a pitch is viewed as providing a supported housing facility, it should be operated by an independent body that can offer pitches fairly to gypsy traveller applicants, with fair rents and resources to maintain the facility and set the way that non-compliance with fair rules can terminate the tenure. This could be either the District Council or a housing association that specialises in this area of work. The District Council shows no appetite to run such sites, so interest should be invited from interested housing associations to purchase the site, finance, build, maintain and manage it. This model could also include implementation of ways of encouraging a greater sense of community with shared interests of the settled and travelling residents.
4. Considering the 5 preferred options.
GT04 Harbury Lane/Fosse Way
The preferred option document describes this site as currently the home ground of the Leamington Football club. The plan , which is not to the scale of 1:10,000 stated in page 37 shows a brown line around the site in which the Football Club and car park is in the south corner. The whole site is 350m by 430m with a small area in the east corner excluded. The total area is 150,300m2 or thereabouts. 10 pitches are suggested which using the 500m2 per pitch would require only 5,000m2.
Major Gas Pipelines run under the site and construction over the pipeline zones will not be permitted by the Health & Safety Executive. There is a small triangular area north of the football club that appears to be outside the zones between the two pipelines, so any location in this area needs to be carefully worked out with National Grid. However, excavations for drainage that would need to pass over the exclusion zones is unlikely to be permissible. Surface water drainage to this area is by ditches above ground and in persistent wet weather water flows off the fields to the south of Harbury Lane towards the car park and pitch of the Football Club. This part of the site is not therefore suitable for a permanent G & T site.
The site is remote to schools, health services, hospitals, shops & community facilities. It is said that some travellers do not find this a problem.
If kept to a maximum of 6 pitches, a 3,000m2 plot, avoiding the Gas pipeline zones, could be located north of the existing football Club with an access road to the site immediately to the west of the club car park. The site itself could be screened from view along Harbury Lane with suitable tree & shrub planting all around it. This location is less likely to be affected by flooding than the football club area.
I would therefore support the use of this site north of the existing Football Club premises with a separate access to Harbury Lane, surrounded by shelter belt tree planting for a maximum of 6 pitches under the direction of a specialist housing association. This would not require relocation of the football club to another location, safeguarding that site for housing required to meet the Local Plan targets. If the football club wanted to move for other reasons then it could be relocated to a suitable site in the green belt as a compatible use of greenbelt.
GT12 Westham Lane, Barford
This site is South of Westham Lane, not north as described in the preferred options document, close to the River Avon on the west, with the Barford by-pass on the east. The plan, which is not to the scale of 1:10,000 stated in page 39 shows a brown line around the site to the edge of the river and has an approximate area of 7,500m2 excluding the shrub belt on the bank of the river.
8 pitches on this site are too many and would be so close to the by-pass to be impossible to hide with planting. This is not good for the area or for the tenants.
The risk of pollution to the river from activities of the tenants as well as a non-mains drainage solution from this development that would be needed, is too high.
The by-pass is a fast road and access on & off the site would have serious safety concerns.
This concept would quickly deteriorate into a problem. The maximum number of pitches that this site could sustain is 3, to release space for setting the site back sufficiently to get adequate screening and small enough to stop it getting out of hand.
Alternatively, in the village housing options document, 3 housing sites have been identified between the bypass and the Wellesbourne Road. Site 2 is for 60 dwellings and site 3 is for 15 dwellings. 40% of these will presumably be affordable homes and it may therefore be an idea to put these 3 sites as single sites, within probably the larger housing site, in a similar manner to that set out in section 2 above.
GT15 East of Europa Way
This is not suitable for a permanent Gypsy & Traveller site because
* It was built as a permanent woodland as part of the Europa Way construction and forms a valuable screen to the east side of the road and is a positive contribution to the Tachbrook Valley landscape as this photo shows which was taken from the bottom right hand corner of the plan on page 41 towards Europa Way. The proposed site is to the right of the single oak tree (left hand side mid distance) at the point where the trees on the horizon are higher than the tree belt to the left. The Tach Brook is at the bottom of the slope on the right, where the trees along the side of the brook show how the brook relates to the wood and fields.
* The site within the brown lines on plan on page 41 stretches from Europa way down to the Tachbrook. The level at Europa Way is about 65m AOD and the level at the top of the bank to the brook is below 55m. This 10m fall occurs over a distance of between 40 and 150m, so the land has considerable falls across it that would make the site difficult for manoeuvring large vehicles and trailers. Note that the plan on page 41 is not to 1:10,000 but at about 1:2,500.

* The access onto Europa Way, which is a fast road when it is not congested, has serious safety concerns for a site containing large vehicles and trailers as well as young children. Roadside vegetation, trees and shrubs, would need to be removed to get adequate visibility splays.
* To construct the permanent site, large numbers of the trees would have to be cleared. This is one piece of young woodland that is playing a valuable part in carbon dioxide absorption, taking out 4 tonnes of CO2 per annum for every 100m2, which for the area of woodland affected means about a total of 450 tonnes per annum. Loss of such woodland would be contrary to the NPPF definition of sustainable development.
* Although the woodland is young it is dense and gives valuable habitat to wildlife. Human intervention from a permanent site would remove those habitats and the deer, badgers and other mammals would not survive in this location.
* The site would need non-mains foul drains so there is a risk of pollution of the waters in the brook that flows swiftly through to New Waters and then into the Avon, both from drainage spillage and debris from the tenants.
* Considering how this site could be laid out for 5 pitches, because it is a relatively narrow piece of woodland, after accounting for the new road access required and the falls across the site, it is probable that 5 pitches could not be satisfactorily sited and would have to be linear, parallel with the road. On a cost per pitch costing it is probably one of the most expensive locations in its capital cost of provision.
* Due to the heavy traffic on Europa Way and the proximity of living spaces to that road it is unlikely that it meets the noise standards required for a permanent site.
* As a site this is remote to any other community and is not as recommended by the DCLG guidelines. All facilities (shops, schools, health etc.) are pretty much only accessible by car.
This site should not have been included as a viable option and should be removed from the list.
GT19 Birmingham Road, Budbrooke
This site is on the A41 to Solihull between this road and the canal. The plan, which is not to the scale of 1:10000 stated in page 43 shows a brown line around the site, demonstrating its restricted nature. It would appear to be about 40m by 40m or 1600m2 so if a plot size is 500m2, then it will only take 3 pitches at most.
The site is an untidy corner but it is close to an urban community. Access could be obtained off the lane that goes south to Ugly Bridge and if the site is fenced and planted it could be reasonably self-contained and screened from the Birmingham Road. However, it would be more liable to succeed if it was limited to 3 pitches.
GTalt01 Brookside Willows, Banbury Road
This site, if it is to be used, needs very careful consideration. It is on the Banbury Road and Castle Park, a Grade 1 historic park, is on the opposite side of the road. It is part of a major visually powerful route into Warwick and forms a major route from the M40 and traffic approaching from the south to visit the area and Castle. It is a major tourist as well historic heritage.
It was granted permission as a holiday caravan site so if used for Gypsy & Travellers, unless this element is successfully run and does not deter visitors, then it will never become that. The District Council needs to decide which group of visitors they wish to attract.
It may be possible to do both. If the number of pitches is constrained to about 6 and a part of the site to the east is selected for the purpose with its own independent access from the Banbury Road and the site is run to a high standard, then it could still be viable as a tourist caravan park.
Providing that the size of the permanent site is limited to 6 pitches taking 100m by 40m of the south east corner of the site with fencing and strong shrub planting around it, it would be more or less be invisible to visitors and if run successfully would not prevent the rest of the site being used for normal caravan purposes. It would also be essential to protect the Tach Brook and its embankments from pollutants, human usage and detritus so that can be a successful wildlife corridor that feeds clean water into New Waters and the River Avon.
5. Alternative Sites

GT02 Land abutting the Fosse Way close to the A425
This area of land is a prominent and valuable piece of landscape on the Fosse Way and a caravan site for anyone, travellers or tourist caravans, would be a extremely negative in this location. So this site should not be used.
However on the east side of the Fosse way, there is The Fosse Exhibition complex and North Fosse Farm. It would be possible to provide a small permanent site in this location using existing services and access and to screen the site with substantial planting.
But it is not suggested that this should considered in this consultation.
GT05 Land at Tachbrook Hill Farm
This land should not be considered for a permanent site because
* It is on the Banbury Road and this is a major route from the M40 to Warwick and Warwick Castle and as such it is part of a major tourist attraction, enhancing the economy of the district. A G & T site here would be clearly seen by visitors coming into the area and be negative to the visitor experience.
* The barn north of the farm buildings at Tachbrook Hill Farm is Listed Grade II. The site suggested is land immediately to the north of the barn and so is part of the context of the listed building. Any development on this site would not be appropriate and is contra to the NPPF.
* The Banbury Road is a fast road. It connects to junction 13 of the M40 only 500m away from Tachbrook Hill Farm and drivers are normally accelerating up to motorway speeds in anticipation of the motorway or when coming off the motorway have not readjusted to non-motorway speeds. Any new junction for slow moving traffic would be a major safety hazard.
* The Banbury Road and its junction with Mallory Road are known accident black spots including a history of fatalities. The frontage to Banbury Road is lined with Oak trees and any sight lines required for a new access would require removal of a considerable number of them. This is not acceptable and it would make the site even more open to the visitor transport route.
* The WCC Landscape Sensitivity, Ecology & Geological Report for the New Local Plan assessed the landscape sensitivity as High. This indicates that development for any purpose should not be permitted.
* It is within 400m of the M40 on which vehicles can be seen travelling along the motorway, demonstrating a straight noise line to the site. It is too close to the motorway and the traffic noise on this site, particularly at night, or the wrong cloud base level, is high.
GT06 Land at Park Farm
This land should not be considered for a permanent site because
* It is on the Banbury Road and this is a major route from the M40 to Warwick and Warwick Castle and as such it is part of a major tourist attraction, enhancing the economy of the district. The land shown on the plan on page 53 is clearly visible to traffic using Banbury Road so substantial visual screening would be required.
* It is close to Castle Park which is a grade 1 Listed Park and is part of the parkland layout for Warwick Castle. Visually, the Castle Park, The Asps farm and Park Farm are all part of the rural context for the Castle and the entrance to Warwick from the south.
* Using part of Park Farm may affect the viability of the whole farm and that would be an unacceptable outcome of taking part of it as a G & T permanent site.
* It is remote from any community and does not have easy access to local services and to social contact with other residents in the community. It is also remote to schools, health and GP services.

GT08 Depot west side of Cubbington Heath Farm.
This site is on the northwest side of the A445, Leicester Lane, from Cubbington to Stoneleigh. The plan, which is not to the scale of 1:10,000 stated in page 55, shows a brown line around the site which is currently a road salt store used by the County council on lease from the current owners. It is presumed that this use would need to remain in the future.

The whole site is rectangular about 200m by 100m and has a good access to the south of the site from the road. The salt store occupies the southern 2/3rds of the site.

The northern end is grassed and is hedged to the road, the northern and western boundaries. It is not used in the salt operations as can be seen in the aerial photo. This part of the site is about 60 by 100 or about 6000m2 so at 500m2 per pitch could accommodate 12 pitches. However, to ensure retention of a substantial part of the green area, only 7 pitches should be provided on this site that would only require 3,500m2 of the available area. In the remaining area additional tree planting should be set out to compensate for any loss of green space that might occur.

Access to the site could be via the existing depot access or could have its own direct access to Leicester Lane but this would require removal of the hedgerow to the road to get adequate site lines. Since the salt store is only used in cold weather it is possible that this limited usage could be managed with the access to the G & T site from the existing access.


The site is close to the farm complex but is over 600m from the crossroads at the north of Cubbington. So it is a convenient distance to the urban area for local services, schools health and for social contact with other residents in the community as advised in the DCLG guidance. It is not visible from the road so would provide privacy to the tenants and although it is in the Green Belt would only have negligible impact on the area, not reducing the distances between the urban areas so separated.

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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.

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.

I would like to respond to the latest consultation process for the five potential sites .

Part A
Part B

Commenting on the Gypsy and Traveller Site Options.
The whole G&T issue seems to be driven to support the Draft Local Plan, rather than to be the correct solution in itself . I strongly believe that the sites should be considered within the New Local Plan and not as a separate exercise.
I have attended the WDC exhibitions and it appears that there is no justifiable reason why the G&T sites cannot be reviewed and incorporated into the new sites designated for providing the 12,300 houses currently under consultation.
I would like to refer my comments specifically to the following sites:
GT12, GT 15 and GT alt 12 alt 01.

I would like to OBJECT to the proposal of all these sites for the reasons stated below. I have based my objections on the suitability and sustainability criteria used in the WDC consultation document.

* Site GT alt 01 - sits immediately approximate to the Asps which Warwick District Council decided, after further research regarding the landscape and transport impact of development, that site should remain open due its value as a backdrop to the historic Warwick Castle Park. The Revised Development Strategy, therefore, excludes the Asps and should also exclude the site GT alt 01for the same reasons.

* Sites GT 12, GT alt 12 and GT alt 01 - the sites are not sustainable in terms of multi modal accessibility. None of the sites offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycle routes, or by bus. The only means of accessibility is by car which would place further pressure on the local highway network infrastructure and is unsustainable.

* Sites GT 12 and GT12 alt 01 - sit within (part) and otherwise immediately adjacent to areas identified by the Environment Agency as having significant flood risk. Extensive flooding has taken place in both sites earlier this year.


* Sites GT 12 and GT 12 alt 01 - development would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and it's likely requirement to provide 70-90 new dwellings during the Plan period.

* Sites GT 12 and GT12 alt 01 - a number of residents have reported the existence of water voles in and immediately adjacent to these sites. Water voles are, of course, now a legally protected species.

* Site GT 15 - this site sits alongside Europa Way which following recent upgrade is now an even busier road. There is no apparent logic to this site what so ever , indeed the site has no access to any local facilities and would be best integrated into one of the areas of land being considered for new local housing


* Sites GT12 and GT 12 alt 01 - there is inadequate pedestrian crossing facilities for safe access into the village. It is an extremely busy road and crossing and road improvement measures would require significant investment to be safe for users.

* Sites GT 12 and GT 12 alt 01 - the development of all of these sites could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity of the sites.

* Sites GT 12 and GT 12 alt 01 - WDC have disregarded their own Rural Area Policies, especially RAPs 1 (New Housing), 6 (New Employment), 10 (Safeguarding Rural Roads) and 15 (Camping and caravan Sites). In all respects the sites fail to meet the policy criteria to allow any form of development.

* Sites GT 12, GT 12 alt 01 and GT 15, - are not locations which allow peaceful and integrated co-existence with the local community.

* Sites GT 12 and GT 12 alt 01 - development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (eg site 12) totally unviable.

* Sites GT 12 and GT 12 alt 01 - vehicular access to these sites is from the A429 trunk road which was constructed as a bypass to Barford. It is a 60 mph speed limit road and there have been a significant number of accidents on it since its opening, including a fatality. The existing access into the sites is entirely inadequate.


* Sites GT 12, GT 12 alt 01 and GT 15 - vehicular access to these sites is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.

My general comments relating to ALL of the above sites are:

* WDC should have identified sites within the existing urban areas of Kenilworth, Warwick and Leamington for Gypsies and Travellers. These sites would be more suitable and sustainable, and would enable better integration in to the local community. Despite such sites existing, they are all being proposed for redevelopment for more valuable uses. These sites should be integrated into new housing sites identified for the New Local Plan. The new G&T sites can be integrated into those sites from the start. Discussions with developers confirm that they would be willing to accept a number of G&T sites into new housing development areas along with affordable housing schemes.


* Availability - none of the sites listed are available, namely sites GT 12 , GT 12 alt 01 and GT 15. By definition the remaining sites are not deliverable. A compulsory purchase order would be extremely lengthy, costly and unviable compared to other options.

* WDC should be requiring Gypsy and Traveller sites are delivered within the proposed major new housing developments in Kenilworth, Warwick and Leamington where 12,300 houses are proposed. This would ensure that the sites could be properly designed in a sustainable fashion and be fully integrated into a local community which will provide facilities such as a school, a doctors surgery and shops which are accessible on foot, on bike, by bus and by car.

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

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

I would like to respond to the latest consultation process for the five potential sites .

Part A
Part B

Commenting on the Gypsy and Traveller Site Options.
The whole G&T issue seems to be driven to support the Draft Local Plan, rather than to be the correct solution in itself . I strongly believe that the sites should be considered within the New Local Plan and not as a separate exercise.
I have attended the WDC exhibitions and it appears that there is no justifiable reason why the G&T sites cannot be reviewed and incorporated into the new sites designated for providing the 12,300 houses currently under consultation.
I would like to refer my comments specifically to the following sites:
GT12, GT 15 and GT alt 12 alt 01.

I would like to OBJECT to the proposal of all these sites for the reasons stated below. I have based my objections on the suitability and sustainability criteria used in the WDC consultation document.

* Site GT alt 01 - sits immediately approximate to the Asps which Warwick District Council decided, after further research regarding the landscape and transport impact of development, that site should remain open due its value as a backdrop to the historic Warwick Castle Park. The Revised Development Strategy, therefore, excludes the Asps and should also exclude the site GT alt 01for the same reasons.

* Sites GT 12, GT alt 12 and GT alt 01 - the sites are not sustainable in terms of multi modal accessibility. None of the sites offer the ability to access local community facilities (schools, doctors surgeries etc) on foot or on bike via pedestrian footpaths or cycle routes, or by bus. The only means of accessibility is by car which would place further pressure on the local highway network infrastructure and is unsustainable.

* Sites GT 12 and GT12 alt 01 - sit within (part) and otherwise immediately adjacent to areas identified by the Environment Agency as having significant flood risk. Extensive flooding has taken place in both sites earlier this year.


* Sites GT 12 and GT 12 alt 01 - development would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and it's likely requirement to provide 70-90 new dwellings during the Plan period.

* Sites GT 12 and GT12 alt 01 - a number of residents have reported the existence of water voles in and immediately adjacent to these sites. Water voles are, of course, now a legally protected species.

* Site GT 15 - this site sits alongside Europa Way which following recent upgrade is now an even busier road. There is no apparent logic to this site what so ever , indeed the site has no access to any local facilities and would be best integrated into one of the areas of land being considered for new local housing


* Sites GT12 and GT 12 alt 01 - there is inadequate pedestrian crossing facilities for safe access into the village. It is an extremely busy road and crossing and road improvement measures would require significant investment to be safe for users.

* Sites GT 12 and GT 12 alt 01 - the development of all of these sites could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity of the sites.

* Sites GT 12 and GT 12 alt 01 - WDC have disregarded their own Rural Area Policies, especially RAPs 1 (New Housing), 6 (New Employment), 10 (Safeguarding Rural Roads) and 15 (Camping and caravan Sites). In all respects the sites fail to meet the policy criteria to allow any form of development.

* Sites GT 12, GT 12 alt 01 and GT 15, - are not locations which allow peaceful and integrated co-existence with the local community.

* Sites GT 12 and GT 12 alt 01 - development would lead to an unacceptable loss of farmland and rural employment, rendering the isolated sites (eg site 12) totally unviable.

* Sites GT 12 and GT 12 alt 01 - vehicular access to these sites is from the A429 trunk road which was constructed as a bypass to Barford. It is a 60 mph speed limit road and there have been a significant number of accidents on it since its opening, including a fatality. The existing access into the sites is entirely inadequate.


* Sites GT 12, GT 12 alt 01 and GT 15 - vehicular access to these sites is from an already heavily utilised road network. Access and egress to and from these sites to the highways network would not be safe.

My general comments relating to ALL of the above sites are:

* WDC should have identified sites within the existing urban areas of Kenilworth, Warwick and Leamington for Gypsies and Travellers. These sites would be more suitable and sustainable, and would enable better integration in to the local community. Despite such sites existing, they are all being proposed for redevelopment for more valuable uses. These sites should be integrated into new housing sites identified for the New Local Plan. The new G&T sites can be integrated into those sites from the start. Discussions with developers confirm that they would be willing to accept a number of G&T sites into new housing development areas along with affordable housing schemes.


* Availability - none of the sites listed are available, namely sites GT 12 , GT 12 alt 01 and GT 15. By definition the remaining sites are not deliverable. A compulsory purchase order would be extremely lengthy, costly and unviable compared to other options.

* WDC should be requiring Gypsy and Traveller sites are delivered within the proposed major new housing developments in Kenilworth, Warwick and Leamington where 12,300 houses are proposed. This would ensure that the sites could be properly designed in a sustainable fashion and be fully integrated into a local community which will provide facilities such as a school, a doctors surgery and shops which are accessible on foot, on bike, by bus and by car.

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

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

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.

I would like to object to Option GT12 Westham Lane, Barford.
The reasons are that it does not fit your own criteria and there are better options being considered, the most obvious one being GTalt01 Brookside Willows, Banbury Road. In addition, I feel that not enough time has gone into the planning of larger sites, that would be economically much better in terms of economies of scale and impact on fewer proposed sites.
New, larger, mixed communities within the new proposed developments in the area appear not to have been considered. Why? Then they could be properly planned and managed in a sympathetic and economic way.
GT12 Westham Lane is not suitable because:
* The site is situated on the edge of a very busy, fast road(A429)with a history of accidents at the nearby junctions making safe access impossible. It would also be noisy.
* The site is cut off from the village by A429 and would involve pedestrians crossing to get to the village primary school for instance.
* There is no doctor's surgery nearby.
* The physical impact of the site would be detrimental to the main tourist route between the area and the Cotswalds
* There are no utilities so provision of these would be costly.
* Integration into the landscape would obviously be an issue in a pretty riverside location.
GTalt01 Brookside Willows is a more obvious choice because:
* Access is safe and established
* The site is set back from the road which would be beneficial to all concerned and it is not situated on a fast stretch of road so traffic noise would not be an issue.
* Schools, doctors are nearby and transport links are good.
* There is safe, pedestrian links to town.

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