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Dear Sir/Madam,

I wish to object to this proposed development on the following grounds:-

- WDC utilised the findings in the Salford GTAA report in order to establish need, however there is no evidence of WDC's due diligence in validating the accuracy of the report and /or the relevance of the established need.
- The WDC consultation does not consider as required the existing capacity of current sites within Warwickshire county and adjacent districts.
- The GTAA ignores the impact of the planned Transit site near Southam which has been agreed since completion of the GTAA
- According to the Government's planning policy framework, adjacent DCs are required to collaborate, and yet Warwick DC and Stratford DC are very much out of phase with their consultations so logically they cannot collaborate. Further there is no evidence that WDC has collaborated or discussed with Stratford DC other than a reported "10 minute long but un-minuted meeting" or with Rugby DC
- there is no evidence in WDC's consultation report that as required by NPFF and CLG , that WDC have weighed up the cost to council of Compulsory purchase vs development of underutilised brownfield sites including those that the council already own.
. - The WDC proposals will provide for more accommodation than there are G&T residents within WDC boundary the vast majority of whom already live in houses so the requirement is clearly seriously over-stated
- There is clear evidence via Hansard that MP's now want a fair planning policy that should result in the abolition of the G&T planning requirement
- There has been little (and passive) publicity of the Consultation process and key milestones. Had it not been for the local Community group I would not have known about it - it feels and looks like this is a deliberate underhanded approach.
Specific to Site GT04:
- The site does not meet the fundamental planning criteria laid out in the NPPF, guidance from Department of Communities and Local Government and WDC's own consultation documents for Gypsy & Traveller sites. GT04 does not comply with planning policy whereby sites should provide access to nearby services and quality of life. Specifically:-
- Accessibility to shops and local services: GT04 does not meet national planning framework guidelines recommended 5-10mins walk on a pavement.
-Proximity to local community: GT04 does not meet the national planning framework guidelines recommendation for sites to be on community periphery to encourage integration.
-Establishing 5-10 pitches at GT04 would be disproportionate to the local community (8 residential properties, with 16 adults and 4 children). This is contradictory to national planning framework guidelines recommendations.
- GT04 does not meet national planning framework guidelines recommendations for accessibility to good local transport.
- GT04 does meet national planning framework guidelines recommendations for availability of good infrastructure (roads, pavement, street lighting, broadband, cellphone reception).The infrastructure at GT04 is poor and would require considerable investment to rectify. And this is an expense that WDC should not incur during times of cutbacks in public expenditure and services.

- The area is prone to flooding with Harbury Lane and surrounding fields are often under water.
In accordance with planning and building regs, GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based and will require connection to mains sewerage which does not exist in Harbury Lane.
-Planning policy for G&T requires schools / GP surgeries to be a 5-10 minute walk away, GT04 is at least a 45 minute walk away.
- The nearest GP surgery is three miles away
- that GP surgery is at capacity.
- The nearest primary, junior and senior schools are already at capacity.
- GT04 is located on Harbury Lane and Fosse Way cross roads that is a high risk travel route with high
volumes of traffic and an increasing number of accidents. Speed cameras and warning signs highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to school if indeed such transport exists
- According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This raises serious environmental and health concerns, and was a primary reason that the potential G&T site at Barnwell farm was previously rejected. Simply -Barnwell chicken farm can smell awful and GT04 would not be a good place to live
GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and which would make GT04 an unpleasant place to live but also an unhealthy one.
- The NPFF requires that the assessment of site suitability should be consistent with other planning requests. However I understand that other residential planning applications within 200m of GT04 have been recently rejected by council planning authorities, referencing rural policy on the grounds that the proposal would have an adverse "impact on the character of the area".

- the cost to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's figures (£65k per pitch). In addition to this, G04 site may require relocation of Football club. There is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that G&T can and will buy and develop it
- GT04 is an area of good quality farmland fully utilised for livestock and arable farming.
- GT04 will lack of Integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire
- The proposed site will have an adverse visual impact from Harbury and The Fosse Way (Roman Road).
- If GT04 were to be developed, the use of a vehicle or public transport to shops and schools is a necessity and not considered eco-friendly.
- The site will have a detrimental impact on tourism and visitors to Warwickshire especially including Mallory Court Hotel and a consequential effect on local employment.
- The site will damage wildlife habitat.

All of the above objections are both valid and reasonable, and I cannot understand why WDC are still considering GT04 as an option.

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I am writing to register my objection to the proposed Gypsy and Traveller site GT02 (Warwickshire Exhibition Centre).

I am objecting to the site on the basis of:

- The site is on Green Belt land and will directly affect the Green Belt

- The site is overlooked by Ufton, Leamington and Harbury and will have a detrimental effect on the landscape. Due to the elavation of the land around it it will not be possible to screen the site.

- Both the Fosse and A425 are busy routes and the access to and from the site will be unsafe.

- The Exhibition Centre will need to closed and it's heritage will disappear

- There is no infrastructure at this site and no facilities. The travellers will have to walk on busy public highways leading to risk to themselves and other.

I also feel that the study that was used to establish the requirement for gypsy sites is out of date and floored and has been driven by the current affairs and at that time. The requirement for these sites at all needs review.

I am also concerned that the site is on the Warwickshire DC and Stratford DC boundary and any implication and effects of this site will cross this boundary leading to inefficiencies and ineffectiveness of response.

I attempted to complete the online form but I was unable to select the document I wished to comment on. I fear the link may have broken. For this reason I emailing my objection and request that the deadline be extended to ensure that residents have the opportunity to make their feelings known.

I wish to register my objection to the proposed Gypsy Traveller site near to Harbury (GT02, GT04).

My concerns are as follows.

1. The strain on local amenities. Our doctors surgery and village school is struggling to meet the needs of the community at it's current size. To add more families to this would require a large investment of public money (which given the current economic climate is unrealistic) to adequately meet the needs of the local tax payers. We have recently have Harbury fields phase 1 and 2 which has added many more families. When phase 3 and 4 are complete the strain will be even greater.

2. There are currently no footpaths and very limited public transport options close to the proposed site. This will mean that another significant investment of tax payers money to make it safe for the inhabitants of the proposed site.

3. The fosse way is a saturated travel network. The volume of traffic already traveling to jaguar land rover, and Aston Martin at Gaydon results in challenging and sometime dangerous travel environments for families taking their children to school in Leamington or Warwick during the commuting hours. If you add a gypsy settlement at the proposed sites along the fosse way you will be invertible be adding significantly to an already struggling transport system. This will result in treacherous traveling conditions and more accidents as well as potential loss of life.

These reason make it inappropriate for the site to be positioned along the fosse way and close to Harbury. At the consultation we were told that Warwick district council does not have any permanent sites. I believe it is only fair that the needs (school doctors surgery etc) of any sites be met by the Warwick district. Stratford on Avon district council already provides homes and amenities to the travelling community and so it does not make sense that we meet the needs of your districts travelling community as well as our own.

I understand that the report upon which the local plan has been based is fundamentally flawed and challenged by local MPs. I implore you to suspend this project until thorough and unbiased research base on an actual need can be carried out and an adequate and professional consultation can be completed.

I would be very interested to hear your thoughts on the above points.

I wish to register my objection to the proposed Gypsy Traveller site near to Harbury (GT02, GT04).

My concerns are as follows.

1. The strain on local amenities. Our doctors surgery and village school is struggling to meet the needs of the community at it's current size. To add more families to this would require a large investment of public money (which given the current economic climate is unrealistic) to adequately meet the needs of the local tax payers. We have recently have Harbury fields phase 1 and 2 which has added many more families. When phase 3 and 4 are complete the strain will be even greater.

2. There are currently no footpaths and very limited public transport options close to the proposed site. This will mean that another significant investment of tax payers money to make it safe for the inhabitants of the proposed site.

3. The fosse way is a saturated travel network. The volume of traffic already traveling to jaguar land rover, and Aston Martin at Gaydon results in challenging and sometime dangerous travel environments for families taking their children to school in Leamington or Warwick during the commuting hours. If you add a gypsy settlement at the proposed sites along the fosse way you will be adding significantly to an already struggling transport system. This will result in treacherous traveling conditions and more accidents as well as potential loss of life.

These reasons make it inappropriate for the site to be positioned along the fosse way and close to Harbury. At the consultation we were told that Warwick district council does not have any permanent sites. I believe it is only fair that the needs (school doctors surgery etc) of any sites be met by the Warwick district. Stratford on Avon district council already provides homes and amenities to the travelling community and so it does not make sense that we meet the needs of your districts travelling community as well as our own.

I understand that the report upon which the local plan has been based is fundamentally flawed and challenged by local MPs. I implore you to suspend this project until thorough and unbiased research base on an actual need can be carried out and an adequate and professional consultation can be completed.

I would be very interested to hear your thoughts on the above points.

I wish to report my objection to the proposed gypsy sites GT02 and GT04.

I have read the recent literature and attended the meeting/exhibition earlier in the spring at Harbury Village Hall. I have concerns about the original research that sourced these potential Gypsy & Traveller Sites and the fact that the research was not done locally and that gypsys were actually involved in the direction of the research.

GT04

I am concerned about its proximity to my home and village and if this site were successful I fear for the drain on resources that the site would create as school and doctors places are already at maximum capacity.

I am aware that the football club will only agree to the use of the land as a G&T site if they are able to relocate to a city centre site, if this is not possible they do not wish to move so if you choose this land it would be an attempt at a compulsory purchase.

GT02

I object to the suggestion that this site is put forward as a proposed G&T site based on the following facts:

1. My wife is employed at the Warwickshire Exhibition Centre (WEC) and we are clearly aware that the land owners do not wish to sell, so if this site is forced through it would need to be via compulsory purchase which would be costly for the council and take years to complete if it ever would.

2. The threat of this site alone has been sufficient to deter potential event organisers from using our exhibition hall and it has also deterred current organisers working with us from signing extended contracts to work with us over the next 5 years.

3. My wife is one of 7 permanent employees at the WEC and when we have exhibitions on we employ many more people on a temporary basis, sometimes up to 30 or 40. If the site at GT02 was approved the WEC would be forced to close down and myself and all colleagues would be forced into unemployment.

4. The WEC brings significant revenue into the county/district through the thousands of visitors and hundreds of exhibitors it brings to the Centre each year. Revenue for the district is source through hotels, B&Bs, restaurants, other tourist attractions in the area etc. For some of our events we will book directly accommodation for our exhibitors and we promote local facilities via our website.

5. I have concerns about the location of the proposed site being on such a main road - this does not prove safe access to and from the site for vehicles and there is really no pedestrian access from the proposed site.

6. The proposed site is opposite a business but also a residential home.

7. The adjacent site is protected ancient woodland and if a G&T site were placed next to it is would have severe damage to wildlife habitat.

8. The land is a historic toll site from medieval times.

9. I do question why all the sites are in the south of Warwickshire and I also question the governments suggestion on how manysirte are required - it is far too many for our area and the proposed sites are too close to each other.

I do sincerely hope that Warwick District Council do remove these 2 options from the local G&T lists.

I am writing to register my objection to the proposed Gypsy and Traveller site GT02 (Warwickshire Exhibition Centre).

I am objecting to the site on the basis of:

- The site is on Green Belt land and will directly affect the Green Belt

- The site is overlooked by Ufton, Leamington and Harbury and will have a detrimental effect on the landscape. Due to the elavation of the land around it, it will not be possible to screen the site.

- Both the Fosse and A425 are busy routes and the access to and from the site will be unsafe.

- The Exhibition Centre will need to closed and it's heritage will disappear

- There is no infrastructure at this site and no facilities. The travellers will have to walk on busy public highways leading to risk to themselves and other.

I also feel that the study that was used to establish the requirement for gypsy sites is out of date and floored and has been driven by the current affairs and at that time. The requirement for these sites at all needs review.

I am also concerned that the site is on the Warwickshire DC and Stratford DC boundary and any implication and effects of this site will cross this boundary leading to inefficiencies and ineffectiveness of response.
I am writing to register my objection to the proposed Gypsy and Traveller site GT04 (Leamington FC).

I am objecting to the site on the basis of:

- The site is overlooked by Leamington and Harbury and will have a detrimental effect on the landscape.

- Both the Fosse and Harbury Lane are busy routes and regular access to and from the site will be unsafe. During football matches, stewards have to guide traffic in to and out of the site.

- Leamington FC will need to be relocated and it's history tarnished.

- There is no infrastructure at this site and no facilities. The travellers will have to walk on busy public highways leading to risk to themselves and other.

I also feel that the study that was used to establish the requirement for gypsy sites is out of date and floored and has been driven by the current affairs at that time. The requirement for these sites at all needs review.

I am also concerned that the site is on the Warwickshire DC and Stratford DC boundary and any implication and effects of this site will cross this boundary leading to inefficiencies and ineffectiveness of response.

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.

see attached

Preferred Site GTalt01
Brookside Willows Banbury Road
Of the proposed preferred sites surrounding Bishop's Tachbrook this one appears to be the most suitable. It has already been developed with infrastructure as a caravan site at great expense but has not been utilised as such for whatever reason. I assumed it was because it is the site of an old dump and there are problems caused by contamination. However as a preferred option this is either not the problem or it can be overcome. I do not know the ownership of the land and whether the site will have to be purchased and at what cost.

Located in a dip, the site is well screened by surrounding woodland and will not impact the landscape. Much of the site is reclaimed land of no great agricultural value. It is elevated above the Tach Brook so not prone to flooding and is near all local amenities & facilities with an already built access to the Banbury Road. The site meets all the criteria as deemed necessary in the guidelines of the NPPF. For all these reasons this site would be suitable for a permanent and transit G&T site.



Preferred Site GT15
Europa Way Bishop's Tachbrook
This site abuts a very busy link road making access and egress very dangerous. The site is steeply sloping and would require major/expensive works to level. Moreover the land is wooded without any facilities and utilities such as sewerage etc. For these reasons I think the site would be unsuitable for a G&T site.










Alternative Site GT05
GT05 Tachbrook Hill Farm, Mallory Road Bishop's Tachbrook

Situated on the edge of Bishop's Tachbrook near the junction of Mallory Road and Banbury Road; this is already a very dangerous junction where a number of accidents including fatalities have been recorded. Increased traffic especially vans and lorries from the proposed G&T site would add to the danger of this junction and access to Mallory Road.

The site on rising elevation is very exposed and would be detrimental to the approach view to the village. In addition the site presently used as agricultural land. Indeed the farmer/landowner is not willing to sell and the site would be subject to compulsory purchase. In addition the extra transient and or permanent G&T population will put an excessive strain on the resources of the village school and part-time GP surgery. For these reasons I believe this location would be unsuitable for a G&T site.



Alternative Site GT06
Park Farm/Spinney Farm Banbury Road

My objection to this site is on the grounds that it would make an enormous adverse affect on the rural landscape and visual approach to Warwick as a major tourist destination. It is close to the important A452 & A425 junctions with heavy motorway access traffic and commuter traffic into Leamington, Warwick and Aston Martin and JLR at Gaydon. Apart from increasing noise and pollution the extra traffic entering & exiting on to the A452 from the site would add an extra road hazard to the already overloaded roads in the area.

The site is also farmland and would diminish the viability of running a farm enterprise. For these reasons this would not make and ideal G&T site

Alternative site GT04
Land at Harbury Lane/Fosse way Junction
It would seem perverse to turn a purpose-developed football ground (home of Leamington Football Club) into a G&T site. The expense and disruption of relocating the Club has not been evaluated or for that matter costed. For this reason alone this would make this a non- viable site. Harbury Lane is already a very busy commuter route from surrounding areas and this site with vehicle entering & exiting on to it would add to the traffic burden and cause a major safety hazard.

It would also be highly visible travelling down the hill from the Fosse way and become an unnecessary blemish on the rural landscape. Overall these reasons make this site a non-viable a G&T site.

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.

GT04 is in close proximity of Harbury Lane breakers yard and Barnwell chicken farm and will be subject to associated pollution.
This site will require the re-location of a football club and will not therefore be cost effective.
This site will utilise quality farmland
This site will prejudice the landscape and spoil views from Chesterton Windmill.
The site will damage habitat / wildlife.
The site will have a detrimental impact on tourism and visitors (especially Mallory Court Hotel

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


I have listed my comments and concerns below which are:


* WDC utilised the findings in the Salford GTAA report in order to establish need, however there is no evidence of WDC's due diligence in validating the accuracy of the report and /or the relevance of the established need.
* The WDC consultation does not consider as required the existing capacity of current sites within Warwickshire county and adjacent districts.
* The GTAA ignores the impact of the planned Transit site near Southam which has been agreed since completion of the GTAA
* According to the Government's planning policy framework, adjacent DCs are required to collaborate, and yet Warwick DC and Stratford DC are very much out of phase with their consultations so logically they cannot collaborate. Further there is no evidence that WDC has collaborated or discussed with Stratford DC other than a reported "10 minute long but un-minuted meeting" or with Rugby DC
* There is no evidence in WDC's consultation report that as required by NPFF and CLG , that WDC have weighed up the cost to council of Compulsory purchase vs development of underutilised brownfield sites including those that the council already own.
* The WDC proposals will provide for more accommodation than there are G&T residents within WDC boundary the vast majority of whom already live in houses so the requirement is clearly seriously over-stated
* There is clear evidence via Hansard that MP's now want a fair planning policy that should result in the abolition of the G&T planning requirement
* There has been little (and passive) publicity of the Consultation process and key milestones. Had it not been for the local Community group I would not have known about it - it feels and looks like this is a deliberate underhanded approach. On this point I am particularly unimpressed by the council officer at the consultation meeting who considered that handing out leaflets to a member of the residents association for distribution then failing to follow up that the leaflets had been delivered. The excuse that the leaflet drop was to be completed by a volunteer does not constitute absolve the council or its officers from the responsibility of delivering the leaflets or for the need to manage the action. The statement by the officer that the council could not manage a volunteer shows an appalling lack of understanding and judgement. At the very least the officer should have telephoned the volunteer to check on progress and made appropriate plans based on the feedback. In my view this is negligence and deserves disciplinary action for the staff concerned!


Specific to Site GT04:
* The site does not meet the fundamental planning criteria laid out in the NPPF, guidance from Department of Communities and Local Government and WDC's own consultation documents for Gypsy & Traveller sites. GT04 does not comply with planning policy whereby sites should provide access to nearby services and quality of life.
Specifically:
o Accessibility to shops and local services: GT04 does not meet national planning framework guidelines recommended 5-10mins walk on a pavement. There are no pavements in the location of the proposed site!
o Proximity to local community: GT04 does not meet the national planning framework guidelines recommendation for sites to be on community periphery to encourage integration.
o Establishing 5-10 pitches at GT04 would be disproportionate to the local community (8 residential properties, with 16 adults and 4 children). This is contradictory to national planning framework guidelines recommendations.
o GT04 does not meet national planning framework guidelines recommendations for accessibility to good local transport.
o GT04 does not meet national planning framework guidelines recommendations for availability of good infrastructure (roads, pavement, street lighting, broadband, cellphone reception).The infrastructure at GT04 is poor and would require considerable investment to rectify. And this is an expense that WDC should not incur during times of cutbacks in public expenditure and services.
o The area is prone to flooding with Harbury Lane and surrounding fields are often under water. In accordance with planning and building regs, GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based and will require connection to mains sewerage which does not exist in Harbury Lane.
o Planning policy for G&T requires schools / GP surgeries to be a 5-10 minute walk away, GT04 is at least a 45 minute walk away.
o The nearest GP surgery is three miles away
o The nearest GP surgery is operating at its maximum at capacity.
o The nearest primary, junior and senior schools are already at capacity.
o GT04 is located on Harbury Lane and Fosse Way cross roads that is a high risk travel route with high volumes of traffic and an increasing number of accidents. Speed cameras and warning signs highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to school if indeed such transport exists
o According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This raises serious environmental and health concerns, and was a primary reason that the potential G&T site at Barnwell farm was previously rejected. Simply -Barnwell chicken farm can smell awful and GT04 would not be a good place to live
o GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and which would make GT04 an unpleasant place to live but also an unhealthy one.
o The NPFF requires that the assessment of site suitability should be consistent with other planning requests. However I understand that other residential planning applications within 200m of GT04 have been recently rejected by council planning authorities, referencing rural policy on the grounds that the proposal would have an adverse "impact on the character of the area".
o The costs to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's figures (£65k per pitch). In addition to this, GT04 site may require relocation of Football club. There is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that G&T can and will buy and develop it. Also WDC should not fund the relocation of the Football Club in the event of a compulsory purchase. This does not represent good taxpayer value.
o GT04 is an area of good quality farmland fully utilised for livestock and arable farming.
o GT04 will lack of Integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire
o The proposed site will have an adverse visual impact from Harbury and The Fosse Way (Roman Road).
o If GT04 were to be developed, the use of a vehicle or public transport to shops and schools is a necessity and not considered eco-friendly and is likely to overwhelm the available parking creating further road safety issues
o The site will have a detrimental impact on tourism and visitors to Warwickshire especially including Mallory Court Hotel and a consequential effect on local employment.
o The site will damage wildlife habitat.

I wish to object to this proposed development on the following grounds:-

- WDC utilised the findings in the Salford GTAA report in order to establish need, however there is no evidence of WDC's due diligence in validating the accuracy of the report and /or the relevance of the established need.
- The WDC consultation does not consider as required the existing capacity of current sites within Warwickshire county and adjacent districts.
- The GTAA ignores the impact of the planned Transit site near Southam which has been agreed since completion of the GTAA
- According to the Government's planning policy framework, adjacent DCs are required to collaborate, and yet Warwick DC and Stratford DC are very much out of phase with their consultations so logically they cannot collaborate. Further there is no evidence that WDC has collaborated or discussed with Stratford DC other than a reported "10 minute long but un-minuted meeting" or with Rugby DC
- there is no evidence in WDC's consultation report that as required by NPFF and CLG , that WDC have weighed up the cost to council of Compulsory purchase vs development of underutilised brownfield sites including those that the council already own.
. - The WDC proposals will provide for more accommodation than there are G&T residents within WDC boundary the vast majority of whom already live in houses so the requirement is clearly seriously over-stated
- There is clear evidence via Hansard that MP's now want a fair planning policy that should result in the abolition of the G&T planning requirement
- There has been little (and passive) publicity of the Consultation process and key milestones. Had it not been for the local Community group I would not have known about it - it feels and looks like this is a deliberate underhanded approach.
Specific to Site GT04:
- The site does not meet the fundamental planning criteria laid out in the NPPF, guidance from Department of Communities and Local Government and WDC's own consultation documents for Gypsy & Traveller sites. GT04 does not comply with planning policy whereby sites should provide access to nearby services and quality of life. Specifically:-
- Accessibility to shops and local services: GT04 does not meet national planning framework guidelines recommended 5-10mins walk on a pavement.
-Proximity to local community: GT04 does not meet the national planning framework guidelines recommendation for sites to be on community periphery to encourage integration.
-Establishing 5-10 pitches at GT04 would be disproportionate to the local community (8 residential properties, with 16 adults and 4 children). This is contradictory to national planning framework guidelines recommendations.
- GT04 does not meet national planning framework guidelines recommendations for accessibility to good local transport.
- GT04 does meet national planning framework guidelines recommendations for availability of good infrastructure (roads, pavement, street lighting, broadband, cellphone reception).The infrastructure at GT04 is poor and would require considerable investment to rectify. And this is an expense that WDC should not incur during times of cutbacks in public expenditure and services.

- The area is prone to flooding with Harbury Lane and surrounding fields are often under water.
In accordance with planning and building regs, GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based and will require connection to mains sewerage which does not exist in Harbury Lane.
-Planning policy for G&T requires schools / GP surgeries to be a 5-10 minute walk away, GT04 is at least a 45 minute walk away.
- The nearest GP surgery is three miles away
- that GP surgery is at capacity.
- The nearest primary, junior and senior schools are already at capacity.
- GT04 is located on Harbury Lane and Fosse Way cross roads that is a high risk travel route with high
volumes of traffic and an increasing number of accidents. Speed cameras and warning signs highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to school if indeed such transport exists
- According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This raises serious environmental and health concerns, and was a primary reason that the potential G&T site at Barnwell farm was previously rejected. Simply -Barnwell chicken farm can smell awful and GT04 would not be a good place to live
GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and which would make GT04 an unpleasant place to live but also an unhealthy one.
- The NPFF requires that the assessment of site suitability should be consistent with other planning requests. However I understand that other residential planning applications within 200m of GT04 have been recently rejected by council planning authorities, referencing rural policy on the grounds that the proposal would have an adverse "impact on the character of the area".

- the cost to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's figures (£65k per pitch). In addition to this, G04 site may require relocation of Football club. There is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that G&T can and will buy and develop it
- GT04 is an area of good quality farmland fully utilised for livestock and arable farming.
- GT04 will lack of Integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire
- The proposed site will have an adverse visual impact from Harbury and The Fosse Way (Roman Road).
- If GT04 were to be developed, the use of a vehicle or public transport to shops and schools is a necessity and not considered eco-friendly.
- The site will have a detrimental impact on tourism and visitors to Warwickshire especially including Mallory Court Hotel and a consequential effect on local employment.
- The site will damage wildlife habitat.

All of the above objections are both valid and reasonable, and I cannot understand why WDC are still considering GT04 as an option.

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

My comments and some of my concerns are as follows:

- WDC utilised the findings in the Salford GTAA report in order to establish need, however there is no
evidence of WDC's due diligence in validating the accuracy of the report and /or the relevance of the
established need.
- The WDC consultation does not consider as required the existing capacity of current sites within
Warwickshire county and adjacent districts.
- The GTAA ignores the impact of the planned Transit site near Southam which has been agreed
since completion of the GTAA
- According to the Government's planning policy framework, adjacent DCs are required to
collaborate, and yet Warwick DC and Stratford DC are very much out of phase with their
consultations so logically they cannot collaborate. Further there is no evidence that WDC has
collaborated or discussed with Stratford DC other than a reported "10 minute long but un-minuted
meeting" or with Rugby DC
- there is no evidence in WDC's consultation report that as required by NPFF and CLG , that WDC
have weighed up the cost to council of Compulsory purchase vs development of underutilised
brownfield sites including those that the council already own.
. - The WDC proposals will provide for more accommodation than there are G&T residents within
WDC boundary the vast majority of whom already live in houses so the requirement is clearly
seriously over-stated
- There is clear evidence via Hansard that MP's now want a fair planning policy that should result
in the abolition of the G&T planning requirement
- There has been little (and passive) publicity of the Consultation process and key milestones. Had
it not been for the local Community group I would not have known about it - it feels and looks
like this is a deliberate underhanded approach.

Specific to Site GT04:

- The site does not meet the fundamental planning criteria laid out in the NPPF, guidance from
Department of Communities and Local Government and WDC's own consultation documents for
Gypsy & Traveller sites. GT04 does not comply with planning policy whereby sites should provide
access to nearby services and quality of life. Specifically:-
- Accessibility to shops and local services: GT04 does not meet national planning framework
guidelines recommended 5-10mins walk on a pavement.
-Proximity to local community: GT04 does not meet the national planning framework
guidelines recommendation for sites to be on community periphery to encourage integration.
-Establishing 5-10 pitches at GT04 would be disproportionate to the local community
(8 residential properties, with 16 adults and 4 children). This is contradictory to national
planning framework guidelines recommendations.
- GT04 does not meet national planning framework guidelines recommendations for
accessibility to good local transport.
- GT04 does meet national planning framework guidelines recommendations for availability
of good infrastructure (roads, pavement, street lighting, broadband, cellphone reception).The
infrastructure at GT04 is poor and would require considerable investment to rectify. And this is an
expense that WDC should not incur during times of cutbacks in public expenditure and services.
- The area is prone to flooding with Harbury Lane and surrounding fields are often under water.
In accordance with planning and building regs, GT04 would be unable to use soak away or runoff
based drainage systems since the soil is clay based and will require connection to mains sewerage
which does not exist in Harbury Lane.
-Planning policy for G&T requires schools / GP surgeries to be a 5-10 minute walk away, GT04 is at
least a 45 minute walk away.
- The nearest GP surgery is three miles away
- that GP surgery is at capacity.
- The nearest primary, junior and senior schools are already at capacity.
- GT04 is located on Harbury Lane and Fosse Way cross roads that is a high risk travel route with high
volumes of traffic and an increasing number of accidents. Speed cameras and warning signs
highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to
school if indeed such transport exists
- According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This
raises serious environmental and health concerns, and was a primary reason that the potential G&T
site at Barnwell farm was previously rejected. Simply -Barnwell chicken farm can smell awful and
GT04 would not be a good place to live
GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and
which would make GT04 an unpleasant place to live but also an unhealthy one.
- The NPFF requires that the assessment of site suitability should be consistent with other
planning requests. However I understand that other residential planning applications within
200m of GT04 have been recently rejected by council planning authorities, referencing rural
policy on the grounds that the proposal would have an adverse "impact on the character of the
area".

- the cost to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's
figures (£65k per pitch). In addition to this, G04 site may require relocation of Football club. There
is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an
alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that
G&T can and will buy and develop it
- GT04 is an area of good quality farmland fully utilised for livestock and arable farming.
- GT04 will lack of Integration into the landscape and would spoil the views from Chesterton
Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire
- The proposed site will have an adverse visual impact from Harbury and The Fosse Way (Roman
Road).
- If GT04 were to be developed, the use of a vehicle or public transport to shops and schools is a
necessity and not considered eco-friendly.
- The site will have a detrimental impact on tourism and visitors to Warwickshire especially including
Mallory Court Hotel and a consequential effect on local employment.
- The site will damage wildlife habitat.

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

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

My comments and some of my concerns are as follows:

* I query the validity and accuracy of the Salford GTAA report in order to establish need.
* The WDC consultation does not consider as required the existing capacity of current sites within Warwickshire county and adjacent districts.
* The GTAA ignores the impact of the planned Transit site near Southam which has been agreed since completion of the GTAA.
* According to the Government's planning policy framework, adjacent DCs are required to collaborate, and yet there is no evidence that WDC has collaborated or discussed with Stratford DC.
* There is no evidence in WDC's consultation report that, as required by NPFF and CLG, WDC have weighed up the cost to council of Compulsory purchase vs development of underutilised brownfield sites including those that the council already own.


Specific to Site GT04:

GT04 does not meet national planning framework guidelines in the following areas:
* Not within recommended 5-10mins walk on a pavement for accessibility to shops, local services or good local transport
* Not on community periphery to encourage integration.
* No good infrastructure (roads, pavement, street lighting, broadband, cellphone reception) .
* G&T requires schools / GP surgeries to be a 5-10 minute walk away with GT04 at least a 45 minute walk away.
* The nearest primary, junior and senior schools & GPs are already at capacity.



The site is unsuitable and unpleasant for G&Ts because:

* The area is prone to flooding with Harbury Lane and surrounding fields often under water.
* In accordance with planning and building regs, GT04 would be unable to use soak away or runoff based drainage systems since the soil is clay based and will require connection to mains sewerage which does not exist in Harbury Lane.
* GT04 is located on Harbury Lane and Fosse Way cross roads which is a high risk travel route with high volumes of traffic and an increasing number of accidents.
* Children will be at risk if allowed to stand on a busy road to wait for transport to school.
* According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This raises serious environmental and health concerns.
* GT04 is within 400m of the Harbury Lane Breakers yard which generates noise and air pollution.


In addition,

* The cost to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's figures (£65k per pitch). In addition to this, G04 site may require relocation of Football club. There is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that G&T can and will buy and develop it.
* GT04 is an area of good quality farmland fully utilised for livestock and arable farming.

* The site will damage wildlife habitat.
* GT04 will lack integration into the landscape and would spoil the views from Chesterton Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire, and views from Harbury and The Fosse Way (Roman Road).
* If GT04 were to be developed, the use of a vehicle or public transport to shops, doctors and schools is a necessity and not considered eco-friendly.

Thank you for taking the time to consider our views.

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

My comments and some of my concerns are as follows:

- WDC utilised the findings in the Salford GTAA report in order to establish need, however there is no
evidence of WDC's due diligence in validating the accuracy of the report and /or the relevance of the
established need.
- The WDC consultation does not consider as required the existing capacity of current sites within
Warwickshire county and adjacent districts.
- The GTAA ignores the impact of the planned Transit site near Southam which has been agreed
since completion of the GTAA
- According to the Government's planning policy framework, adjacent DCs are required to
collaborate, and yet Warwick DC and Stratford DC are very much out of phase with their
consultations so logically they cannot collaborate. Further there is no evidence that WDC has
collaborated or discussed with Stratford DC other than a reported "10 minute long but un-minuted
meeting" or with Rugby DC
- there is no evidence in WDC's consultation report that as required by NPFF and CLG , that WDC
have weighed up the cost to council of Compulsory purchase vs development of underutilised
brownfield sites including those that the council already own.
. - The WDC proposals will provide for more accommodation than there are G&T residents within
WDC boundary the vast majority of whom already live in houses so the requirement is clearly
seriously over-stated
- There is clear evidence via Hansard that MP's now want a fair planning policy that should result
in the abolition of the G&T planning requirement
- There has been little (and passive) publicity of the Consultation process and key milestones. Had
it not been for the local Community group I would not have known about it - it feels and looks
like this is a deliberate underhanded approach.

Specific to Site GT04:

- The site does not meet the fundamental planning criteria laid out in the NPPF, guidance from
Department of Communities and Local Government and WDC's own consultation documents for
Gypsy & Traveller sites. GT04 does not comply with planning policy whereby sites should provide
access to nearby services and quality of life. Specifically:-
- Accessibility to shops and local services: GT04 does not meet national planning framework
guidelines recommended 5-10mins walk on a pavement.
-Proximity to local community: GT04 does not meet the national planning framework
guidelines recommendation for sites to be on community periphery to encourage integration.
-Establishing 5-10 pitches at GT04 would be disproportionate to the local community
(8 residential properties, with 16 adults and 4 children). This is contradictory to national
planning framework guidelines recommendations.
- GT04 does not meet national planning framework guidelines recommendations for
accessibility to good local transport.
- GT04 does meet national planning framework guidelines recommendations for availability
of good infrastructure (roads, pavement, street lighting, broadband, cellphone reception).The
infrastructure at GT04 is poor and would require considerable investment to rectify. And this is an
expense that WDC should not incur during times of cutbacks in public expenditure and services.
- The area is prone to flooding with Harbury Lane and surrounding fields are often under water.
In accordance with planning and building regs, GT04 would be unable to use soak away or runoff
based drainage systems since the soil is clay based and will require connection to mains sewerage
which does not exist in Harbury Lane.
-Planning policy for G&T requires schools / GP surgeries to be a 5-10 minute walk away, GT04 is at
least a 45 minute walk away.
- The nearest GP surgery is three miles away
- that GP surgery is at capacity.
- The nearest primary, junior and senior schools are already at capacity.
- GT04 is located on Harbury Lane and Fosse Way cross roads that is a high risk travel route with high
volumes of traffic and an increasing number of accidents. Speed cameras and warning signs
highlight this fact. Children will be at risk if allowed to stand on a busy road to wait for transport to
school if indeed such transport exists
- According to aroma maps GT04 is within zone of aerial discharge from Barnwell Chicken farm. This
raises serious environmental and health concerns, and was a primary reason that the potential G&T
site at Barnwell farm was previously rejected. Simply -Barnwell chicken farm can smell awful and
GT04 would not be a good place to live
GT04 is within 400m of the Harbury Lane Breakers yard, which generates noise and air pollution and
which would make GT04 an unpleasant place to live but also an unhealthy one.
- The NPFF requires that the assessment of site suitability should be consistent with other
planning requests. However I understand that other residential planning applications within
200m of GT04 have been recently rejected by council planning authorities, referencing rural
policy on the grounds that the proposal would have an adverse "impact on the character of the
area".

- the cost to create 5 to 10 permanent pitches ranges between £325k to £650k, using government's
figures (£65k per pitch). In addition to this, G04 site may require relocation of Football club. There
is no firm evidence that G&T can or will pay these sums of money and WDC have not suggested an
alternative if G&T cannot or will not pay. GT04 should not be considered if there is not proof that
G&T can and will buy and develop it
- GT04 is an area of good quality farmland fully utilised for livestock and arable farming.
- GT04 will lack of Integration into the landscape and would spoil the views from Chesterton
Windmill, a 17th-century Grade I listed building and a striking landmark in South-East Warwickshire
- The proposed site will have an adverse visual impact from Harbury and The Fosse Way (Roman
Road).
- If GT04 were to be developed, the use of a vehicle or public transport to shops and schools is a
necessity and not considered eco-friendly.
- The site will have a detrimental impact on tourism and visitors to Warwickshire especially including
Mallory Court Hotel and a consequential effect on local employment.
- The site will damage wildlife habitat.

I note that you have given Preferred Status to two G&T sites (GT02 + GT04) in the vicinity of Harbury. These sites were in your original discussion document and I raised my objections to them at that time. Below are my current ( and former objections).

In my opinion neither site should have got to this stage of the process as WDC has not, in my opinion, complied with government guidance in important areas (see below), which makes the whole process flawed and ipso facto any decisions resulting from said process invalid.

At the time the sites were originally considered there had been insufficient consultation as recommended in the government's guidance.
1. There was minimal contact with Stratford District Council. I have it in writing from the Chief Planning Officer that between February 2012 and January 2013 there had been just 3 meetings with SDC, only one of which had any minutes taken. Indeed, in the words of your Chief Planning Officer, "Although the council continue to hold dialogue with other councils and in particular Coventry City Council, Rugby Borough Council and Stratford District Council, sites within Warwick District have not been discussed at length."
In my opinion, this does not comply with the government's guidance notes
P5: Point 4:2
"to ensure that local planning authorities, working collaboratively, develop fair and effective strategies to meet need through the identification of land for sites"
and 9c
"consider production of joint development plans that set targets on a cross-authority basis, to provide more flexibility in identifying sites, particularly if a local planning authority has special or strict planning constraints across its area (local planning authorities have a duty to cooperate on planning issues that cross administrative boundaries)
2. Community groups prior to the decision on the sites were not consulted. A meeting was held in Harbury AFTER GT02 and 04 were put forward as preferred sites. This runs contra to the government's guidelines which state:
12- When assessing the suitability of sites in rural or semi-rural settings, local planning authorities should ensure that the scale of such sites does not dominate the nearest settled community."
3. The surgery and the school in Harbury were not consulted to identify if there was spare capacity. This is especially important given that I am led to believe money for extending any current facilities is either not available or extremely limited. This lack of consultation seems to be directly at odds with government guidance 4.11:"to enable provision of suitable accommodation from which travellers can access education, health, welfare and employment infrastructure"

The council failed to carry out any due diligence exercise on the Salford University GTAA report, which has formed the basis of its decision making. For example, WDC's own 2011 report identified the need for just 15 TRANSIT pitches and that "demand for permanent site-based accommodation was low and transitory in nature". Yet now we are led to believe that in addition to 15 transit pitches , there is now a need (according to Salford) of 15 PERMANENT pitches. Who has questioned this discrepancy?

Both sites will require the use of compulsory purchase powers. No costings have been provided either for the cost of purchase or for the loss of livelihood of those displaced by the compulsory purchase. This seems a fundamental issue, especially as current guidance from the ministry concerned with G&T sites indicates that such powers should NOT be used in relation to G&T sites.

Finally, I reiterate the following objections I made during the consultation phase:

a) Both GT02 and GT04 are located next to a busy commuter route . It is also a known that the Fosse Way is a high risk accident black spot and because of this, public transport would not be able to stop near the sites.

b) There is no separate provision for pedestrians or cyclists . Thus, at neither site is there any safe way for children to get to Harbury School without vehicular assistance (which seems, again, to run contra to government guidelines 4.11 "which travellers can access education,"). This would mean that the site would exacerbate parking and obstruction problems at the school, which have only recently been overcome . The school is already oversubscribed and is likely to remain so given the current village demographic.
c) As far as I can tell, sites GT02 and GT04 have no running water, mains sewerage, drainage or mains gas supply. Whilst the later can be overcome with the use of butane gas cylinders, the former are essential for public health and the prevention of pollution of local water courses. Such pollution is likely to damage local wildlife, grazing livestock and be a health hazard. In addition, the GT04 site is close to a chicken farm and so would be subject to strong atmospheric smells and pollution.

d) I note that your document mentions that sites should not have a high risk of flooding. Site GT04 does have a risk of flooding given that it is affected by water run off from Harbury.

e) Site GT04 will directly affect the view from the well-known Chesterton Windmill, which is important given the historic nature of the surrounding area.