I have the following concerns about GT19 being proposed a one of the preferred Gypsie/travellers sites.They are as follows:

1) The current site has always looked a "mess" & placing a Gypsie/travellers site is hardly going to improve it unless signiicant landscaping and visual improvements & specific regulations of how its used/kept tidy etc are made.This is a major road into Warwick & for an area that is somewhat dependent economically on tourism the current visual impact is already poor & as I've already said unless significant visual & landscaping improvements etc can be made the plans to have a permanent site would be a poor decision.

2) Under the original local plan placed online this site was deemed unacceptable for "normal" housing because,as I understood,it was unsustainable.If it was unsustainable for normal brick built houses how can it be proposed for caravans?

3) The current site does'nt generate a lot of traffic onto the Birmingham Road mainly because the business operating from there does'nt appear to have been that successful over the years & therefore has not generated much traffic.However,if a permanent Gypsie traveller site were established here the number of vehicle movements would increase,and with the proposed Hatton Park development, the volumes of extra traffic could be detrimental to the area without significant upgrading of the Birmingham Road(wider road,footpaths on both sides,lower speed limit,another roundabout etc). The current traffic in & out of the Shell Garage and the Ugly Bridge Road already causes traffic problems. The proposed site would just add to them & without a significant monetary investment could be become dangerous.Whats the estimated cost to the council,with all the changes that should be taken into consideration for this site? What traffic count does this area already have & whats expected with the proposed site

4)The general environmental affect of the proposed site on the adjacent canal & canal community could be significant backward step for all canal users.

5)The site proposed has,as detailed in your own documents,been breaching the planning laws for many years with caravans & to legalise it is sending a bad message.Whats changed?

I urge the planning officers,the planning committee & the council to think again about this proposal.

We wish to lodge an objection to the proposed travellers site on the A4177 by the Shell garage.

We feel the A4177 simply will not be able to cope with a greater volume of traffic than it now has, the road is the main link into Warwick, also to the A46 and onto the M40, the volume of traffic is such that the road is frequently at a standstill in a morning, the speed of the traffic will mean any vehicle trying to turn into/out of the proposed site will be disruptive & positively dangerous. Especially when there is already a constant flow of traffic in/out the Shell garage. The A4177 is a dangerous road as fatalities over the last few years have proved.

Whilst aware that the proposal is for only five caravans, the likelihood is that far more than this will congregate, as happened at the Kites Nest Lane site which, incidentally, looked a terrible mess most of the time it was there, will any watch be kept on this, what action will be taken when more than five caravans are on site, the Kites Nest Lane site most certainly had more caravans on it than were permitted & nothing was done to bring the amount down to the agreed level while they sort permission to stay there, who will ensure the site is kept clean & free of debris. If this goes ahead who is going to pay for the utilities to be connected to the site, who will pay the council tax, who will pay for refuse collection. We all pay heavily for these services will the travellers do the same?

As the A4177 is one of the main routes into Warwick, the approach to the town will look awful when the site is in full view of the road, is that really the impression you are trying to give to the very vital tourism industry that Warwick depends on? Warwick Council dismissed the planning option of building houses opposite Brownley Green Lane as it would be seen from the A4177 & would disturb the canal use, surely a travellers site would do precisely the same, are double standards coming to the fore here? Having one rule for one site & another rule for another site on the same stretch of road & canal is not acceptable.

Also there is the need for school places to be found for the travellers children, as all the local primary schools are full, where will they be schooled? Warwick Council does not believe in all siblings going to the same school, will this mean even more cars on the A4177 during rush hour when the parents of the children have to shoot off in different directions to take their children to different schools? Which GP surgery has the capacity to take on extra patients? Will Warwick hospital have the capacity to deal with more patients? Is the infrastructure in place to take these extra people on?

We would be most grateful to have these concerns answered properly and in full.

RE: Written objection to Gypsy/Traveller site proposed at
OAKLANDS FARM SITE, BIRMINGHAM ROAD, near Hatton Park

I am writing to firmly object to the proposed site as listed above. This, may I politely say, is a thoughtless idea due to the following valid reasons:-

1) Local schools are already full and bulging at the seams.

2) GPs locally are also full and over-stretched.

3) The site will cause a traffic hazard on the Birmingham Road, which is already gridlocked in the mornings at rush hour. This is because it is the route everyone uses to access Warwick/M40 and A46. This site would cause even more traffic congestion.

4) The pollution and mess/rubbish produced by the site would spoil this beautiful area, and would look 'out of character' with how everything else looks within that area.

5) Would have a massive detrimental effect on family leisure activities and tourism around the canal, beauty would be lost and people would not use the lovely café which relies heavily on visitors to the area. All leisure pursuits/families would go elsewhere.

6) Highly visible site not in tune with how the rest of the area looks.

7) Would cause undue stress to local residents who have lived here happily for many years, and who are very different to Gypsy/Traveller people. This will inevitably result in negative relations, in turn causing the Council and Police regular complaints/more work. Why do this to an area which is very peaceful and unspoilt?

May I respectfully suggest the site proposed at Junction 15, M40, as this is perfect for vehicle access/traffic, not very near at all to private residences and with more choice for schools and GPs.

Many thanks for your urgent attention.

I have been unable to find a form on line so have written this email to lodge my objection to this site for the following reasons;

It does not meet your criteria as laid down in section 6.1 of appendix 2, G&T PO consultation document re;

Convenient access to a GP surgery, school, and public transport - public transport is poor in the area.
Safe access to the road network - it is on a busy main road which is already suffering from traffic problems and long queues, and is certainly not safe for children.
Promotes peaceful and integrated co-existence between the site and the local community - bearing in mind the number of objections and the type of community in the area, this is highly unlikely so cannot possibly meet your criteria.
Avoids placing undue pressure on local infrastructure and services - this site will cause additional pressure on all facilities and there is also a proposal for additional housing at Hatton Park which if successful will add to the local infrastructure needs.
Reflects the extent to which traditional lifestyles (whereby some travellers live and work from the same location thereby omitting many travel to work journeys) can contribute to sustainability - how can this site do this?

Written objection to Traveller site proposed at
OAKLANDS FARM, BIRMINGHAM ROAD, Warwick

I am writing to register my formal and firm objection to the proposed site as listed above. This is a thoughtless idea which will result in an enormous amount of disruption and stress that will, in turn, leave permanent damage/ruin to this beautiful area. My reasons why this plan should not go ahead are as follows:-

a) Local schools are already too full.

b) GPs locally will not cope.

c) The site will cause a traffic hazard and congestion to an already busy route which everyone uses to access Warwick/M40 and A46.

d) The pollution, mess/rubbish produced by the site would spoil this scenic area, and would be out of keeping with the natural beauty of this lovely area.

e) Huge negative effect on family leisure activities/tourism around the canal, beauty would be lost and people would not use the lovely café which relies heavily on visitors to the area. All leisure pursuits/families would go elsewhere. A popular area for families and tourists would be lost forever.

f) Highly visible site which would look totally out of place in this area.

g) Would cause undue stress to local residents who have lived here happily for many years, and who are very different to Gypsy/Traveller people. This will inevitably result in negative relations, in turn causing the Council and Police regular complaints/more work on a permanent basis.

h) The site is far too close to the attractive houses on Hatton Park and those which are situated along the Birmingham Road. A traveller site would devalue properties, tarnish this area and put off developers from building desirable dwellings/investing in this area.

Why do this to an area of natural beauty by the canal which is very peaceful and unspoilt?


Many thanks for your immediate attention and registration of this objection

I am writing to object to the proposed plans for Oaklands Farm to a Permanent Gypsy Site, Kites Nest and other local planning on the Birmingham Road are ; they are as follows:

1: The current owner & his father before him have applied for change of use/ building of small residential houses for many years & only recently been granted planning permission for 1 home & outbuilding. As a council you have objected due to the land accessing a country lane & the busy Birmingham Rd, along with other objections which are a matter or record. Proof of the dangers of this road are public knowledge with many deaths and serious injuries; which has seen yet again been brought to our attention the last few weeks with RTA's one of which requiring the Air Ambulance to attend!

2: A4177 Birmingham Rd is the main road between Warwick and the second city Birmingham this handles not only increased local traffic but Warwick Towns lifeline of visitors to its historic town and famous canal side. Putting a gypsy site there would intimidate people using the canal, it's walkways; this had already happened at the illegal Kites Nest Site where people did not feel safe to walk or take their dogs due to the attitude of the illegal residents and their aggressive dogs. Does Warwick council really want to deprive the local shops, businesses and town folks of their incomes and feeling safe in their surroundings and driving potential much needed visitors away?

3: There is also the increase of pollution whether from activities that would take place on such a site or motor vehicles; our community should be protected from this. Warwick already suffers from pollution levels above European guidelines on safety. This not only takes it toll on our health but also the structure of our historic buildings.

4: The 1993 Local Plan along with the inspectors report in 1994 required measures to reduce the impact of traffic on our town centre; and yet over a decade on we have been unable to mitigate the traffic effect on this development, despite funding from the developer.

5: The local infrastructure cannot cope wether it being our local GP's, Hospital, Schools or Emergency Services; these should be paramount to being brought in line for the existing residents before adding to our community. These plans should be in place prior to any others for additional housing or traveler sites.

6: We should be looking at using empty properties, factories and building sites before using our treasured green belt areas for future housing; one can only presume it is easier and less costly for a developer to clear existing neglected housing and sites; they just want to make as much profit as they can in the shortest of time regardless of the local people and their feelings or safety.

7: As much as you do not consider the value of people's properties to be important in your proposals, it has shown in other areas that house prices can fall by up to 40% where gypsy sites, illegal or otherwise are. As a home owner and having worked for everything I own, paid taxes, national insurance etc I feel having contributed into the system along with other hardworking taxpayers in our area that our home is our castle and should not have its value diminished by these sites.

8: We should therefore not have inflicted upon us non contributing, untidy and unruly people living within our community as the gypsy site proposals you as a council have put forward. Kites Nest illegal site has shown no respect to the locals or yourselves as councillors as they have blatantly disregarded the law and cost thousands of pounds opposing over the last three years!!! It is beyond belief that you now consider giving into this and even thinking of having a proposed additional site on the busy Birmingham Road on Oaklands Farm area.

9: Putting gypsy sites in and around our village would hamper any future development of your housing as people would not be prepared to purchase homes with these sites in place. This is surely being very short sighted as a council representing our community.

I look forward to your response as a a tax payer who contributes to the local community charges.

We wish to lodge an objection to the proposed travellers site on the A4177 by the Shell garage.

We feel the A4177 simply will not be able to cope with a greater volume of traffic than it now has, the road is the main link into Warwick, also to the A46 and onto the M40, the volume of traffic is such that the road is frequently at a standstill in a morning, the speed of the traffic will mean any vehicle trying to turn into/out of the proposed site will be disruptive & positively dangerous. Especially when there is already a constant flow of traffic in/out the Shell garage. The A4177 is a dangerous road as fatalities over the last few years have proved.

Whilst aware that the proposal is for only five caravans, the likelihood is that far more than this will congregate, as happened at the Kites Nest Lane site which, incidentally, looked a terrible mess most of the time it was there, will any watch be kept on this, what action will be taken when more than five caravans are on site, the Kites Nest Lane site most certainly had more caravans on it than were permitted & nothing was done to bring the amount down to the agreed level while they sort permission to stay there, who will ensure the site is kept clean & free of debris. If this goes ahead who is going to pay for the utilities to be connected to the site, who will pay the council tax, who will pay for refuse collection. We all pay heavily for these services will the travellers do the same?

As the A4177 is one of the main routes into Warwick, the approach to the town will look awful when the site is in full view of the road, is that really the impression you are trying to give to the very vital tourism industry that Warwick depends on? Warwick Council dismissed the planning option of building houses opposite Brownley Green Lane as it would be seen from the A4177 & would disturb the canal use, surely a travellers site would do precisely the same, are double standards coming to the fore here? Having one rule for one site & another rule for another site on the same stretch of road & canal is not acceptable.

Also there is the need for school places to be found for the travellers children, as all the local primary schools are full, where will they be schooled? Warwick Council does not believe in all siblings going to the same school, will this mean even more cars on the A4177 during rush hour when the parents of the children have to shoot off in different directions to take their children to different schools? Which GP surgery has the capacity to take on extra patients? Will Warwick hospital have the capacity to deal with more patients? Is the infrastructure in place to take these extra people on?

We would be most grateful to have these concerns answered properly and in full.

I am writing to strongly object to the proposed gypsy site on the Oakland farm, Birmingham road. It is a totally unacceptable site, being so close to both a really busy main road and a canal, for people to reside beside. It makes no sense for such a location to be used, for such purposes, and in my opinion is an accident waiting to happen. Over and above this there are multiple other reasons why such a site should not be located in this location, many of which have been voiced in the mass number of objections previously submitted. I urge you to strongly think again in choosing this fatally flawed location.

As a Hatton Park resident, I would like to strongly object to the above planning proposal.

My main objection is due to the inadequate road infrastructure (Birmingham Road) which is already an extremely busy and dangerous road. It cannot cope with the volume of traffic in rush hour presently, and causes daily distress getting our children to school. I would like to add at this point, we operate a car share with other parents to help minimise the volume of cars on this route and have to leave Hatton Park one hour before school starts, in order to get ahead of the traffic, to travel 3 miles into Warwick. This is not London - it is Warwick!

I cannot believe ANY proposals which would impact using the Birmingham Road near Hatton Park for access, would be seriously considered by Warwick District Council. Only last weekend, there was a serious accident on this road, which required the assistance of an Ambulance and other Emergency Services.

I seriously suggest Warwick District Council consider alternative sites which would be a safer option for everyone.

I would like to formally object to the option of having the Gypsies and Travellers site located at the following area:

GT19 - Land off Birmingham Rd, Budbrooke, Oaklands Farm
I note in your appendix 2 from the formal council meeting that you deem this site to be a good option for the site (and have given it a 'green' rating).
In doing so, I can only assume you have ignored all your own stated criteria for such an assessment and have decided to ignore the valid points already highlighted as objections (shown below to remind you):
* Green Belt land that should be preserved
* Would destroy countryside
* Access onto main road will increase traffic hazards. Notoriously
difficult and dangerous road with speeds in excess of 40mph
limit and bend in road limiting visibility
* Close to heavily populated urban area and highly visible so not in
keeping with locality
* Distracting to passing motorists
* Schools are oversubscribed
* Canal bridge suffers from subsidence and unsuitable for heavy
vehicles and very narrow for caravans
* Site has been breaching law for years with caravans occupying
the site. To legalise is sending a bad message
* Potential for unauthorised expansion
* Negative effect on property values
* Unattractive on approach to Warwick
* Effect on tourism
* Grand Union Canal recently upgraded towpath and locks are
popular with walkers, family groups, canal cruisers and anglers
* Direct access to the Canal from at least two points at Oaklands
Farm. Leakage of noise and waste onto canal bank
* Impact on important features of natural and historic
environment
* GP surgery already stretched
* Dentists at capacity
* Any further development to small community on Birmingham
Road will spoil quality of life
* Should be well away from existing communities
* Would hamper any future development of housing
* Possibility of ribbon development in green belt
* Close to railway lines and bridges
* Close to petrol station with dangers of waiting vehicles on road,
fumes, emissions and pollutants
* Effect on cleanliness and tidiness of canal and towpath
I therefore would like to formally add my objections to this site as a local resident for all the reasons outlined above.

-With reference to the Hatton Park development, these are some concerns I have;

1. I object to the proposals to allocate 90 additional houses on Hatton Park set out in the Village Housing Options and Settlement Boundaries Consultation of November 2013.

2. Hatton Park is not sustainable in terms of offering a good range of services/facilities or good accessibility to services/facilities - particularly by public transport and no evidence is provided in the Consultation document or preceding documents.

3. Hatton Park does not have good public transport connections. The 68 bus service that serves the estate is infrequent, unpunctual, unreliable and does not integrate with the rail service.

4. I have concerns over the safe access to the road network particularly given the proposed two new accesses including one directly onto the Birmingham Road (A4177) and the impact of the additional trips that would be generated by the proposed additional houses. Notably there are a number of existing accesses onto the Birmingham Road in close proximity to the proposed new access and specific visibility issues are identified in the Site Appraisal Matrix (Appendix 6 of the Consultation document).

5. Warwickshire is experiencing a significant growth in pupil numbers and demand for places is currently outweighing availability. Notably, in 2012, there was a consultation on proposals to increase the Published Admission Number (PAN) of The Ferncumbe CE Primary School from and to re-allocate the Hatton Park development across the priority areas for Budbrooke Primary School and The Ferncumbe CE primary School to help the Local Authority to meet its statutory duty to ensure a sufficiency of places.

6. I consider that the proposed 90 additional houses will place undue pressure on local infrastructure and services - particularly local schools and the road network in isolation and together with the options for two Gypsy and Traveller sites in the vicinity as set out in Warwick District Council's document Sites for Gypsies and Travellers (June 2013).

The A4177 is truly awful already ... the idea of adding another what 180 cars potentially onto that road at 8.30 in the morning seriously concerns me.

We wish to strongly object to the proposed gypsy in Budbrooke next to the Shell Garage. Having disputed the site for years on Kites Nest Lane with huge disruption to the community, the same principle applies that this is destroying yet again Green Field sites and have previously been rejected for caravan storage and change of use due to the destruction of green belt land.

This is an extremely busy and dangerous road with fatalities directly next to the area so more traffic and turning of vehicles would increase this danger.
Any development would be totally obvious from the canal, the road and dwellings nearby destroying the countryside and the community.

We would like to register our absolute objection to the traveller site proposed for the above location .

It is a highly dangerous road layout where I have myself seen several car accident when dealing with the main road, side road, petrol station and the site itself.

It is an extremely busy road for residents to cross and walk to the walkway opposite which is inevitable and especially if there are young children who want to play in the forest and parkland close by.

It is a tourist spot with the canal that brings great tourism and natural surroundings to the area. As a local we see how many people use the canal and the cafes and pubs as a day out. This will look very unsightly ruining the look of the whole landscape and what the council have built up.

There are much more suitable , larger pieces of land in the proposal that we would urge the council to consider appreciating they have targets to meet but this land is wholly unsuitable for such a project.

If the proposed houses are to be built opposite this will be a very bad selling point for prospective buyers, plus the view they will look onto. The two strategies are not aligned together at all.

I am amazed by the lack of notice given to attend the open meeting and also the way the local plan has been notified .......I have received nothing about it other than via the local action group.
I feel you have not given residents and I who live in Hatton Park - Tredington Park enough time to object.
Also there is no way to object on your website as not currently under a site planning application.
However I cannot believe how you have poorly managed traveller site applications and sites around Hatton Park you have not dealt with the Beausale site yet?
The area will be over development with two housing developments being planned and will no longer will be an area of beauty, green belt attractive to tourists and locals for walks.
I am objecting about the traveller site at Oaklands Farm - Birmingham Road for the following reasons:
1. The area is an outstanding beauty area and with housing development has enough growth affecting the countryside.
2. Why are you not using derelict inner city / town areas for travellers who will not affect local people first rather than one of the county's most beautiful / tourists / leisure locations.
3. Caravans entry and exit will be dangerous as the Birmingham road is a commuter zone and the road is fast despite traffic calming.
4. You allow illegally the Beausale site without any ability to control the set-up of travelers, building etc. surely the area has enough travelers.
5. The Birmingham road is one of Warwick's main entry roads surely we do not want a travellers site on it.
6. With the development of Warwick Parkway, housing around Hatton Park there is now getting too much road traffic / over development and there are plenty of better areas for travelers to go which are not having these other developments.

I would like to object the following site "GT19 - Land adjacent Shell Petrol Filling Station, Birmingham Road, Budbrooke, Warwick".

I find it strange that you want to place the site next to a busy road with caravans turning in.

very small site

I object strongly to the traveller's site being put on the Oaklands Farm site on the Birmingham Road which is within the Green Belt. A proposed traveller site has already been refused planning permission in Kites Lane due to it being within the Green Belt ( which the council used as one of their objections) The site is situated on one of the busiest road in the Warwick area & even though the site has already being given planning permission for pleasure caravans this very different as the travellers will be entering & exiting the site more due to their business which uses trailers . This road has already been the scene of several accidents one being fatal only a few hundred yards from the proposed entrance to the traveller's site. Also the Birmingham Road is one on the main roads into Warwick so having a traveller's site in full view of tourist which could give a bad impression & impact the tourist trade. The site is situated between a canal & a busy road so there is a health & safety issue with the travellers children & animals. Also having the entrance to the travellers site near to the proposed entrance to the new 70-90 houses would cause traffic problems on an already busy road.

I write on behalf of myself and and my wife to object to the inclusion of the proposed site GT19 (Oaklands Farm)
We have already expressed our objection to the inclusion of this site previously, but would like to make the following additional comments about the points made in the report to members in proposing this site
It is described as a previously developed site - the area suggested is a small green space, which is sometimes used by the odd touring caravan
Services are already provided - my understanding is the only 'services' provided are a water tap and access to a flushing toilet.
There will obviously need to be significant costs in provided appropriate 'services' - is this proposal economically prudent given the proposal is for 5 pitches, when these costs could be incurred on another site for far more more pitches at probably a similar cost - surely a significant consideration for the council in the current economic climate?
Access and fewer movements of large vehicles - as I have previously stated very few touring caravans currently make use of this site - I am sure the owner can provide you with actual figures. I would suggest that there is likely to be significantly more movements of large vehicles as the travellers go about there day to day business, as this usually involves lorries I believe.
I have written to Budbrooke Parish Council to ask if they can confirm that there are places available at the school and GP surgery mentioned in the report.
Finally has consideration been given to the fact that a site almost opposite this proposal, has been included as a preferred option for additional housing?

We object to preferred site option at Birmingham Road Budbrooke and alternative sites at Budbrooke Lodge and Hampton Road, Hampton on the Hill on the following grounds which were raised at the Warwick Parish Council meetings.

We at Hatton Station do not enjoy the infrastructure which would support this kind of influx of settlement and population. We have no playing fields or playgrounds for children and teenagers, no pavements, no street lighting and very slow broadband. The local lanes are narrow and traffic such as school buses are more and more frequent, and dangerous to local rural horseback riders.

The local school at Fernculme is fully subscribed as are Snitterfield and Hampton Magna schools. Our local GP surgeries and Warwick hospital are under strain. With no street lighting and Warwickshire lighting being dimmed nighttime crime is on the increase. We are increasingly under threat from crime in broad daylight which just 5 years ago did not exist in this area. The incidents are all there to see in our neighbourhood watch scheme.

Finally, we only heard of the deadline for objection from our neighbours at number 28 since they had received an email from WDC. Why not everyone? This is a stealthy approach. Communications should be to all in the District affected in fairness to us who pay our council taxes and live here.

1) I support all five sites listed as Preferred Options
2) I object to inclusion of site GT11 in the list of Alternative Sites, for reasons stated in my submission to initial consultation of June 2013, as per attached file
3) i reserve the right to submit further comments and/or objections on any listed site(s) prior to any final decisions being made by the Council

SITES FOR GYPSIES & TRAVELLERS, JUNE 2013
SITE GT11 - SUBSTANTIVE OBJECTIONS
I was quite shocked to learn that this land, labelled GT11, adjacent to the Chase Meadow estate, is being considered by the Council for use as a possible large scale permanent site for Gypsies and Travellers (Gypsies and Travellers Sites - Options for Consultation, June 2013, Warwick District Council) in connection with its new Local Plan.
Indeed, there are so many reasons why the use of a large part of this land as a Gypsy and Traveller site cannot possibly fit any rational planning policy criteria that, as a qualified planner, I have to question why it was ever considered in the first instance?
It is hard to know where to start with objections to this proposal but in this detailed submission I set them out in three sections as follows:
 Objections to the Council's approach to needs assessment, which underpins the subsequent site search options.
 Specific objections to site GT11.
 Recommendations for a sustainable approach to site search and assessment, with additional potential sites proposed.
Throughout this submission, 'GTC' refers to Gypsy and Traveller Community; 'the Council' refers to Warwick District Council (WDC); 'the District' refers to Warwick District.
OBJECTIONS TO OVERALL APPROACH
1. Assessment of Accommodation Need - General Approach
The document 'Planning Policy for Travellers Sites', March 2012 is part of the National planning framework and sets out guidance in respect of the government's aims in respect of traveller sites, an extract from which states:
 to ensure that local planning authorities, working collaboratively, develop fair and effective strategies
 that local planning authorities should make their own assessment of need for planning purposes

In addition, the 2011 Localism Act sets out a 'duty to co-operate' in the production of joint development plans on a cross-authority basis, especially where a local planning authority has planning constraints across its area as in Warwick District where the Green Belt covers 81% of its modest 109 square miles, (in comparison Stratford District contains 378 square miles).
However, in respect of the foregoing, the Council admits it has attempted to, but failed to liaise and work with adjacent councils, both in assessment of need and in the identification of suitable sites, and has therefore continued to try and identify land within its own boundaries to serve its own need, ie at a relatively small geographical scale.
Such an approach makes little sense in relation to the GTC, which is by its very nature transient, and where administrative boundaries have little if any, relevance. Thus identification of need and planning of site provision is best carried out at a larger (sub-regional or county) scale in order to be strategic, robust, rational and equitable.
The Council's approach to this issue can therefore be seen to be fundamentally flawed, even at this preliminary stage.
2. Assessment of Accommodation Need - Quantification
Since 2008 there have been a whole series of GTC accommodation needs assessments for permanent pitches the District, with widely varying results.
The original 2008 (South Housing Market) assessment identified a District requirement for 11 permanent pitches, subsequently the Regional Spatial Strategy allocated 23 to the District for the period 2007 - 2017.
However the Council subsequently rejected this figure suggesting it was based on limited evidence and therefore not robust or reliable, and undertook its own assessment which reported in April 2011. This concluded that demand for permanent GTC sites in the area was 'low and transitory in nature' and recommended provision of a 12 pitch transit site only, (15 caravans).
In 2012 the Council appointed consultants from Salford University to carry out a detailed assessment of GTC accommodation needs within the District. Although the final report is quite lengthy, the key figure of 31 permanent pitches (2012 - 2026), is based fairly simplistically on current (2012) unauthorised encampments of 23 pitches (1 pitch = 1 household). However, their separate estimate, from interview survey, of the number of GTC households 'based in the District' was 30, but of these, only 7 were actually living in caravans, the rest were living in bricks and mortar houses!
In view of their wide range, the reliability of all these estimates of GTC permanent pitch need must be questionable.
OBJECTIONS TO SITE GT11
Site Location and Nature
This is a substantial area of search, within which a large site of 12 pitches/19 caravans would be located i.e. approximately 6,400 m2 in area, (at 500 m2 per pitch). Such a site would be expected to accommodate some 45 persons, based on an average GTC household size of 3.7, however it is not unreasonable to take this as a minimum estimate for planning purposes.
Bounded by mature trees to the A4189, it is currently in use as farmland but also contains a spur to the racecourse track and one large residential property. The area is less than 20 metres via the A4189 from the edge of Chase Meadow, a large residential estate of approximately 1,000 dwellings, due to increase to approximately 1,400 when fully developed. Hence present and future population figures of 4,000 and 5,600 respectively can be estimated for the estate at an average of 4 persons per dwelling.
Assessment against Policy Criteria
The suitability of GT11 can partly be determined by assessing the extent to which the site meets, or fails to meet, each of the 10 policy criteria as listed in the Council's document 'Sites for Gypsies and Travellers', June 2013, paragraphs 7.3 and 7.4, as listed in the next section.
It should be noted however that these ten are not necessarily the only or the most appropriate criteria, have not been consulted upon, moreover they do not fully take into account the National guidance ('Planning Policy for Travellers Sites', March 2012), as they omit a key National policy requirement, namely the protection of local amenity - see page 7.
1. Convenient access to a GP surgery, school, and public transport
Whilst access to these may be physically convenient, both the local GP practice on Chase Meadow and both Newburgh Primary and Aylesford schools have no spare capacity, primarily due to existing demand from the resident population of the Chase Meadow and Forbes Estates and from projected future demand from the former - an additional 1,600 persons. Moreover, in the case of the schools, the demand on teaching time and resources from the GTC is likely to be disproportionately greater per pupil than from the settled community, due to the former's well documented special educational needs
CONCLUSION - FAILS
2. Avoiding areas with a high risk of flooding
The site is directly bounded to the east by the Gog Brook and a tributary stream to the north, the former falling within the Environment Agency's Flood Zone 3, hence a measurable risk of flooding is present. (See also under 3. below)
CONCLUSION - FAILS
3. Safe access to the road network and provision for parking, turning and servicing on site
In the vicinity of the site, there is already a high volume of peak time traffic flows along the A4189 Hampton Road with eastbound traffic approaching at relatively high speeds and considerable traffic turning movements from and into the Chase Meadow and Forbes estates. Due to the high levels of GTC vehicle ownership, the proposals for this site would significantly exacerbate traffic congestion by generating additional flows and turning movements, in particular of large, slow moving commercial vehicles, many towing caravans and/or trailers. Moreover, this is a road that is subject to periodic flooding in the vicinity of the racecourse main entrance, and where the road is restricted in width due to parked vehicles along the residential frontage.
CONCLUSION - FAILS on safe access
4. Avoiding areas where there is the potential for noise and other disturbance
The site is subject to significant traffic noise from the adjacent A46. A related issue is the 'noise and disturbance' which might be generated by the resident GTC themselves and so would be likely to adversely affect the amenity of adjacent Chase Meadow residents. CONCLUSION - FAILS
5. Provision of utilities (running water, toilet facilities, waste disposal, etc)
As this is essentially a green field site, there are no utilities present; they would all have to be provided from scratch at considerable cost and higher than that for other brown field equivalents.
CONCLUSION - FAILS
6. Avoiding areas where there could be adverse impact on important features of the natural and historic environment.
This is a sensitive urban fringe location, adjoining the Green Belt boundary at the A46 by pass, and this importance was reflected in its designation by the Council in 2012 as a 'Green Wedge' search area, areas that the Council are committed to protecting in future:
The Council will identify and protect a network of green wedges important for their ecological, landscape and/or access functions in the setting of differing urban areas and urban rural fringe. It is intended that this approach will revise and replace the existing policy of Areas of Restraint in the Local Plan 1996 - 2011.'
(New Local Plan Preferred Options report, May 2012, WDC, paragraph 15.14).
Related to the above, the site lies at a key 'Gateway Route' via the A4189, into the town of Warwick. Despite screening, due to its large scale there would most likely be an adverse visual impact from the perspective of both the racecourse and the A4189. In particular in the case of visitors and coach borne tourists approaching from the east, their first visual impression of Warwick, a town of national historic and cultural importance, would be a large gypsy encampment!
CONCLUSION - FAILS
7. Sites which can be integrated into the landscape without harming the character of the area.
As for 6. above.
CONCLUSION - FAILS
8. Promotes peaceful and integrated co-existence between the site and the local community
Site locations close to existing residential areas are more likely to increase rather than reduce tensions between settled and traveller communities, especially if both are at larger scales as with GT11. This is due to fundamental incompatibilities between the two communities, arising from the nature of the GTC culture, way of life and economic activity, and regardless of whether sites are authorised or not.
There is also evidence that crime and antisocial behaviour increases due to the presence of large numbers of the GTC in a locality.
CONCLUSION - FAILS
9. Avoids placing undue pressure on local infrastructure and services
As for 1. and 3.
CONCLUSION - FAILS
10 Reflects the extent to which traditional lifestyles (whereby some travellers live and work from the same location) thereby omitting many travel to work journeys, can contribute to sustainability
There will be no net increase in 'sustainability' as the same factors already apply to existing unauthorised sites, and all GTC sites will generate many 'travel to work' journeys. Moreover, to the extent that these sites are commercial and industrial in nature as well as residential, this is clearly incompatible with established planning principles of zoning and separation and likely to be detrimental to local amenity and environment. ie detract from 'sustainability'.
CONCLUSION - FAILS
The protection of local amenity is an important consideration in any planning process and a specific requirement of the government's March 2012 guidance for traveller sites: 'for local planning authorities to have due regard to the protection of local amenity and local environment'
It has already been noted this key aspect is not even included in the Council's 10 criteria, and one has to question why - could it be because the Council are fully aware that GTC sites invariably have a detrimental effect on local amenity, and extending beyond the boundaries of the sites themselves?
There have been several large scale unauthorised gypsy encampments in the District in recent years, including locations in Kenilworth, on Warwick Racecourse and on Myton Fields. In all these cases it is on the record that the sites have been left badly littered and degraded when vacated, requiring costly clean up and remediation work, all paid for out of public funds. Similar ongoing negative impacts are likely to be generated with permanent sites, which could affect the amenity of any adjoining residential areas. The larger the sites and the closer to the residential areas, as in the case of GT11, the larger the impacts are likely to be.
CONCLUSION - FAILS
SITE SEARCH AND ASSESSMENT
Site Search and the Green Belt
Twenty options for sites/areas of search are listed, the sizes are not given but many comprise substantial areas. The distribution of these sites within the District is noticeably skewed, with 65% located in the south, 40% immediately west of Warwick and 4 or 20% located within 1 kilometre of a major residential area, Chase Meadow estate
The Council may claim this is due to a need to protect the Green Belt from inappropriate development, but it is also a result of the Council's failure to co-operate with adjoining councils, necessary because it is both small in area, and predominantly Green Belt.
It is important to note at this point that Chapter 9 of the 'National Planning Policy Framework', March 2012, makes it clear that the Green Belt, which covers the northern four fifths of the District, does not represent an insuperable barrier to development; indeed the preparation of a new Local Plan provides opportunities 'to review and adjust Green Belt boundaries and also to identify areas for development' (Paragraph 84).
The Council took on board this National guidance in its Green Belt policy, (New Local Plan Preferred Options report, May 2012, WDC, Chapter 16), which allocated substantive residential and employment development on Green Belt land with associated boundary adjustments. The justification for this Preferred Option was set out in the Housing Chapter of the same report, and although Chapter 16 is silent on GTC sites, it seems logical that they would be permissible on the same grounds as housing. Regrettably, and misguidedly, the Council has now changed its approach to the broad location of growth from that set out in the May 2012 report, and which is now the subject of major but separate objections.
Nevertheless, the March 2012 National Policy Framework still applies and should be taken into account by the Council in the identification of suitable traveller sites, as outlined in the next section.
Site Search Process
As things currently stand, in moving to the next stage of this part of the Local Plan process the Council will need to identify a 'preferred' list of suitable sites, not necessarily from the current options.
How should the Council go about this crucial next stage?
Good access to the trunk road network and locations within reasonable travelling time, say 15 minutes, of major urban areas should be the key initial considerations.
As the GTC have high levels of vehicle ownership, the availability of public transport is a subsidiary issue.
A sequential search process, (a well established planning principle), should then be followed, starting with brownfield sites, (which may already have some infrastructure, utility connections etc), including those close to/adjacent to industrial/commercial land use areas.
Only when the previous stages have been exhausted would it be necessary to consider greenfield sites, some of which may be in the current Green Belt and starting with those close to/adjacent to agricultural/industrial/commercial land use areas.
Only as a final stage, and if necessary, would consideration be given to greenfield sites close to or adjacent to small scale residential areas.
There should be no need in this process to consider sites close to or adjacent to large scale residential areas, with all the conflicts and problems this would be likely to generate. Indeed, a search exclusion zone of at least 1 mile should be applied around such areas. The reason for this is the fundamental incompatibility between the GTC and the settled community, due to the nature of the GTC culture, lifestyle and economic activity, previously referred to.
At each stage, sites can be assessed against the relevant national and local policy criteria.
As an example of a robust and rational approach to site assessment reflecting the above principles, I would commend that recently adopted by Lewes District Council, ('Gypsy and Traveller Site Assessment 2011 - Lewes District Council'), based on a set of 14 criteria, which had been widely consulted on by both the local settled and traveller communities. Sites were scored against each criterion, and subsequently ranked.
One of the criterion was the proximity to large numbers of residential properties, identified as a negative factor, on the grounds that:
'In order to promote understanding and tolerance between local residents/landowners and Gypsies and Travellers, it is important that any impact on the living conditions for local people are acceptable. The number of residential properties in proximity to sites is therefore a factor'
This is yet another very good reason to reject site GT11 on the grounds of its proximity to the large Chase Meadow estate.
Locations Not Yet Considered
There are a number of locations apparently not yet considered by the Council with potential to provide suitable sites, including:
 Castle Park - an extensive tract of land to the south of the town but with no public access
 Various areas of vacant land north of Warwick town centre in the vicinity of the canal, e.g. sites around Lower Cape
 Open fields adjacent to the river/canal/railway line between Warwick and Leamington
 Areas adjacent to Warwick/Leamington southern urban fringe and industrial estates e.g. Gallows Hill, Heathcote Lane, etc
In conclusion, this objections submission clearly shows the perversity of ever including site GT11 in the present options list, a site which demonstrably fails to meet ANY of the relevant national and local policy criteria. Thus, the Council should give no further consideration to this site.
Whilst the Council's underlying approach to this whole GTC sites issue is also shown to be fundamentally flawed, some constructive proposals are put forward in relation to identification of suitable alternative sites.
I rest my case.

This is a small site which will provide few pitches - whilst it may be cheap to implement and could work, it may not be worth the harm it will do to the area.

Firstly I wish to object to the very limited selection of sites in Warwickshire meaning that all 'possible' sites are to be found in the South of the County. This does not appear representative of a fair and thorough consideration of all available land that might be suitable. No reasonable justification appears to have been provided for this by Warwick County Council. I am not aware of any proposals which consider more urban locations on land which would naturally be considered for development. (Ie non Green / Brown belt land)
In relation to the specific site at Hatton I believe that there are a number of features, which make the site itself unsuitable per se, regardless of its comparison to other proposed locations.
1) The location at Hatton adjacent to Hatton Locks an area of outstanding natural beauty and a gem in the County of Warwickshire. The location of any new community build adjacent to this site would be wrong and will detract from the important heritage of the locks with both noise and visual detriment.

2) The Canal corridor is a haven for a variety of wildlife. The proposal to develop land at the Hatton Site can do nothing other than impact negatively upon the wide variety of bird and animal life that inhabits that area. This is a unique waterway and that habitat extends to the fields, woodland and hedgerows adjacent to the Canal, not just the water itself.

3) The B4100 is also the gateway to Warwick from Birmingham and the North and provides an important visual 'First Impression' for visitors arriving in the town. Warwick relies heavily upon tourism and any planning application must consider the sometimes disproportionate impact of any negative visual impressions on the town with its revenue from visitors. Siting of a Travellers site on this gateway would create that negative visual impact.

4) Despite a 50 mph Speed restriction the B4100 remains a fast, busy road, additional loading around the junction with Ugly Bridge Road has the potential to cause road safety issues. The sweeping bend travelling away towards Hatton Village adds to this concern. With slow moving commercial vehicles (with or without caravans in tow) will create risk entering or leaving the site.

In conclusion I do not believe that the site at Hatton has been considered in detail by Warwick County Council and that sites which would not impact upon the immediate and wider locality need consideration before any decision to progress is made.

I write to state my strong objections to the proposed gypsy site (GT19) on Birmingham Road. The selection strongly contradicts your own site selection criteria:-

1) The area is prone to flooding
2) The road access is not by any means safe, there have been several deaths on this stretch of road, and it would be wilfully negligent to have a site containing potentially young children right in the middle of a canal and an extremely busy stretch of road
3) Such a site would not be able to be integrated into the landscape, due to the current gaping hedge set-up; nor would it be 'integrated' from the canal side

Additionally, The need to build on 'green belt' land should only be under exceptional circumstances, clearly this site location would not merit this.

Lastly I would like to additionally bring to attention Councillor Claire Sawden's response to WDC Executive. All the points she made I totally agree with. I have attached a link to her response:-
http://hattonparkactiongroup.files.wordpress.com/2014/03/gypsy-and-traveller-sites-in-budbrooke-ward.pdf

We wish to record our strong objection to the inclusion of the land at Oaklands Farm in your preferred option sites which lies in the Green Belt.

In the absence of any "very special circumstances" any development in the Green Belt would be contrary to Government guidelines and Warwick District Council's policy. Recent Government guidelines indicate that unmet need, whether for traveller sites or for conventional housing, is unlikely to outweigh harm to the Green Belt and other harm to constitute the "very special circumstances" justifying development in the Green Belt.

The Birmingham Road is exceptionally busy at peak times and any increased use of access near the existing junction and Petrol Station would be potentially very hazardous.

Any residential development of the site would be a serious visual intrusion into the Green Belt and detrimental to the significant tourist attraction of the canal both for the frequent canal users and walkers.

Budbrooke School and Medical Centre are both stretched and may have significant difficulty in coping with increased demand for services in the light of the substantial increase in demand likely to arise through the proposed allocation of over 100 or more new conventional homes to the Budbrooke area under the Local Plan.

There are no very special circumstances to justify any development of the site in the Green Belt for the proposed residential use and in our view the site should be coded RED and not taken forward for any further consideration.

We write on behalf of Taylor Wimpey UK Ltd in respect of the Warwick District Council Gypsies and Travellers Preferred Options consultation document. Whilst there is an identified need to be met for Gypsies and Travellers either living in or passing through the area, it is imperative that the preferred sites are located where they embrace opportunities for community cohesion and maximise the accessibility of services for all. In addition the Green Belt designation of land, as exists across much of Warwick District, should be given due weight.
Preferred site at land off Birmingham Road, Budbrooke (site GT19)
We note that, despite our previous representations, site GT19 has now been recognised as a 'preferred' site by the Council for meeting the Gypsy and Traveller need over the Plan period. Whilst the site is located in the Green Belt, the Council have seemingly determined that the status of the site as previously developed land provides the exceptional circumstances required by paragraph 83 of the National Planning Policy Framework (NPPF).
The Planning Policy for Traveller Sites document published by DCLG in March 2012 states in paragraph 14 that, 'Traveller sites (temporary or permanent) in the Green Belt are inappropriate development.' As per paragraph 83 of the NPPF it then goes on to add in paragraph 15 that 'Green Belt boundaries should be altered only in exceptional circumstances.'
In assessing the site for the Preferred Options consultation document there is a limited reference to the 'exceptional circumstances' test in the NPPF, however, at no point in assessing site GT19 does it state precisely how the Council have determined that this test has been met. Although the statement at the start of the summary of GT19 on page 42, 'The land is in the Green Belt but part of a larger use making it previously developed land', suggests that the development status of the site as previously developed land is what, in the Council's view, offsets the loss of Green Belt land and provides an exceptional circumstance.
However, we would consider that in order to demonstrate exceptional circumstances in this regard it should be demonstrated that the needs for the Gypsy and Traveller community cannot be met on non-Green Belt sites. We do not consider that this has been demonstrated by the Council at this
time and we would ask that further justification is provided at any subsequent consultation period if the Council consider this to be the case.
In addition, we would note that the character of the land as a Caravan and Camping Club site is different to that of a Gypsy and Traveller site. The Caravan and Camping Club site is likely to have usage restrictions in terms of the number of consecutive days that people can remain on the site and limited usage in the winter months, whilst Gypsies and Travellers will be residing on this site as a permanent base and thus a quite different effect on the site is anticipated.
We would also disagree that there is an 'urban feel' to this side of Birmingham Road, as set out on page 42 of the Preferred Options consultation document. There is, at best, a partial ribbon of development along the southern side of Birmingham Road. However even this ribbon is punctuated by green gaps along its route and thus in our view aspects of rurality are retained along the southern side of Birmingham Road.
We are also concerned as to whether the location of the Birmingham Road will lead to a level of detachment from the community which is inconsistent with the aspirations set out in paragraph 11 of the aforementioned Planning Policy for Traveller sites document, including:
* promote peaceful and integrated co-existence between the site and the local community; and
* provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there or on others as a result of new development (Para. 11).
Summary
Given the above it is considered that the Council have failed to show the exceptional circumstances required for releasing Gypsy and Traveller sites in the Green Belt. Furthermore the Council should ensure that there are opportunities to achieve community cohesion and access essential services for the travelling community on any sites included as future allocations. In our view, these factors should restrict development of a Gypsy and Traveller site on the preferred option site on land to the south of Birmingham Road, Budbrooke (site GT19).
We trust the enclosed representations are clear. If however you have any queries or wish to discuss the above in any further detail, please do not hesitate to contact me.

I am a resident of, Birmingham Road, Budbrooke, Warwick, CV35 7DZ.


It has come to my attention that Warwick district council are proposing to situate a Gypsy and traveller site at Oakland's farm Birmingham Road Budbrooke, this is right next door to where I live and I wish to place on record my formal objection and protest at the proposition of this site being used for such a purpose.


My reasons for this objection are
1- The proposed site is designated greenbelt land the preservation of which is paramount to this community, the local infrastructure, tourism in the area and maintenance of the house prices locally.
I would further highlight that government guidelines specifically state that there have to very special circumstances to use greenbelt land and neither I or anyone else affected is aware of any justification to have such a site located at Oakland's Farm.
2- The proposed site is in full view of the main Birmingham Road which is an access point in to the historic town of Warwick, location of this site at Oaklands farm will have a massively negative impact on local tourism as it will create a blot on the sweeping open greenery that currently exists, screening of the site would not prevent this or further lessen the noise created by the site it would simply draw unwelcome attention and ruin the landscape.
3- The proposed site location is on a well-documented accident black spot and if this site is located here this will only cause further fatal accidents and severe traffic problems for this already busy road.
4- The community local to this site are but a few in number and a site of travellers/gypsies would overwhelm and outnumber the local residents and this would not promote a peaceful and integrated coexistence, further the inhabitants of these sites are notoriously rowdy, loud, aggressive with a wanton disregard for peace and public order it is further statistically proven that when such a site is located in a neighbourhood the crime rate in the neighbourhood and surrounding areas rises substantially.
The individuals who have worked hard with dedication and determination in order to purchase properties which are expensive because they are based in a well-regarded and highly sought after area stand to make substantial financial losses if this site is located at Oaklands Farm.
To disregard this fact would be negligence on the part of the council who owe a recognisable duty of care to local residents and to allow such a site to be located in an area which would result in loss to local residents would be negligent on the part of the council the losses for which would therefore need to be borne by the council and paid to local residents.
This are is highly valued area and dubbed locally as the stairway to heaven, the Hatton Locks are of great historic importance to both the local area and the county of Warwickshire and they further date back to 1799 and because of this historic significance the local area benefits from tourism contributing thousands of pounds to the local economy as well as the council, this revenue would be in jeopardy with the location of this site at Oakland's Farm as it will deter tourists.
5- There are further dangers with the location of the proposed site being at Oakland's farm as already pointed out the site would be on a very fast and dangerous road with close proximately to a 24 hour petrol station the traffic from the site will increase the number of fatal accidents and congestion on the Road. There are further dangers with regards to flooding and deep water together with the local railway line which in itself presents dangers.


There will also without doubt be a detrimental effect on the canal and tow path users the detriment to the ecology, wildlife and local farmland clearly presents numerous and very strong reason to oppose this site.


I very much hope that the council will consider and take on board the very real concerns and anxieties raised in this email and will further act to ensure that the proposed site is not located at Oaklands farm

It is a greenbelt site. It is between a major road an a canal the risk of accidents involving young children must be considered. Previous experience of illegal sites in Beausale lane and on more recently on the path opposite the Shell garage would suggest high levels of animosity from the local community.

I am a resident of, Birmingham Road, Budbrooke, Warwick, CV35 7DZ.

It has come to my attention that Warwick district council are proposing to situate a Gypsy and traveller site at Oakland's farm Birmingham Road Budbrooke, this is right next door to where I live and I wish to place on record my formal objection and protest at the proposition of this site being used for such a purpose.

My reasons for this objection are
1- The proposed site is designated greenbelt land the preservation of which is paramount to this community, the local infrastructure, tourism in the area and maintenance of the house prices locally.
I would further highlight that government guidelines specifically state that there have to very special circumstances to use greenbelt land and neither I or anyone else affected is aware of any justification to have such a site located at Oakland's Farm.
2- The proposed site is in full view of the main Birmingham Road which is an access point in to the historic town of Warwick, location of this site at Oaklands farm will have a massively negative impact on local tourism as it will create a blot on the sweeping open greenery that currently exists, screening of the site would not prevent this or further lessen the noise created by the site it would simply draw unwelcome attention and ruin the landscape.
3- The proposed site location is on a well-documented accident black spot and if this site is located here this will only cause further fatal accidents and severe traffic problems for this already busy road.
4- The community local to this site are but a few in number and a site of travellers/gypsies would overwhelm and outnumber the local residents and this would not promote a peaceful and integrated coexistence, further the inhabitants of these sites are notoriously rowdy, loud, aggressive with a wanton disregard for peace and public order it is further statistically proven that when such a site is located in a neighbourhood the crime rate in the neighbourhood and surrounding areas rises substantially.
The individuals who have worked hard with dedication and determination in order to purchase properties which are expensive because they are based in a well-regarded and highly sought after area stand to make substantial financial losses if this site is located at Oaklands Farm.
To disregard this fact would be negligence on the part of the council who owe a recognisable duty of care to local residents and to allow such a site to be located in an area which would result in loss to local residents would be negligent on the part of the council the losses for which would therefore need to be borne by the council and paid to local residents.
This are is highly valued area and dubbed locally as the stairway to heaven, the Hatton Locks are of great historic importance to both the local area and the county of Warwickshire and they further date back to 1799 and because of this historic significance the local area benefits from tourism contributing thousands of pounds to the local economy as well as the council, this revenue would be in jeopardy with the location of this site at Oakland's Farm as it will deter tourists.
5- There are further dangers with the location of the proposed site being at Oakland's farm as already pointed out the site would be on a very fast and dangerous road with close proximately to a 24 hour petrol station the traffic from the site will increase the number of fatal accidents and congestion on the Road. There are further dangers with regards to flooding and deep water together with the local railway line which in itself presents dangers.

There will also without doubt be a detrimental effect on the canal and tow path users the detriment to the ecology, wildlife and local farmland clearly presents numerous and very strong reason to oppose this site.

I very much hope that the council will consider and take on board the very real concerns and anxieties raised in this email and will further act to ensure that the proposed site is not located at Oaklands farm.

RESPONSE TO PROPOSED SITE GT19 (LAND ADJACENT SHELL PETROL FILLING STATION, BIRMINGHAM ROAD, BUDBROOKE, WARWICK)

This response is submitted by Hampton Magna Residents' Association.


"Our policy document planning policy for traveller sites was issued in March 2012. It makes clear that both temporary and permanent traveller sites are inappropriate development in the green belt and that planning decisions should protect green belt land from such inappropriate development ... .

... it has become apparent that, in some cases, the green belt is not always being given sufficient protection that was the explicit policy intent of ministers.

"The Secretary of State wishes to make clear that, in considering planning applications, although each case will depend on the facts, he considers that the single issue of unmet demand, whether for traveller sites or for conventional housing, is unlikely to outweigh harm to the green belt and other harm to constitute the "very special circumstances" justifying inappropriate development in the green belt."

This was reiterated by Brandon Lewis in his 17 January 2014 statement:

"The Secretary of State remains concerned about the extent to which planning appeal decisions are meeting the government's clear policy intentions, particularly as to whether sufficient weight is being given to the importance of green belt protection. Therefore, he intends to continue to consider for recovery appeals involving traveller sites in the green belt."

Planning Policy for Traveller Sites (PPTS) states:

"Policy E: Traveller Sites in Green Belt

14. Inappropriate development is harmful to the Green Belt and should not be approved, except in very exceptional circumstances. Traveller sites (temporary or permanent) in the green belt are inappropriate development"

WDC has not shown very exceptional circumstances exist for including GT 19 in the list of preferred sites. This contravenes government policy.

The Consultation Document merely states that previous development has been permitted on the proposed site but it is equally the case that planning permission has also been refused due to its impact on the Green Belt.

In addition, the Green Belt argument was used against Kite's Nest site being a gypsy and traveller site. It is less than a mile away and the sites are in several aspects similar, therefore this argument applies equally if not more so to Site GT 19. To oppose the Kites Nest site on the grounds of impact on Green Belt and propose GT19 site when on Green Belt land would also show a lack of consistency in WDC's appraising of sites with similar issues.

The Inspector's report from Kites Nest refusal stated:

"For development to be allowed in the Green Belt, very special circumstances need to be identified. What constitutes very special circumstances are not identified by local planning authorities. The term is consequently a moving target as appear to be the weights and measures used to arrive at a weighted decision. The appellants (at Kites Nest) provided a list of 15 issues that could be considered as very special circumstances as to why the development should be allowed. These did not include such common issues as health, education or children. The issues are complicated and fraught."

Impact on the Green Belt should alone be a sufficient ground for refusal.


Criterion: Availability of the site (including impact on the existing uses on the site)

It is my understanding that the owner of the land at site GT19, Robert Butler, does not want to sell it for a Traveller and Gypsy site. Therefore a Compulsory Purchase Order (CPO) would be needed and Warwick District Council has said that a CPO could be used. This is in complete contravention of ministerial statements.

The use of a Compulsory Purchase could set up conditions for a legal challenge.

If the GT19 site were to be approved it would put the current owner's business at considerable risk and so there would also be the question of compensation for the owners business that suffered as a consequence. Expenditure on this and a CPO would not be an appropriate use of limited financial resources of WDC.


Criterion: Proximity to other residential properties

The Kites Nest inspector found and the Secretary of State agreed that the Kites Nest site was situated within the local community of about 10 households, and that community would be dominated by a 13 or 8 pitch scheme.

The same argument applies for site GT19 which is set within a group of houses 4 houses to the south and a Shell petrol station to the north followed by a further 10 houses. The provision of five pitches on this site would increase the housing density by 25 per cent and thus would change the local dynamics.

The use of the term "community" is deliberate; it is not the same as settlement or that term would have been used. There is a close-knit and neighbourly sense of community amongst the occupiers of the 10 or so dwellings in the immediate vicinity of the proposed GT19 site.

The Kites Nest inspector accepted that the scattered houses do form an identifiable community. Birmingham Road houses similarly form a community and therefore it could be argued that approval of site GT19 would be going against the inspector's comments which have helped WDC in the past.

PPTS Policy B, paragraph 11(a) states that policies should "promote peaceful and integrated co-existence between the site and the local community". PPTS - Policy C states that authorities should "ensure that the scale of such sites does not dominate the nearest settled community".

For the above reasons, selection of Site GT19 would appear to contravene these policies.

Criterion: Safe Access from the Site for vehicles and pedestrians.

Approval of the GT19 site would locate the pitches between the canal and a fast and busy road (Birmingham Road A4177). Traffic on this road is already dangerous and if proposed housing developments occur it would be set to increase. This road has had 2 fatal accidents in the last five years. There was also another serious accident in March 2014.

Movement of caravans and large vehicles in and out of the site on such a fast and busy road would not only be potentially dangerous to the proposed occupiers of the GT19 site it could increase the likelihood of more accidents to other traffic. In fact an application by the current owner for the importation, storage and cutting of timber was refused on the grounds of Green Belt citing the fact that the site is on a busy and fast main road (Birmingham Road A4177). To refuse the landowner's application on such grounds and then ignore them when assessing the GT19 proposal is contradictory.

Criterion: Impact on visual amenity including the visibility of the site and surrounding area.
The previous inspector involved with Kites Nest found that the development was very prominent through "gappy hedges" and from public footpaths, and that the existing caravans were an "extremely jarring element". The secretary of State agreed with this assessment. Site GT19 would be similarly visible through gappy hedges.

The road is higher than the proposed site so that it would be overlooked. In the current consultation document reference is made to a habitat buffer being required to the canal side of the development. It could be argued that similar screening would be required on the road side to give the residents privacy from passing traffic and to screen off the caravans from the neighbouring houses. Screening issues for Site GT19 are even more extensive than Kites Nest.

Site GT 19 would also be visible from the canal which is a tourist attraction with its many locks and is likely to have an adverse impact on important features of the natural and historic environment. The present canal dates back to 1799 and the flight of 21 locks are well known among waterways aficionados and are a greatly valued heritage asset. There is also a great deal of narrow boat traffic, especially in the summer months, to see and use the 21 locks.


Criterion: Distance to nearby Schools ... etc.
Education would have to be provided for gypsy children and it has been suggested that children could attend Budbrooke School. Budbrooke School is already struggling with numbers due to rising population. Ferncombe School in Hatton is also full.


Criterion: Impact of land contamination, noise and other disturbance

The five pitches present potential noise and disturbance for families living in close proximity.


Compliance with PPTS - health and wellbeing

It is noted that no criterion is listed to address this policy and it should be.

PPTS Policy B - Paragraph 11(e) states that local planning authorities should, ensure that their policies:

" provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there or on others as a result of new development ."

The GT19 site is adjacent to a nearby a canal. There could be detrimental effects to the health and wellbeing of young children living near the canal.

Also, to put children on a site near a potentially dangerous road does not appear to comply with this Policy.


Criterion: impact on heritage assets and setting of heritage assets

The flight of 21 locks was opened in 1799 and known as the "stairway to heaven". The tourist heritage side of Budbrooke is currently underdeveloped. Ramblers, joggers, dog walkers, cyclists, artists, photographers, bird watchers and other groups use the towpath. Then there is the river traffic. Narrow boat owners travel along the canal at weekends and for their holidays. Boats are also rented for holidays.

To locate the Gypsy and Traveller Site adjacent to this area would not enhance it but have an adverse effect and the history and heritage of the area.

We understand that the current owner of proposed GT19 site in conjunction with British Waterways has drawn up plans for a marina with a restaurant and a conference centre. This would include a heritage area with pictures and artefacts of traditional life so that local people and visitors could see and appreciate the lives of former generations.

The viability of this proposal should at least be considered in order to examine whether it could increase the tourist industry in the area and provide employment opportunities for local people.

It would seem that encouraging tourism, preservation of heritage, and possible employment opportunities should take precedence over inappropriate use of expenditure on CPOs and potential financial compensation.

I wish this document to be regarded as my personal representations against the GT19 site.

"Our policy document planning policy for traveller sites was issued in March 2012. It makes clear that both temporary and permanent traveller sites are inappropriate development in the green belt and that planning decisions should protect green belt land from such inappropriate development ... .

... it has become apparent that, in some cases, the green belt is not always being given sufficient protection that was the explicit policy intent of ministers.

"The Secretary of State wishes to make clear that, in considering planning applications, although each case will depend on the facts, he considers that the single issue of unmet demand, whether for traveller sites or for conventional housing, is unlikely to outweigh harm to the green belt and other harm to constitute the "very special circumstances" justifying inappropriate development in the green belt."

This was reiterated by Brandon Lewis in his 17 January 2014 statement:

"The Secretary of State remains concerned about the extent to which planning appeal decisions are meeting the government's clear policy intentions, particularly as to whether sufficient weight is being given to the importance of green belt protection. Therefore, he intends to continue to consider for recovery appeals involving traveller sites in the green belt."

Planning Policy for Traveller Sites (PPTS) states:

"Policy E: Traveller Sites in Green Belt

14. Inappropriate development is harmful to the Green Belt and should not be approved, except in very exceptional circumstances. Traveller sites (temporary or permanent) in the green belt are inappropriate development"

WDC has not shown very exceptional circumstances exist for including GT 19 in the list of preferred sites. This contravenes government policy.

The Consultation Document merely states that previous development has been permitted on the proposed site but it is equally the case that planning permission has also been refused due to its impact on the Green Belt.

In addition, the Green Belt argument was used against Kite's Nest site being a gypsy and traveller site. It is less than a mile away and the sites are in several aspects similar, therefore this argument applies equally if not more so to Site GT 19. To oppose the Kites Nest site on the grounds of impact on Green Belt and propose GT19 site when on Green Belt land would also show a lack of consistency in WDC's appraising of sites with similar issues.

The Inspector's report from Kites Nest refusal stated:

"For development to be allowed in the Green Belt, very special circumstances need to be identified. What constitutes very special circumstances are not identified by local planning authorities. The term is consequently a moving target as appear to be the weights and measures used to arrive at a weighted decision. The appellants (at Kites Nest) provided a list of 15 issues that could be considered as very special circumstances as to why the development should be allowed. These did not include such common issues as health, education or children. The issues are complicated and fraught."

Impact on the Green Belt should alone be a sufficient ground for refusal.


Criterion: Availability of the site (including impact on the existing uses on the site)

It is my understanding that the owner of the land at site GT19, Robert Butler, does not want to sell it for a Traveller and Gypsy site. Therefore a Compulsory Purchase Order (CPO) would be needed and Warwick District Council has said that a CPO could be used. This is in complete contravention of ministerial statements.

The use of a Compulsory Purchase could set up conditions for a legal challenge.

If the GT19 site were to be approved it would put the current owner's business at considerable risk and so there would also be the question of compensation for the owners business that suffered as a consequence. Expenditure on this and a CPO would not be an appropriate use of limited financial resources of WDC.


Criterion: Proximity to other residential properties

The Kites Nest inspector found and the Secretary of State agreed that the Kites Nest site was situated within the local community of about 10 households, and that community would be dominated by a 13 or 8 pitch scheme.

The same argument applies for site GT19 which is set within a group of houses 4 houses to the south and a Shell petrol station to the north followed by a further 10 houses. The provision of five pitches on this site would increase the housing density by 25 per cent and thus would change the local dynamics.

The use of the term "community" is deliberate; it is not the same as settlement or that term would have been used. There is a close-knit and neighbourly sense of community amongst the occupiers of the 10 or so dwellings in the immediate vicinity of the proposed GT19 site.

The Kites Nest inspector accepted that the scattered houses do form an identifiable community. Birmingham Road houses similarly form a community and therefore it could be argued that approval of site GT19 would be going against the inspector's comments which have helped WDC in the past.

PPTS Policy B, paragraph 11(a) states that policies should "promote peaceful and integrated co-existence between the site and the local community". PPTS - Policy C states that authorities should "ensure that the scale of such sites does not dominate the nearest settled community".

For the above reasons, selection of Site GT19 would appear to contravene these policies.

Criterion: Safe Access from the Site for vehicles and pedestrians.

Approval of the GT19 site would locate the pitches between the canal and a fast and busy road (Birmingham Road A4177). Traffic on this road is already dangerous and if proposed housing developments occur it would be set to increase. This road has had 2 fatal accidents in the last five years. There was also another serious accident in March 2014.

Movement of caravans and large vehicles in and out of the site on such a fast and busy road would not only be potentially dangerous to the proposed occupiers of the GT19 site it could increase the likelihood of more accidents to other traffic. In fact an application by the current owner for the importation, storage and cutting of timber was refused on the grounds of Green Belt citing the fact that the site is on a busy and fast main road (Birmingham Road A4177). To refuse the landowner's application on such grounds and then ignore them when assessing the GT19 proposal is contradictory.

Criterion: Impact on visual amenity including the visibility of the site and surrounding area.
The previous inspector involved with Kites Nest found that the development was very prominent through "gappy hedges" and from public footpaths, and that the existing caravans were an "extremely jarring element". The secretary of State agreed with this assessment. Site GT19 would be similarly visible through gappy hedges.

The road is higher than the proposed site so that it would be overlooked. In the current consultation document reference is made to a habitat buffer being required to the canal side of the development. It could be argued that similar screening would be required on the road side to give the residents privacy from passing traffic and to screen off the caravans from the neighbouring houses. Screening issues for Site GT19 are even more extensive than Kites Nest.

Site GT 19 would also be visible from the canal which is a tourist attraction with its many locks and is likely to have an adverse impact on important features of the natural and historic environment. The present canal dates back to 1799 and the flight of 21 locks are well known among waterways aficionados and are a greatly valued heritage asset. There is also a great deal of narrow boat traffic, especially in the summer months, to see and use the 21 locks.


Criterion: Distance to nearby Schools ... etc.
Education would have to be provided for gypsy children and it has been suggested that children could attend Budbrooke School. Budbrooke School is already struggling with numbers due to rising population. Ferncombe School in Hatton is also full.


Criterion: Impact of land contamination, noise and other disturbance

The five pitches present potential noise and disturbance for families living in close proximity.


Compliance with PPTS - health and wellbeing

It is noted that no criterion is listed to address this policy and it should be.

PPTS Policy B - Paragraph 11(e) states that local planning authorities should, ensure that their policies:

" provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there or on others as a result of new development ."

The GT19 site is adjacent to a nearby a canal. There could be detrimental effects to the health and wellbeing of young children living near the canal.

Also, to put children on a site near a potentially dangerous road does not appear to comply with this Policy.


Criterion: impact on heritage assets and setting of heritage assets

The flight of 21 locks was opened in 1799 and known as the "stairway to heaven". The tourist heritage side of Budbrooke is currently underdeveloped. Ramblers, joggers, dog walkers, cyclists, artists, photographers, bird watchers and other groups use the towpath. Then there is the river traffic. Narrow boat owners travel along the canal at weekends and for their holidays. Boats are also rented for holidays.

To locate the Gypsy and Traveller Site adjacent to this area would not enhance it but have an adverse effect and the history and heritage of the area.

We understand that the current owner of proposed GT19 site in conjunction with British Waterways has drawn up plans for a marina with a restaurant and a conference centre. This would include a heritage area with pictures and artefacts of traditional life so that local people and visitors could see and appreciate the lives of former generations.

The viability of this proposal should at least be considered in order to examine whether it could increase the tourist industry in the area and provide employment opportunities for local people.

It would seem that encouraging tourism, preservation of heritage, and possible employment opportunities should take precedence over inappropriate use of expenditure on CPOs and potential financial compensation.

I wish this document to be regarded as my personal representations against the GT19 site.