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The proposed site is bordered by the A4177 main road, the canal and the junction of Ugly Bridge Road and the Shell petrol station. The A4177 is a known dangerous road that has seen many accidents, some resulting in fatalities. Any vehicular access to or from this site would constitute a dangerous and major hazard.
The very close proximity to both canal and road would pose a significant risk to any children on this site.
The location is green belt land. Government guidelines state that land in the green belt can only be used in exceptional circumstances.
The canal is a major visitor attraction, used extensively by walkers and cyclists and is an important ecological site. The nature of the proposed site would have a significant and adverse effect.
In a previous Local Plan Consultation land adjacent to the canal was assessed as unsuitable for development. Therefore the same arguments apply to this site.

see attached

Further to your below email and the Consultation on the Preferred Options Sites for Gypsy and Travellers deadline of Monday 5th May, I refer you to my below comments and objections.

2. History: How we got to this point

2.4 -OBJECT

the assessment from Salford University contains no adequate "demonstration of the need for 31 pitches", the public was not consulted in its production and as the sole basis of the Council's policy, it is unreliable and unsound.


2.7 -OBJECT

No adequate rationale has been given for the Council not owning or managing the sites. The Council is presenting conjecture as fact which is unsound.

There is no explanation, crucial at this stage, of who the Council would sell sites to. Will the sites be widely available? What guarantees are there that the Council will fulfil its obligations to achieve best value?

The Council needs to retain accountability for managing and controlling the sites and securing all relevant planning consents. This could possibly be achieved through a registered social landlord.


2.8 - OBJECT

The sentence "extending the number of pitches on a site would be subject to a planning application and sites would then be assessed for any constraints and restrictions" seems to leave open the possibility of adding the number of pitches at a later date through the planning process not only a possibility but also exposes this entire process to abuse and manipulation and offering local residents no certainty.


2.10 - COMMENT

The GTAA was actually published in November 2012, so this does not bode well for the professionalism or competence of the Council's approach.


2.13 - COMMENT

The public deserves more information on why conversations with neighbouring authorities over several years have not yielded any results.

3. Warwick District - Context


3.5 - OBJECT

The NPPF requires "exceptional" circumstances, not special. This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should not be promoting any green belt site above any non green belt site.

I was assured by you in your email of 30 July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need."

3.6 - OBJECT

The NPPF requires "exceptional" circumstances, not special. This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should not be promoting any green belt site above any non green belt site.

I was assured by you in your email of 30 July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need."

6. Criteria

6.3 - COMMENT

A fundamental flaw in this draft policy is that there is no explanation of why some 'green' sites are in Preferred Sites and others are Alternative Sites. You should be more transparent.

7. Sites Summary Table

GT19 - OBJECT

Against the Council's own criteria in section 6.1, GT19 fails on the following points.

1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.

Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.

7 Sites which can be integrated into the landscape without harming the character of the area. Site development will accord with national guidance on site design and facility provision FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.

8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
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


In addition, the commentary and treatment for this site is very one-sided. Firstly this is true as a standalone because factors mentioned in the full site assessment are omitted from the policy document. Secondly there is great inconsistency in the commentary on factors across different sites, which seriously undermines the soundness and confidence in the Council's approach.

For example (referring to the commentary on page 22):

"Site area reduced to avoid other existing uses and retain viability of remaining unit" There is no proof or even indication that this will be the case

"Possible use of existing access points" There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.

How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?

"Services available on site as currently used by Caravan and Camping Club" This is spun as a factor supporting GT19 as a Preferred Site. How does this compare with the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?

The following key points have not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:

1) The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this, why has GT19 therefore been proposed as a preferred site?
2) Possible flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly.
3) Part of the site is within high flood risk Zone 3. The proposed site is 0.3 acres in size. With part being within a high flood risk Zone- why does it therefore remain a preferred option?
4) Ecological factors being adjacent to the canal, and the Council's own plans show that this land has a high sensitivity to housing development.
5) Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
6). GT19 is adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
7) The Council recently rejected the proposed development of a similar site owned by Mr Arkwright further west along the Birmingham Road. The Council's reasoning's were sound and should be reiterated on this site.
8) Reference to the site being located within the Green Belt have been included - however the reference that it has been "previously developed land" is misleading. The previous use of the land was for agricultural purposes.

8. Preferred Options for Consultation

PO1: Meeting the Requirement for Permanent Pitches - OBJECT

A fundamental flaw in this draft policy is that there is no explanation of why some 'green' sites are in Preferred Sites and others are Alternative Sites.

There is also great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.

For example:

GT19 - "Services available on site as currently used by Caravan and Camping Club " has been presented as a positive factor.

By comparison:

GTalt22 - "As a Caravan and Camping Club site, this use would not be suitable"

GT19 - Within the Detailed Gypsy and Traveller Site Assessments it has been noted that "the site is adjacent to the Grand Union Canal Local Wildlife Site." This comment has not been included within Section 7 and the site remains a preferred option.

By comparison:

There are numerous other sites including GTalt20 and GTalt23 where the sites have proximity to a LWS in the form of a canal. This information has been included within the commentaries in Section 7.

You are not fully representing the situation by omitting this information.

GT19 - there is no mention that Mr Butler, the current owner of GT19, is not prepared to sell the land to the Council. A fact which he has told all Hatton Park Residents - and was confirmed by Clare Sawdon in the recent Hatton Park Action Group meeting of March 2014.

By comparison:

Sites GT02, GT05, GT06, GT08 and GTalt12, all in the alternative sites list, all say "the land owner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward."

You are not fully or fairly representing the situation by omitting this information.

GT19 - part of the site is within high flood risk Zone 3. The site is 0.3 acres in size - with part being within a high flood risk Zone- why does it therefore remain a preferred site?

By comparison:

Sites GTalt20 and GTalt23 have close proximity to a canal and are subject to flooding/surface flooding, but are not located within high flood risk zones - but are deemed inappropriate sites.

Many other sites are noted as being located within high flood risk zone 3 - but all are deemed inappropriate sites.

The above issues seriously undermine the soundness and confidence in the Council's approach to deeming a site their "preferred" option.


9. Summary of Preferred Option Sites

GT19 (p.42) - OBJECT

Against the Council's own criteria in section 6.1, GT19 fails on the following points.

1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.

Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.

7 Sites which can be integrated into the landscape without harming the character of the area. Site development will accord with national guidance on site design and facility provision FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.

8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
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

In addition, the commentary and treatment for this site is very one-sided. Firstly this is true as a standalone because factors mentioned in the full site assessment are omitted from the policy document. Secondly there is great inconsistency in the commentary on factors across different sites, which seriously undermines the soundness and confidence in the Council's approach.

For example (referring to the commentary on page 22):

"Site area reduced to avoid other existing uses and retain viability of remaining unit" There is no proof or even indication that this will be the case

"Possible use of existing access points" There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.

How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?

"Services available on site as currently used by Caravan and Camping Club" This is spun as a factor supporting GT19 as a Preferred Site. How does this compare with the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?
"Urban feel" This is subjective.
"A habitat buffer would be required"
Why it is not mentioned that the site is adjacent to Grand Union Canal Local Wildlife Site?
"Subject to agreement with the landowner, this site could be delivered within 5 years."
As the site is not readily available, why is this a Preferred Site?

The following key points have not been mentioned in the commentary within Section 9 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:

1) The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this, why has GT19 therefore been proposed as a preferred site?
2) Possible flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly.
3) Part of the site is within high flood risk Zone 3. The proposed site is 0.3 acres in size. With part being within a high flood risk Zone- why does it therefore remain a preferred option?
4) Ecological factors being adjacent to the canal, and the Council's own plans show that this land has a high sensitivity to housing development.
5) Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
6) GT19 is adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
7) The Council recently rejected the proposed development of a similar site owned by Mr Arkwright further west along the Birmingham Road. The Council's reasoning's were sound and should be reiterated on this site.
8) Reference to the site being located within the Green Belt have been included - however the reference that it has been "previously developed land" is misleading. The previous use of the land was for agricultural purposes.


10. Summary of Alternative Sites - COMMENT

Why are no photographs of these sites provided, unlike for the preferred sites in section 9? This is arguably prejudicial.

I look forward to receiving your comments on the above and confirmation that my above representation has been received and logged.

Yours faithfully
Dear Mr Smith
This is to confirm that your email has been received and retained as your representation to the consultation on the options for sites for Gypsies and Travellers.
You have made a couple of comments which you would like us to address. Firstly, the sites that are in the 'options' consultation booklet are all there because they have either been promoted to us by landowners, suggested to us by others or are 'areas of search' within which we think it may be possible to identify an area of land that would be suitable for this use. We have not identified which of these are in the green belt (although the map on pages 12/13 gives an overview) because at this stage of the work, we want to draw out comments from others before more work is carried out to assess sites in greater detail with a view to taking the most suitable sites forward into the next consultation. Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need.
Whilst adjacent local authorities have rejected the invitation to discuss this issue with them in the past, a dialogue has been re-established with Stratford District Council and Rugby Borough Council and we are more hopeful that we can co-operate with these authorities at least in coming to some agreement about sharing sites or council's providing sites within their boundaries for those who have no potential for sites or insufficient sites. Each district has its own need to address and provide for.
The sites that we are looking to establish are for permanent pitches i.e. in a similar way to the settled community in that a family will reside on a permanent basis on their pitch. They will only 'travel' to find work or to visit family, holiday etc.
Your site by site comments are noted.
Yours sincerely
Lorna Coldicott
Please find below my various representations with regard to the proposed site options.

In line with the report I wish to make representations on a number of points as detailed below.

1. Introduction

No comment

2. Background

No comment

3. Who are Gypsies and Travellers?

No comment

4. What are the Issues?

No comment

5. Policy Background

SUPPORT

National policy is correct in advocating that (1) local planning authorities work together to identify sites and (2) that decision-taking protects Green Belt from inappropriate development and makes enforcement more effective.

On Point (1) it is therefore extremely worrying that Warwick District Council (WDC) is no longer working with other authorities to consider plans on a cross-authority basis, which it has a duty to do under the 2011 Localism Act. On point (2) WDC makes no distinction between Green Belt and non-Green Belt sites in its policy criteria so again contradicts national policy.

6. Evidence Base

No comment

7. Local Plan Requirements

OBJECT

The policy criteria listed by WDC are sensible.

However they omit crucial aspects of national guidance including (1) that plan-making and decision-taking should protect Green Belt from inappropriate development and (2) sites must be in appropriate locations. Why?

There is also the fact that WDC is no longer working on a cross-authority basis to provide sites. Again, why when much of WDC is covered by Green Belt (80%)? Surely by definition travellers are nomadic and the requirement for pitches should not be restricted to Warwick District?

8. Identification of Potential Sites

OBJECT

Section 8.1 is inadequate. WDC should list all sites within it's ownership and explain why it considers each site to be unacceptable.

Section 8.3, in which WDC is seeking to identify sites itself is a total dereliction of its duty under the 2011 Localism Act. WDC contains a high proportion of Green Belt and the Council should be looking to share supply of sites in appropriate locations with other authorities.

Site listing criteria should distinguish first whether locations are appropriate according to national and local planning policy. This is a planning document and land ownership (and willingness to sell) should not be a concern due to CPO powers.

9. Sites for consideration and comment
10. Table of Sites

GT01 Land adjacent to the Colbalt Centre, Siskin Drive

No Comment

GT02 Land abutting the Fosse Way at its junction with the B425

No comment

GT03 Land at Barnwell Farm

No comment

GT04 Land at Harbury Lane, Fosse Way

No comment

GT05 Land at Tachbrook Hill Farm

No comment

GT06 Land at Park Farm, Spinney Farm

No comment

GT07 Land at Stoneleigh Road

No comment

GT08 Depot to the west side of Cubbington Hill Farm

No comment

GT09 Land to the north east of M40

No comment

GT10 Land at Tollgate House and Guide Dogs National Breeding Centre

No comment

GT11 Land at Budbrooke Lodge, Racecourse and Hampton Road

No comment

GT12 Land north and west of Westham Lane (area of search)

No comment

GT13 Kites Nest Lane, Beausale

OBJECT

Kites Nest Lane, Beausale is totally inappropriate as a site for this purpose because:

1. It is a greenfield site in the open countryside within the Green Belt and any use for this purpose (or residential etc) is inappropriate development. The National Planning Policy Framework protects the Green Belt from inappropriate development.

2. Adopting it as a possible site would legitimise the long-running unauthorised applications to impose this illegal use at this site. WDC has rightly objected to such applications (although achieved nothing in removing the illegal settlement) and allowing development through this process would set an extremely damaging precedent in this and other areas that will attract significant public disapproval. National policy supports effective enforcement against unauthorised developments.

3. Access to local services is limited.

4. Its rural location means that this use cannot be integrated in the landscape without harming the character and amenity of the area in terms of aesthetic appearance and noise.

GT14 Warwick Road, Norton Lindsey

No comment

GT15 Land east of Europa Way

No comment

GT16 Land to north of Westham Lane and west of Wellesbourne Road, Barford (small site)

No comment

GT17 Service area west of A46 Old Budbrooke Way

No comment

GT18 Service area east of A46 Old Budbrooke Way

No comment

GT19 Land off Birmingham Road, Budbrooke, Oaklands Farm

OBJECT

Land at Oaklands Farm, Birmingham Road is totally inappropriate as a site for this purpose because:

1. It is in the Green Belt and any use for this purpose (or residential etc) is inappropriate development. The National Planning Policy Framework protects the Green Belt from inappropriate development.

2. Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.

3. It is adjacent to the Grand Union Canal running locally between Warwick and Hatton offering views of Warwick Castle and St Nicholas Church.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

This is a very popular towpath for boaters, walkers, runners and cyclists alike whose amenity will be greatly impacted by the occupation/development of this site.

Its location will further impact on the visual amenity of the Grand Union Canal.

4. The site may be prone to flooding due to its location next to a water network.

GT20 Land at Junction 15 of M40

No comment

Do you have any other suggestions for land within this district that you think would be suitable for use as a Gypsy and Traveller site?

No comment

I look forward to receiving your comments and trust that the Council will make a well informed and well researched decision when it comes to sites to be considered in greater detail.

Yours faithfully


John Smith

Various arguments have been proposed by Hampton Magna Resident's Association to assist me in formulating my response. Having considered these arguments and the Consultation documents and the criteria for responses, I wish the following to be considered as my own personal submission on the subject.
Criterion: Impact on the green belt
Site GT19 is in the Green Belt. Of the five preferred option sites currently shortlisted, it is the only one in the Green Belt. The Government has consistently stated that Green Belt Land should only be used in very exceptional circumstances.
On 1 July 2013, in his written statement to Parliament, Brandon Lewis MP, Local Government Minister stated:
'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 inapprpriate development in the green belt'.
This was reinterated 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 recoveru 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'
WEDC has not shown very exceptional circumstances exist for including GT19 in the list of preferred options. This contravenes government policy.
The Consultaiton 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 artument was used against Kite's Nest site being a gyspy and traveller site. It is less than a mile away and the sites are in several aspects similar, therefore this aregument applies equally if not mor so to Site GT19. To oppose the Kites Nest site on the grounds of impact on the 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 cicumstances are not identified by local planning authorities. The term is condequently 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 fo the site (including impact on the existing uses on the site)
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 copuld be used. This is in complete contravention of ministerial statements.
The use of 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 by25 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 occupants of he 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 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 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, but it could incerase 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 htat 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 residents privacy from passing traffic and to screen off the caravans from neighbouring houses. Screening issues for Site GT19 are even more extensive than Kites Nest.
Site GT19 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 he summer months, to see and use the 21 locks.
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. Ferncumbe 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 shoud 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 canal. There could be detrimental effects on the health and well being 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, odg 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 affect and the history and heritage of the area.
Weunderstand that the current owner of proposed GT19 site in conjunction has drawn up plans with British Waterways 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.

I wish to register my opposition to the Gypsy and Traveller site, preferred option GT04. My reasons are contained in the attached documents.

I believe that the alternatives set out below are much more suitable

GT15 - quick and convenient as WCC already own the land
Good access to schools, gp surgery and public transport

GT19 - can be delivered in 5 years, good access to schools, gp and public
transport

GT alt01 - Already has planning permission for caravans, access to new schools

9. Summary of Preferred Option Sites
GT19 (p.42) - OBJECT
Against the Council's own criteria in section 6.1, GT19 fails on the following points.
1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.

Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.
7 Sites which can be integrated into the landscape without harming the character of the area. Site development will accord with national guidance on site design and facility provision FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
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
In addition, the commentary and treatment for this site is very one-sided. Firstly this is true as a standalone because factors mentioned in the full site assessment are omitted from the policy document. Secondly there is great inconsistency in the commentary on factors across different sites, which seriously undermines the soundness and confidence in the Council's approach.
For example (referring to the commentary on page 42):
"Site area reduced to avoid other existing uses and retain viability of remaining unit" There is no proof or even indication that this will be the case

"Possible use of existing access points" There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.
How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?
"Services available on site as currently used by Caravan and Camping Club" This is spun as a factor supporting GT19 as a Preferred Site. How does this compare with the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?
"Urban feel" This is subjective. Please explain what the Council means by this?
"A habitat buffer would be required"
Why it is not mentioned that the site is adjacent to Grand Union Canal Local Wildlife Site?
"Subject to agreement with the landowner, this site could be delivered within 5 years."
As the site is not readily available, why is this a Preferred Site?
The following key points have not been mentioned in the commentary within Section 9 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
1) The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this, why has GT19 therefore been proposed as a preferred site?
2) Possible flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly.
3) Part of the site is within high flood risk Zone 3. The proposed site is 0.3 acres in size. With part being within a high flood risk Zone- why does it therefore remain a preferred option?
4) Ecological factors being adjacent to the canal, and the Council's own plans show that this land has a high sensitivity to housing development.
5) Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
6) GT19 is adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.
7) The Council recently rejected the proposed development of a similar site owned by Mr Arkwright further west along the Birmingham Road. What is the difference between that site and this one?
8) Reference to the site being located within the Green Belt have been included - however the reference that it has been "previously developed land" is misleading. The previous use of the land was for agricultural purposes.

On top of all this Site GT19 is located in the Green Belt. The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, and the Council has failed to demonstrate any "exceptional" circumstances. It should simply not be promoting any Green Belt site above any non Green Belt site. I am aware of correspondence from a Warwick DC officer in the consultation round in July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable because the need can be clearly met from non Green Belt sites.
Site GT19 is clearly unsuitable for this use. There are fundamental questions outlined above that I would like a response from Council officers on please.
Please respond to this point about the Green Belt and other questions that have been asked above.
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
GT19 - there is no mention that Mr Butler, the current owner of GT19, is not prepared to sell the land to the Council. A fact which he has told all Hatton Park Residents - and was confirmed by Clare Sawdon in the recent Hatton Park Action Group meeting of March 2014.
By comparison Sites GT02, GT05, GT06, GT08 and GTalt12, all in the Alternative Sites list, all say "the land owner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward."
This, rather than sound planning reasons, seems to be the principal factor in the Council's site selection process. You are not fully or fairly representing the situation by omitting this information in this case.
Please could Council officers explain this inconsistency? Please can Council officers explain the selection process between Preferred and Alternative sites?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
GT19 - Within the Detailed Gypsy and Traveller Site Assessments it has been noted that "the site is adjacent to the Grand Union Canal Local Wildlife Site." This comment has not been included within Section 7 and the site remains a preferred option.
By comparison there are numerous other cases where the sites' proximity to a LWS has been included within the commentaries in Section 7.
Please could Council officers explain this inconsistency?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
There is great inconsistency in the commentary for some sites being deemed suitable and others unsuitable.
For example:
GT19 - "Services available on site as currently used by Caravan and Camping Club " has been presented as a positive factor.
By comparison:
GTalt22 - "As a Caravan and Camping Club site, this use would not be suitable"
Please could Council officers explain this?
8. Preferred Options for Consultation
PO1: Meeting the Requirement for Permanent Pitches - OBJECT
A fundamental flaw in this draft policy is that there is no explanation of why some 'green' sites are in Preferred Sites and others are Alternative Sites.
Could Council officers please explain this shortlisting process, and provide copies of scoring sheets?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
We are aware that the Council recently rejected the proposed development of a similar site between the canal and Birmingham Road owned by Mr Arkwright, closeby to the west along the Birmingham Road.

How does the Council reconcile the refusal of this proposal with listing GT19, a similar nearby site, as a Preferred Site?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
Given the congestion, how does the Council think that the movement of large vehicles into and out of the site will be managed?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
1. Ecological factors are important as the site is adjacent to the canal, and occupation / development of this site will impact on the visual amenity of the Grand Union Canal.
2. The Council's own plans show that this land has a high sensitivity to housing development.
3. The Grand Union Canal Local Wildlife Site is adjacent to the site.

Why was point 3 not mentioned in Section 7 of this document? Why is GT19 proposed as a Preferred Site given this sensitivity?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
There is the possibility of flood risk from the adjacent canal and fields to the north of Birmingham Road, which flood regularly. Part of the site is within high flood risk Zone 3 (the proposed site is only 0.3 acres in size).

With part being within a high flood risk Zone- why has GT19 therefore been proposed as a preferred site?
7. Sites Summary Table
GT19 - OBJECT
This key point has not been mentioned in the commentary within Section 7 which is a major omission on the part of the Council and once again misrepresents the actual situation at GT19:
The landowner is not willing to sell the site, so compulsory purchase powers would have to be used to bring the site forward. It seems that other sites are not preferred because of this.
Why has GT19 therefore been proposed as a preferred site?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states:
"Services available on site as currently used by Caravan and Camping Club"
This is seemingly presented as a factor supporting GT19 as a Preferred Site.
Please explain to me the treatment of this factor compared to the commentary for site GTalt22, which is "As a Camping and Caravan Club site, this use would not be suitable"?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states as a supporting factor:
"Possible use of existing access points"
1. There is no credible solution for allowing large vehicles to turn into a constrained site off a busy road.
2. How does this compare with the commentary for site GTalt22, which is "Access would have to be shared with Camping and Caravan Club access", which is presented as a negative?
7. Sites Summary Table
GT19 - OBJECT
The consultation document states:
"Site area reduced to avoid other existing uses and retain viability of remaining unit"
There is no proof or even indication that this will be the case
What evidence is the Council using to make this statement? Please respond.
7. Sites Summary Table
GT19 - OBJECT
Against the Council's own criteria in section 6.1, GT19 fails on the following points.
1 Convenient access to a GP surgery, school, and public transport
2 Avoiding areas with a high risk of flooding FAIL - the site is located within High Flood Risk Zone 3.
3 Safe access to the road network and provision for parking, turning and servicing on site FAIL - the proposed site is narrow and 0.3 acres.

Access to the road network is not safe - Birmingham Road is 2-way and heavily congested, particularly during peak times. There was a fatal traffic accident immediately outside the proposed site in 2010.
4 Avoiding areas where there is the potential for noise and other disturbance
5 Provision of utilities (running water, toilet facilities, waste disposal, etc)
6 Avoiding areas where there could be adverse impact on important features of the natural and historic environment FAIL - GT19 is located within the Green Belt and adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton.

As stated on numerous websites including Hatton Parish Council, the Canal & River Trust and Enjoy Warwick, (to name but a few), Hatton is home to one of the most picturesque spots on the Grand Union Canal.

The famous Hatton Flights, otherwise known as "The Stairway to Heaven" contains 21 locks in less than two miles, raising or dropping the Grand Union Canal by 146.5 feet. They are an excellent example of original and recent canal engineering providing two hundred years of waterways history at a key location on the Grand Union canal.

As part of a Heritage Lottery Funded Working Boats Project, a pair of restored working boats that once worked this route are moored on the Hatton Flights. A recent Heritage Lottery funded project has also made some of the local history available to visitors through information panels, leaflets, a family wildlife trail along the Hatton Flights, education packs and picnic benches.

The occupation/ development of this site will impact on the visual amenity and historic importance of the Grand Union Canal.

7 Sites which can be integrated into the landscape without harming the character of the area. Site development will accord with national guidance on site design and facility provision FAIL - GT19 is located within the Green Belt. It is also adjacent to the Grand Union Canal, the Grand Union Canal Local Wildlife Site and the famous Hatton Flights running locally between Warwick and Hatton. The occupation/ development of this site will impact on the visual amenity of the Grand Union Canal.

8 Promotes peaceful and integrated co-existence between the site and the local community
9 Avoids placing undue pressure on local infrastructure and services
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
Why is GT19 a Preferred Site? Please respond.
7. Sites Summary Table
OBJECT
As a general point, but with specific regard to site GT19. the commentary and treatment are very one-sided:
1. As a standalone because factors mentioned in the full site assessment for GT19 are omitted from the policy document - this misrepresents the site characteristics
2. There is great inconsistency in the commentary on factors across different sites. For example the phrase "Services available on site as currently used by Caravan and Camping Club" is used as a supporting factor in GT19 but a negative factor for GTalt22.
How can this be? This seriously undermines the soundness and confidence in the Council's approach
3. Warwick District - Context
3.6 - OBJECT
The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, not "special". This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should simply not be promoting any Green Belt site above any non Green Belt site.
I am aware of correspondence from a Warwick DC officer in the consultation round in July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable.
3. Warwick District - Context
3.5 - OBJECT
The NPPF requires "exceptional" circumstances to alter Green Belt boundaries, not "special". This paragraph is inaccurate and disingenuous. The Council has failed to demonstrate any "exceptional" circumstances and should simply not be promoting any Green Belt site above any non Green Belt site.
I am aware of correspondence from a Warwick DC officer in the consultation round in July 2013 that "Warwick District Council will not promote green belt sites if there is sufficient land available outside the green belt to meet the evidenced need." To be promoting a Green Belt site (GT19) at this stage is totally unacceptable.

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

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

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

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

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

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

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

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

To provide 31 pitches I consider the best arrangement to be

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

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

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

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

Evidence provided to Select Committee on the importance of site location:
"What is working [in Ireland] are small sites. And they are not placed under flyovers or pylons, or beside sewers, canals or tips; they are placed on proper positioned land, bang within the middle of a settled community, and they are working."204]

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

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

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

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

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

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

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

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

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

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


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

WDC Local Plan Gypsies & Travellers Preferred Options Consultation


The JPC accepts that allocations must be made for the G&T community within the WDC New Local Plan - rather than relying on sites coming forward through the conventional planning process and we also understand the importance of G&T issues in the Local Plan process, however the JPC believes that any such allocation must be made on a fully democratic and objective basis.

When the June 2013 consultation was staged we were unimpressed with the level of detail provided and very disappointed at the lack of local knowledge and erroneous justifications for selected sites. It can be no surprise that local communities erupted in response to such ill thought-out blight on our district.

Given the levels of residents' responses it is surprising that the Preferred Options consultation has now followed with a similar level of erroneous information and even less quantifiable justification for the Preferred Option choices.

We find the presentation of material confusing at best given that much of the important evidence is buried on the website as "Further Evidence" and "Background" and much that is there is either erroneous and/or conflicting with the March 2014 PO document. At another level we and the vast majority of our residents who have commented found the "Drop-In Sessions" with just a couple of posters and scattered booklets to be a singularly poor way to disseminate information especially as the staff provided had minimal technical knowledge of the subject matter and made it clear that they would not be collating comment made on the day.

We are also concerned at WDC's apparent willingness to rely on the Compulsory Purchase approach given the associated costs and delays which will render most sites non-viable financially and non-deliverable in the terms required. Furthermore success of the CPO process has yet to be established as evidenced by the 2012 Mid Suffolk DC case when the Inspector found insufficient evidence to support CPO on the grounds of "public interest".

We would question WDC's election to limit site sizes to a maximum of 10 pitches, with some considerably less, as this means that site provision must then blight more communities and settlements than is reasonably necessary. If site size limitation is in order to facilitate management and policing this surely gives credence to many residents' concerns about crime and disorder in or near such sites.

Reduction in site size (or more specifically pitch numbers on individual sites) loses economies of scale in terms of establishment costs, management costs and land take whilst directly impacting a greater number of the general population.

National guidance suggests sites of 5-15 to be preferable and this would suggest that our required 31 pitches could reasonably be accommodated in two or at most three sites.

The JPC would suggest that any or all proposed sites could be best accommodated and assimilated in areas which are not current settlements and that they should be properly planned, at a very early stage, into much larger schemes preferably incorporating residential and employment development.

We find the cursory dismissal of such an approach (Page 12, end of section 5) totally unsatisfactory and unacceptable.

The JPC also believes that the Siskin Drive and Gateway area should be vigorously explored to create a site with a mechanism to accommodate the G&T community within an evolving area where they could best integrate with their surroundings.

Whilst reviewing WDC's commentaries on sites in the original and the current consultation we have found that they are erratic and inconsistent. Criteria are sometimes used to support a choice/site and at other times the same criteria are used in a converse manner. The way in which the supporting Sustainability and Sites Assessments have been used to arrive at the Preferred Options is opaque in the extreme and certainly the interpretation of the Sustainability Assessments based on colour coding appears to be minimally objective.

Examples of inconsistencies relate to noise impacts, site prominence in the landscape, flooding, agricultural land value/viability, proximity of services and pedestrian access/safety. Latterly, especially with the "GTalt" sites, there seems to be an inordinate reference to "surface flooding".

The paperwork provided and the public consultations staged also seem to take no or little account of the cost implications inherent in the various Preferred Option choices and we believe this should be a significant factor when making a final selection given the inherent importance of economic viability.

In consideration of the above the JPC has conducted an objective assessment of all the sites which have come forward under these consultations, as well as our lay skills permit, and concludes that not all of the selected Preferred Options are indeed the best sites of those presented.

The findings are presented in spreadsheet format showing support where we believe it to be appropriate. Where we draw different conclusions we offer rebuttal and further comments as seems appropriate and helpful.

The spreadsheet details are as follows:

* Column 1 - Site identification number and PO indication and JPC support or otherwise
* Column 2 - Précis of WDC comments
* Column 3 - JPC commentary
* Column 4 - Sites which JPC consider could reasonably be progressed (where sites cannot be integrated into "larger schemes").

Inevitably the JPC has been much exercised by contact from residents concerning sites proposed within our JPC parishes and we must comment that these sites seem to have been singularly poorly selected. This situation is not helped by the fact that they seem to have come forward accompanied by blatantly incorrect supporting information, viz:
* Repeated reference to Barford doctors' surgery - when the last part-time surgery closed over 30 years ago
* Inclusion of the Barford Bypass flood compensation pond area as site GT16
* Inclusion of Barford Community Orchard and Riverside Walk in GTalt12
* Inclusion of spillage/reed ponds within GT12 in March 2014
* Confusion over the maps for GT12 And GT16 in June 2013
* Confusion over the map of GT12 in March 2014
* Confusion over the map of GTalt12 in March 2014

On a purely local basis it seems bizarre and is certainly unacceptable to blight Barford, recently judged amongst the best 10 places in the Midlands (and number 57 nationally) to live, with the Preferred Options selection of such obviously poor sites. Should the Barford sites persist we are sure that residents will support the landowner in challenging Compulsory Purchase, increasing costs and delay to all concerned and further impacting deliverability.

We are also reminded that there is a duty to co-operate across boundaries and would draw your attention to the site which Stratford DC have at Blackhill, immediately adjacent to Sherbourne parish.

We hope that you will take this letter and the associated spreadsheet in the constructive manner in which it is intended, in order to assist in achieving the best possible solution for both the settled and travelling communities.

CONSULTATION ON GYPSY & TRAVELLER SITES FOR WARWICK DISTRICT

1. CPRE Warwickshire responded to the Options consultation in 2013. At that stage in the process, CPRE supported two locations in principle, which we considered would meet the practical need for about 25 pitches. These locations were
* Siskin Drive, SE of Coventry (adjacent or close to existing Coventry City Council official site)
* Harbury Lane, at Hobson's Choice (preferably where containers are now stored)

2. These two locations are unfortunately not listed among those put forward during the 2013 consultation. The 2014 Preferred Options consultation document at table 5.1 lists sites stated to have been advanced by respondents in 2013, but neither of these is included in the table. CPRE doubts that the need is for as many as 25 pitches by 2017, as stated by the District Council. Gypsies and travellers often hold land in other Districts, which is not made know in the needs surveys; and there is a risk of double-counting between Districts.

3. The comments on sites below assume this figure of 25 pitches; 30 could be provided if necessary at the locations we suggest.

4. CPRE Warwickshire in summary supports the following locations:

* Hobson's Choice, Harbury Lane, SE of Whitnash 15 pitches
* Siskin Drive, by Coventry Airport, S of Coventry City Council official site 10 pitches
* Birmingham Road, Budbrooke up to 5 pitches
GT04 Land at Harbury Lane/Fosse Way

5. This location is supported and was advanced by CPRE in 2013. We do not support the exact location, which would appear to take over or be alongside Leamington Football Club. This would be an exposed position not easily screened. We support the site on the map extract for GT04 called 'Hobson's Choice'. This is surrounded by a high earth bund, and is used currently for container storage. It lies behind Harbury Lane scrapyard and the old airfield hangar used for indoor go-karting. It would be very suitable for up to 15 pitches and would have no adverse effect on the surrounding environment. As Warwick District Council is willing to consider compulsory purchase of land, this site should be examined closely. The container storage activity need not be at this location and industrial land for it could be found elsewhere.

Siskin Drive, E of Coventry Airport

6. The failure to examine the Siskin Drive area further, and the rejection of it in the 2014 document without explanation, is regrettable. The established existence of the Coventry City Council official site at Siskin Drive, with no adverse environmental or social effects, indicates the general suitability of this area east of Coventry Airport. From the point of view of gypsies and travellers the site is also suitable as it has good road access and does not involve use of minor roads, and there are no private houses nearby. While the local authority boundaries at Siskin Drive are complex (Coventry, Warwick and Rugby all meet here), it should be possible for a Warwick District Council site to be located adjacent to or near the Coventry City Council site.

GT19 Birmingham Road, Budbrooke

7. This has had gypsy occupation in the past. The proximity of other buildings here and the non-agricultural nature of the land adjacent to the A4141 Birmingham Road makes this a potentially acceptable location, but only after the two sites listed above have been developed.


Response on other sites included in the 'Preferred' list (Consultation paper section 9) and on those not supported (Section 10, alternative sites)

GT12 W of Barford Bypass N of Shepham Lane

8. This is open countryside along the western side of the A429 Barford Bypass. It would be very visible, difficult to access and damaging to the setting of Barford. It should be dropped.

Gtalt01 Banbury Road, Warwickshire

9. A gypsy site on the historic road approach to Warwick town centre is not acceptable. This is still a classic rural approach to the historic town. The existing permission for caravans (non-gypsy) and the building of the access does not justify allowing this approach to be degraded by an unattractive and intrusive land use. The site is not being used at present and is better left empty so as to protect the historic approach and the setting of Warwick Castle Park.

GT02 Land at Fosse Way / A425

10. This is a large open landscape, between Radford Hill and North Fosse Farm. It is wholly unsuitable as a gypsy site, being very visible agricultural land. It is partly Grade 3a land and is next to a local wildlife site - the wood known as Parlour Spinney.

GT05 Tachbrook Hill Farm, Bishops Tachbrook

11. This is open farmland between the Banbury Road and Bishops Tachbrook village. With the M40 to the SW, the road is busy with traffic on and off the motorway. The junction between the Banbury Road and Mallory Road is not particularly safe; its rural location makes any junction widening or lighting highly damaging to the character of the immediate area.



Gtalt12 Land SE of Barford Bypass, Barford

12. This appears to have no merit at all as a site. The grounds for objection to GT12 (see above) apply equally to this site.

GT06 Park Farm, Banbury Road, Warwick

13. This is a large area of farmland at Park Farm, on the rural approach to the historic town of Warwick. It would be visible and harm this important setting to Warwick. It would be close to Warwick Castle Park. Similar reasons for objection apply to those listed above for Gtalt01, Banbury Road, Warwick.

GT08 Depot W of Cubbington Heath Farm, Cubbington

14. This location is only worth considering if HS2 is built on the line proposed, as it would then be degraded and could be acceptable as a gypsy site.

GT11 Hampton Road, south of Warwick Racecourse

15. The land north of Henley Road and east of A46 Warwick Bypass is part of Warwick's historic setting. Development of South West Warwick stops at the Henley Road. Urban development should not be allowed to cross it.

GTalt02 Woodyard, Cubbington Road, Rugby Road, Cubbington

16. This would be very harmful to the future of CubbingtonWood, which is replanted Ancient Woodland. The consultation document notes, "North Cubbington Wood is one of the prime cases for woodland restoration for the Princethorpe project which is a complex of woods and hedgerows, currently a Warwickshire Wildlife Trust Living landscape project funded by SITA Trust." A gypsy site here would harm the woodland's restoration and make it less attractive for visitors.

Gtalt03 Henley Road, Hampton-on-the-Hill

17. This site is being promoted by the owner. It would be very harmful to the openness of the Green Belt and to the current rural approach to Warwick from Henley-in-Arden if it were to be developed as a gypsy site. The consultation document fails to describe the appearance of this land or its prominence. It is where the Henley road comes over a crest and Warwick is seen on the skyline. It is too prominent a position to be considered.

I am writing to express in the strongest possible terms by objection to the proposed Gypsy site at GT04 on the site currently offered by Leamington Football Club. Even if you believe that the council are required to provide such facilities, that they are necessary and that the people involved in fact want them (all of which are more than debatable), there are some very grave inaccuracies and irregularities about the process and the proposals.

It is absolutely clear that the whole process has been engineered by Warwick DC to push the sites chosen to the very boundaries of the District. This will have two very clear benefits to Warwick DC, firstly it will eliminate any impact on their residents (and therefore voters) of these sites, and secondly it will push the costs for the provision of services such as schools, Doctors, Policing and other welfare onto neighbouring districts. Both of these objectives are utterly deplorable.

On order to achieve these aims, Warwick DC have clearly judged each site not on defined, creditable, consistent, stated and scored criteria, instead they have mixed and matched criteria and weighing to achieve the outcome that suits their own political agenda. Issues that are deemed as worthy of comment for one site are omitted for another, and initial proposals - right down to the actual land in question - have been adjusted to include or exclude sites as required.

Contradictions and inconsistencies
The latest consultation document is full of contradictions, for example, one site is ruled out due to high pressure gas mains, the next a site is altered to accommodate the fact that there is a high pressure gas main. Similarly, one minute the residents of the travellers site needs access to major road network, the next minute they do not or it is too noisy. The arguments made are clearly 'convenient' to suit the agenda of Warwick district council, which is clearly to push this provision to the farthest boundary and onto Stratford-upon-Avon DC and their residents.

The idea that Gypsies will be content to avoid the closest services for Doctors and Schools in Harbury and head to Bishops Itchington due to an arbitrary district boundary as are fanciful as they are preposterous.

Changing the definition of GT04
Furthermore there have been several differences between the initial proposals and the revised proposal, not least that the initial proposal at GT04 stated that the site would be opposite Barwell Farm and it is now limited to the football club. This devious provision of information meant that objections to the first proposal focussed on a different area to that which is now being proposed, which meant that some key factors may have been overlooked and some key arguments voided.

Specific contradictions when comparing sites (and paragraph 6.1)
There are enormous irregularities in the pro's and con's provided in the consultation, where considerations that are applicable to one site are equally applicable to another but ignored. The application list shown in 6.2 of the document highlights this perfectly. In fact, 6.2 is actually a list of further considerations that may or may not be referred to as appropriate to suit the councils agenda.

For example:
GT04 lies within a flood plane, so the 'new' proposed area, which is different to that considered in the first consultation, has been cherry picked to cover only the part that does not lie in this area. This approach has not been afforded to any other proposed site with flood considerations.

GT04 has issues around danger to wildlife, again the 'new' proposed area, which is different to that considered in the first consultation, has been cherry picked to cover only the part that does not lie in this area. This approach has not been afforded to any other proposed site with wildlife considerations.

Various sites mention a high pressure gas main. Only site GT04 has been sub divided to get around this 'problem'.

GT06 'may cause problems for viable agricultural unit'. Of course the land at GT04 could otherwise form prime agricultural land (if indeed that is a consideration) should the football club vacate and the provision of these facilities will of course have an impact on neighbouring agricultural land.

GT08 is flagged as being within 1km of a railway line. GT04 is also within 1km of a railway line.

GT08 is noted as being (potentially too) remote from transport links and the like. It is no more remote than GT04.

Various sites mention potential road noise from the A46 and M40, yet the Fosse Way (which is adjacent to the GT04 site) is one of the busiest roads in the area.

GT13 mentions failed planning applications previously. Without any detail it is impossible to say that those same reasons for failing to approve this site be any less relevant to GT04.

GT13 is noted as being too remote from services and facilities, remote from primary road network and on high quality landscape. All three of these reasons are more applicable to GT04 than GT13.

GT14 mentions contamination from use as a poultry Farm. This is nonsensical, what possible contamination could there be arising from a poultry farm?

Gtalt02. By far and away the biggest irregularities focusses on Gtalt02, which is marked as 'amber'. When compared to GT04:
* it is apparently remote from services, although no more remote than GT04,
* it would require the purchase of a timber business, whereas mention of the cost and disruption of re-homing a football club is conspicuous by it's absence
* the road may be dangerous even though mention of the Fosse Way, the most dangerous road in Warwickshire if not the Midlands - again not mentioned in GT04.
* Mention of the ancient woodland, although the view from Chesterton Windmill is completely omitted in reference to GT04. (but then I suppose that falls in Statford-upon-Avon DC so that probably doesn't count).

Gtalt03 appears to have not been delivered as 'green' on the basis of being on Greenbelt. If this is an overriding issue or is simply too difficult, then these sites should never have been considered in the first place - what is the point of including and then omitting anything on a green belt is not to force non-green belt sites through. This is consistent throughout the document.

Gtalt04 is stated as being remote from ALL services and facilities, despite being next to a railway station and in a village every bit as well served as anything within 2 miles of GT04.

The reasons given for Gtalt06 are so vague it is not worth commenting on, and all of the positive reasons for inclusion at other sites (such as proximity to services, near to transport links, not being on the greenbelt etc etc) have been completely omitted. Very clearly this is bowing to pressure from a landowner and as such this site should be reconsidered and judged in parallel to the other sites whereby pro's are considered in addition to just the 'cons'.

Gtalt07 mentions being 'open to views from the West'. This is a very odd reason and I cannot see why views from Chesterton Windmill have been entirely omitted in the case of GT04.

Gtalt09 (and others) I am intrigued about the mention of land being 'allocated for residential use'. How a gypsy site would not be considered 'residential use' is very odd, except of course if these is a windfall to the council in selling the land to a developer.

Gtalt10 mentions that the area excluded for risk of flooding but that this is going to be remedied, it is completely unclear as to why this is a problem.

Gtalt13 (excusing typo) - states that the road is not suitable to serve caravans, but these are to be fixed units . This is an enormous and concerning irregularity. Furthermore, it is incongruous that the council are seemingly not willing to improve a road but they are willing to move a whole football club with the costs that this activity would incur.

Gtalt15 - again these are no comments about how 'good' the provision of services would be at this site. Furthermore, there is no 'Olympus Way' in Leamington spa, but access from ' Olympus Avenue' would be ideal for residents.

Gtalt16 is far too vague to comment.

Gtalt22 is mentioned as being 'very open and conspicuous', as well as unpalatable to the neighbours. This is a complete re-write of the rules that all other sites have been judged by.

Consideration of Neighbours

I was alarmed, concerned and ultimately unsurprised when told by a representative of Warwick DC that they have travelled the length and breath of the country to similar sites to speak to traveller families, council officials yet not (even once) those local residents that are affected by the sites. This is entirely preposterous, a scandalous mis-use of public money and shows the utter discontempt for residents (especially those of neighbouring Districts) that will be impacted by these plans.

Ideal sites

The following sites should be utilised. In each case they are either already marked 'Green' or the reasons for being amber or red are extremely weak in comparison with other sites.

GT06 - none of the reasons given against using GT06 are strong enough to preclude the site as being Green. Utilising 6 pitches at this site would spread the burden of provision around the district.

GT11 - as above, none of the reasons given are strong enough to preclude the site as being marked Green. This site would give access to the plentiful services in Warwick and has access to facilities and transport links. The only real reason this has been excluded is the council do not want Gypsy's 'in their backyard', as well as probably objections to a current or potential developer.

GT19 - again, an ideal site and possibly small enough for the local community to absorb, although this should be carefully monitored.

Gtalt01 - already earmarked as a camping site but unlikely to be viable as a business. If indeed there is a requirement, desire and need for such facilities, this a very clear and obvious place that gives residents access to the plentiful services on offer in Warwick Town.

On this point, it is as astonishing as it is unsurprising that the district council has not been 'able' to find any 'green rated' sites that would mean that the provision of services is drawn from the council home of Leamington Spa.

Gtalt02 - again, none of the reasons given are strong enough to preclude the site as being marked Green. This site would give access to the plentiful services in Leamington Spa and has access to facilities and transport links. The only real reason this has been excluded is the council do not want Gypsy's 'in their backyard'.

Gtalt03 - again, reasons not strong enough to preclude the site as being marked Green. This site would give access to the plentiful services in Warwick and has access to facilities and transport links. Likely to be affected by the views of a potential developer.

Gtalt12 - Marked Green, although there does seem likely to be a significant amount of pressure put on services in Barford which I believe may fall in Stratford-upon-Avon DC area.

Gtalt15 - Again, it is not clear as to why this site is not marked as green as different criteria seem to have been given to this and other sites. To claim that some remote sites are close enough to facilities and services but then to not comment in relation to this site is entirely perplexing.

The proposed sites at GT17, GT18 and GT20 are all absolutely ideal for a development of this type. There is not a single criteria that are not met by these sites and it seems that the wishes of one group (in this instance the highways) are accepted and not questioned unlike the view of residents elsewhere.
Best mix

The best mix is to place up to 38 pitches all at GT17, GT18 and GT20. As an alternative, the following mix would best meet the needs of the travelling community, not impact disproportionally on the lives of small communities in and near to Warwick District. All of these sites would have significant space to expand.

GT06 Land at Park Farm, Spinney Farm - 6 'pitches' (currently AMBER)
GT11 Land at Budbrooke Lodge, Racecourse and Hampton Road - 5 'pitches' (currently AMBER)
GT19 Land adjacent Shell Petrol Filling Station, Birmingham Road, Budbrooke, Warwick - 5 'pitches' (currently GREEN)
GTalt01 Brookside Willows, Banbury Road - 15 'pitches' (currently GREEN)
GTalt02 Land off Rugby Road, Cubbington - 5 'pitches' (currently AMBER)
GTalt03 Henley Road/Hampton Road, Hampton-on-the-Hill - 5 'pitches' (currently AMBER)
GTalt15 r.o. department store, Leamington Retail Park - 5 'pitches' (currently RED)

That is if these facilities are needed at all - which frankly nobody believes.

Yours sincerely

James Skidmore

see attached

see attached

see attached

Various arguments have been proposed by Hampton Magna Resident's Association to assist me in formulating my response. Having considered these arguments and the Consultation documents and the criteria for responses, I wish the following to be considered as my own personal submission on the subject.
Criterion: Impact on the green belt
Site GT19 is in the Green Belt. Of the five preferred option sites currently shortlisted, it is the only one in the Green Belt. The Government has consistently stated that Green Belt Land should only be used in very exceptional circumstances.
On 1 July 2013, in his written statement to Parliament, Brandon Lewis MP, Local Government Minister stated:
'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 inapprpriate development in the green belt'.
This was reinterated 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 recoveru 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'
WEDC has not shown very exceptional circumstances exist for including GT19 in the list of preferred options. This contravenes government policy.
The Consultaiton 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 artument was used against Kite's Nest site being a gyspy and traveller site. It is less than a mile away and the sites are in several aspects similar, therefore this aregument applies equally if not mor so to Site GT19. To oppose the Kites Nest site on the grounds of impact on the 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 cicumstances are not identified by local planning authorities. The term is condequently 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 fo the site (including impact on the existing uses on the site)
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 copuld be used. This is in complete contravention of ministerial statements.
The use of 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 by25 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 occupants of he 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 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 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, but it could incerase 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 htat 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 residents privacy from passing traffic and to screen off the caravans from neighbouring houses. Screening issues for Site GT19 are even more extensive than Kites Nest.
Site GT19 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 he summer months, to see and use the 21 locks.
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. Ferncumbe 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 shoud 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 canal. There could be detrimental effects on the health and well being 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, odg 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 affect and the history and heritage of the area.
Weunderstand that the current owner of proposed GT19 site in conjunction has drawn up plans with British Waterways 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.

Various arguments have been proposed by Hampton Magna Resident's Association to assist me in formulating my response. Having considered these arguments and the Consultation documents and the criteria for responses, I wish the following to be considered as my own personal submission on the subject.
Criterion: Impact on the green belt
Site GT19 is in the Green Belt. Of the five preferred option sites currently shortlisted, it is the only one in the Green Belt. The Government has consistently stated that Green Belt Land should only be used in very exceptional circumstances.
On 1 July 2013, in his written statement to Parliament, Brandon Lewis MP, Local Government Minister stated:
'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 inapprpriate development in the green belt'.
This was reinterated 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 recoveru 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'
WEDC has not shown very exceptional circumstances exist for including GT19 in the list of preferred options. This contravenes government policy.
The Consultaiton 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 artument was used against Kite's Nest site being a gyspy and traveller site. It is less than a mile away and the sites are in several aspects similar, therefore this aregument applies equally if not mor so to Site GT19. To oppose the Kites Nest site on the grounds of impact on the 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 cicumstances are not identified by local planning authorities. The term is condequently 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 fo the site (including impact on the existing uses on the site)
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 copuld be used. This is in complete contravention of ministerial statements.
The use of 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 by25 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 occupants of he 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 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 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, but it could incerase 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 htat 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 residents privacy from passing traffic and to screen off the caravans from neighbouring houses. Screening issues for Site GT19 are even more extensive than Kites Nest.
Site GT19 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 he summer months, to see and use the 21 locks.
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. Ferncumbe 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 shoud 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 canal. There could be detrimental effects on the health and well being 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, odg 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 affect and the history and heritage of the area.
Weunderstand that the current owner of proposed GT19 site in conjunction has drawn up plans with British Waterways 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.

Various arguments have been proposed by Hampton Magna Resident's Association to assist me in formulating my response. Having considered these arguments and the Consultation documents and the criteria for responses, I wish the following to be considered as my own personal submission on the subject.
Criterion: Impact on the green belt
Site GT19 is in the Green Belt. Of the five preferred option sites currently shortlisted, it is the only one in the Green Belt. The Government has consistently stated that Green Belt Land should only be used in very exceptional circumstances.
On 1 July 2013, in his written statement to Parliament, Brandon Lewis MP, Local Government Minister stated:
'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 inapprpriate development in the green belt'.
This was reinterated 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 recoveru 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'
WEDC has not shown very exceptional circumstances exist for including GT19 in the list of preferred options. This contravenes government policy.
The Consultaiton 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 artument was used against Kite's Nest site being a gyspy and traveller site. It is less than a mile away and the sites are in several aspects similar, therefore this aregument applies equally if not mor so to Site GT19. To oppose the Kites Nest site on the grounds of impact on the 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 cicumstances are not identified by local planning authorities. The term is condequently 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 fo the site (including impact on the existing uses on the site)
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 copuld be used. This is in complete contravention of ministerial statements.
The use of 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 by25 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 occupants of he 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 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 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, but it could incerase 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 htat 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 residents privacy from passing traffic and to screen off the caravans from neighbouring houses. Screening issues for Site GT19 are even more extensive than Kites Nest.
Site GT19 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 he summer months, to see and use the 21 locks.
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. Ferncumbe 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 shoud 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 canal. There could be detrimental effects on the health and well being 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, odg 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 affect and the history and heritage of the area.
Weunderstand that the current owner of proposed GT19 site in conjunction has drawn up plans with British Waterways 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.

Various arguments have been proposed by Hampton Magna Resident's Association to assist me in formulating my response. Having considered these arguments and the Consultation documents and the criteria for responses, I wish the following to be considered as my own personal submission on the subject.
Criterion: Impact on the green belt
Site GT19 is in the Green Belt. Of the five preferred option sites currently shortlisted, it is the only one in the Green Belt. The Government has consistently stated that Green Belt Land should only be used in very exceptional circumstances.
On 1 July 2013, in his written statement to Parliament, Brandon Lewis MP, Local Government Minister stated:
'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 inapprpriate development in the green belt'.
This was reinterated 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 recoveru 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'
WEDC has not shown very exceptional circumstances exist for including GT19 in the list of preferred options. This contravenes government policy.
The Consultaiton 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 artument was used against Kite's Nest site being a gyspy and traveller site. It is less than a mile away and the sites are in several aspects similar, therefore this aregument applies equally if not mor so to Site GT19. To oppose the Kites Nest site on the grounds of impact on the 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 cicumstances are not identified by local planning authorities. The term is condequently 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 fo the site (including impact on the existing uses on the site)
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 copuld be used. This is in complete contravention of ministerial statements.
The use of 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 by25 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 occupants of he 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 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 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, but it could incerase 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 htat 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 residents privacy from passing traffic and to screen off the caravans from neighbouring houses. Screening issues for Site GT19 are even more extensive than Kites Nest.
Site GT19 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 he summer months, to see and use the 21 locks.
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. Ferncumbe 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 shoud 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 canal. There could be detrimental effects on the health and well being 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, odg 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 affect and the history and heritage of the area.
Weunderstand that the current owner of proposed GT19 site in conjunction has drawn up plans with British Waterways 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.

Various arguments have been proposed by Hampton Magna Resident's Association to assist me in formulating my response. Having considered these arguments and the Consultation documents and the criteria for responses, I wish the following to be considered as my own personal submission on the subject.
Criterion: Impact on the green belt
Site GT19 is in the Green Belt. Of the five preferred option sites currently shortlisted, it is the only one in the Green Belt. The Government has consistently stated that Green Belt Land should only be used in very exceptional circumstances.
On 1 July 2013, in his written statement to Parliament, Brandon Lewis MP, Local Government Minister stated:
'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 inapprpriate development in the green belt'.
This was reinterated 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 recoveru 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'
WEDC has not shown very exceptional circumstances exist for including GT19 in the list of preferred options. This contravenes government policy.
The Consultaiton 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 artument was used against Kite's Nest site being a gyspy and traveller site. It is less than a mile away and the sites are in several aspects similar, therefore this aregument applies equally if not mor so to Site GT19. To oppose the Kites Nest site on the grounds of impact on the 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 cicumstances are not identified by local planning authorities. The term is condequently 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 fo the site (including impact on the existing uses on the site)
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 copuld be used. This is in complete contravention of ministerial statements.
The use of 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 by25 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 occupants of he 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 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 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, but it could incerase 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 htat 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 residents privacy from passing traffic and to screen off the caravans from neighbouring houses. Screening issues for Site GT19 are even more extensive than Kites Nest.
Site GT19 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 he summer months, to see and use the 21 locks.
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. Ferncumbe 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 shoud 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 canal. There could be detrimental effects on the health and well being 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, odg 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 affect and the history and heritage of the area.
Weunderstand that the current owner of proposed GT19 site in conjunction has drawn up plans with British Waterways 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.