Barford Residents' Association has consulted with many residents in Barford since the Gypsy and Traveller sites were first proposed last year, and we wish you to know that the residents of Barford object most strongly to the sites GT06, GT12, GTalt 12 proposed in the recent plan, with particular reference to the area known as GT12 as we (the Barford Residents) believe they are totally unsuitable for the following reasons mindful of the Council's own criteria.
The first criterion is for convenient access to a GP surgery. There are no GP surgeries in Barford, the nearest quoted in the brochure in Tachbrook is actually 4.4 miles away by road. This site would therefore fail in this criterion.
Although there is a school and limited public transport - the need to cross the Barford Bypass means that these services are not safely accessible and certainly there is no adequate pedestrian crossing facility to assist in accessing these services.
The western part of the area does fall within or very close to the flood plain as identified on the Environment Agency maps. Development in this area would not be consistent with avoiding areas with a high risk of flooding.
In our view safe access would not be possible. The Barford Bypass already has a poor accident record. Adding slow moving vehicles and turning traffic would exacerbate an already unsafe situation.
The Barford Bypass is adjacent to the site and therefore this is not consistent with an objective of avoiding locating development where there is potential for noise and other disturbance. Noise mitigation, if it were possible, would reduce the land available for the site, be very expensive and not very effective.
There are no utilities within the proposed area so these would have to be provided at considerable cost and disturbance to traffic using the Bypass whilst this work was being undertaken. There has to be a question as to whether the Gypsies and Travellers would be able to, or wish to, fund this development as it would add significantly to the individual pitch price.
The proposed site is Grade 2 agricultural land and a reduction in the holding area it is situated in would render it non-viable as a holding.
The Council has produced no evidence in relation to the ecological and biodiversity importance of the land within the areas proposed. It is our contention that development in this area would cause unacceptable harm to biodiversity interest contrary to the provisions of the NPPF. Indeed we are very much aware that the area contains a number of protected species including, but not limited to, water voles and badgers which we understand, to be legally protected species. This, in our view, represents a failure to accord with the Council's proposed criteria to avoid areas where there could be adverse impact on important features of the natural environment.
Given that this site is greenfield and divorced from the settlement of Barford by the Bypass it is not considered capable of accommodating development that could be successfully integrated into the landscape without materially harming the character of the area.


This site does not fully accord with the provisions of 'Planning Policy for Traveller sites' as it does not promote peaceful integrated co-existence between the site and the local community and does not avoid undue pressure on local infrastructure and services.
The owner of the site is not willing to sell and Compulsory purchase proceedings would therefore need to be initiated. This would be strongly resisted by both the landowner and the residents of Barford.




SUMMARY
There are no GP surgeries in Barford.
There is no safe access to the school or public transport as to access both would require crossing the very busy and dangerous Barford Bypass.
The Barford Bypass already has a poor accident record, adding more traffic in this location and particularly large slow moving vehicles would exacerbate an already unsafe situation.
There are no utilities i.e., running water, toilet facilities, waste disposal. GT12 places undue pressure on local infrastructure and services and therefore does not promote peaceful and integrated co-existence between the site and the local community.
In light of the above we wish you to represent our objections to the appropriate interested parties on the basis that these sites, particularly GT12, is not appropriate as a Gypsy and Traveller site as it is unsuitable, undeliverable and could not be developed

PROPOSED STRATEGY
A number of the required Gypsy and Traveller sites should be accommodated in the new housing developments allocated in the Local Plan. This will give Warwick District Council the opportunity to address all the Gypsy and Traveller's needs at the planning stage rather than imposing them on existing communities.

I trust you will take the above points into consideration and reflect the views of many of your constituents when considering the recommendations for Proposed Gypsy & Traveller Sites in the New Local Plan

Please accept the enclosed as an objection to site GT12 (as a Preferred Option) and GT12a of the Preferred Options Document March 2014


Has WDC really considered the building design and layout of these proposed sites and their effect on open surrounding countryside?
Has the Government or WDC consulted with any of the Gypsy Traveller Community to find out their views on their proposals?

If Gypsies and Travellers wish to be integrated into a Community then the obvious solution is to incorporate the sites into the proposals for new planned communities. The design of G&T permanent dwelling sites will not be 'so obvious' set amongst new housing developments. Communities will naturally form and facilities be automatically shared.

Few of the current proposals meet the strict criteria set down by WDC .

Sites GT12 North of Westham Lane and GT12a Barford Community Meadow certainly do not meet these criteria.

Intrusive building in open Shakespearean Countryside on the edge of an Historic Village.
Spread along a dangerous and noisy trunk road of the A429 and no safe access for vehicles or pedestrians.
No access to a doctors surgery, nurse, dentist or pharmacy.
No safe access to public transport, the School or the Village shop

Both these locations are ill considered. I would not want to live there.

I write to register my opposition to your proposals for gypsy and travellers sites GT12 and GTalt12 at Barford.
You say in your consultation document at para 2.7 that these sites are to be regarded as akin to conventional housing. Any rational examination of the sites would lead one to say that a planning application for housing on these sites would not be granted.
The A429 is an important route. The views from the road are important and I understood that modern planning considerations prevented developments sprawling beyond recognised boundaries.
Your new local plan uses the A429 as a boundary for Barford to justify "in filling" between the village and the bypass. Your proposals for the two sites at Barford would be an extension to that, providing for development on both sides of the road. The development would use important agricultural land, and would provide development in an area where any development would be a detriment.
In your new Local Plan, you have suggested a large area to the south of Warwick/Leamington Spa for development. If you cannot plan to integrate Gypsy and Travellers sites with a completely clear sheet of paper within that area, you cannot expect to be able to integrate by imposition. I think it would be much better to provide sites within the large areas you have already earmarked for development.

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Please accept the following as comment on the current Gypsy and Traveller Consultation.

Site GT 12 North of Westham Lane, Barford.

As a general point I remain staggered that this site is still on a shortlist of all possible sites in the district and it undermines my faith in WDCs ability to evaluate options against their own stated criteria.

1 - Proximity to GP surgery etc: There is no GP in Barford. The school and scarce public transport is accessible only by crossing an extremely dangerous road. This is a sweeping bend on a fast bit of road as recent accident statistics will prove. I am not at all happy crossing it with my kids.
2 - Safe access to road network. As above, this is not a safe stretch of road. We nearly get rear ended pretty much every time we turn into the village from the north. It is a fast and sweeping bend.
3 - Noise and other disturbance. This is a busy trunk road. It will be noisy for the travellers
4- Sites which can be integrated into the landscape.: This is the real big issue here. Land to the west of the A429 is obviously and distinctly open coutryside. It represents an iconic bit of of the River Avon valley on a distinct meander contained to the west by a steep scarp. The traveller site here would be completely out of character and would intrude in open views to the west. Moreover, the proposed site being elongated and spread along the roadside appears to be designed to maximise visual intrusion. Its influence will be accentuated by its proposed form so that it will appear from the road as prominent as the village itself.

The site is prominent due to its open countryside setting, it is prominent because of its insensitive design and it is prominent in that it is next to a busy road seen by thousands of people every day. The utilitarian traveller site would become the face of Barford. WDC would have little or no control over the viability or performance of any landscape mitigation once it has been implemented since you are simply walking away once consent is granted.
I will not be swayed by arguments that mitigation planting will alleviate this harm. Traveller sites are what they are. They tend to be utilitarian in character with few aesthetic merits (and why should they?). This is simply a case of the wrong site.

Site GT12a Barford Community Meadow

The same points apply as for GT 12 with the added insult that a huge amount of community thought care and work has gone in to this site to make it available to the community. The fact that this is still being put forward as a possible site speaks volumes about the WDC's attitudes to existing communities. Truly, this makes me despair.

General Points...for what they are worth.

I believe that WDC is failing in its duties by not considering incorporating these new gypsy and traveller sites into the new planned communities that are coming forward. It depresses me to think that this proactive approach is not being pursued because of the unhealthy influence the major house builders and developers have over our council leaders. Instead you are seeking to somehow lose this unpopular requirement in the rural community.

I believe WDC is failing in its duties by not challenging the function and performance of the greenbelt north of Warwick and Leamington (a 1950s designation with the main aim of preventing Birmingham and Coventry from merging. Its function and performance can and should be reviewed in this District). Instead you are blindly piling development pressure including the gypsy and traveller sites on our rural communities in the south of the District. In the south we feel embattled and that our interests are not represented by our Council leaders. It makes me sad and angry in equal measure.

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.

WDC Local Plan Gypsies & Travellers Preferred Options Consultation
I am writing to register my objections and give my views on the suitability of the following Gypsy and Traveller Preferred Options Consultation.

GT12/GTalt12 - Land at north and west of Westham Lane
* Warwick District Council (WDC) Criteria states that the site should have "convenient access to a GP surgery, school, and public transport" - The nearest GP Surgery is nearly 5 miles away by road in Bishops Tachbrook and there is not an easy access from Barford.
* WDC Criteria states that the site should "avoid areas with a high risk of flooding" - This site sits within (part) and otherwise immediately adjacent to areas identified by the Environment Agency as having significant flood risk.
* WDC Criteria states that the site should have "Safe access to the road network and provision for parking, turning and servicing on site" - Vehicular access to this site is from the A429 trunk road (The Barford Bypass) which was constructed as a bypass to Barford. It is a 60 mph speed limit road and there have been a significant number of traffic accidents including a fatality. There is also inadequate pedestrian crossing facilities for safe access into the village. Access would be difficult and expensive whilst being very dangerous for both vehicle users and pedestrians
* WDC Criteria states that the site should "avoid areas where there is the potential for noise and other disturbance" - Noise levels from the By Pass and M40 roundabout can be heard through double glazing in the surrounding houses. The continuous noise from the Barford Bypass could not be reduced effectively or economically by constructing barriers.
* WDC Criteria states that the site should have "Provision of utilities (running water, toilet facilities, waste disposal, etc)" - There are no such services available in the area and the cost for supplying these for a small number of pitches would be considerable and therefore render the site uneconomical.
* WDC Criteria states that the site should be "Avoiding areas where there could be adverse impact on important features of the natural and historic environment" - The
proposed site is on the busy route between the historic town of Warwick and the Cotswolds, and the impact on the landscape and tourism of a Gypsy and Traveller site would be immense.



WDC Local Plan Gypsies & Travellers Preferred Options Consultation - Cont/d
* WDC Criteria states that the "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" - The proposed site is green field and a satellite from Barford village, the development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity and character of the site.
* WDC Criteria states "Promotes peaceful and integrated co-existence between the site and the local community" - The A429 Barford Bypass isolates the site from the village and therefore presents a physical barrier to integration with the village.
* WDC Criteria states "Avoids placing undue pressure on local infrastructure and services" - This site does not fully meet with the provisions of Planning Policy for Gipsy & Traveller sites as it does not promote peaceful integrated co-existence between the proposed sites and the local community. It will also place undue pressure on the local infrastructure and services. It would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
The Gypsy and Traveller community should be catered for and integrated into new, larger mixed development sites being proposed through the New Local Plan. Larger pitches would be more economical as opposed to smaller pitches which would drive down the pitch costs, gets economies of scale and has less impact on fewer communities and residents.

The following sites would seem eminently more suitable to a greater or lesser degree than the two proposed sites adjacent to Barford Bypass:

Sites GT02- Land Abutting Fosse Way at Junction with A425 (part) already has an immediate access to popular route for Gypsies and Travellers.

SiteGTalt03 Henley Road /Hampton Road - where the landowner is very keen to promote the site for the required purpose. The site is available and deliverable.

Warwick District Council should be requiring Gypsy and Traveller sites are delivered within the proposed major new housing developments. This would ensure that the sites could be properly designed in a sustainable fashion and be fully integrated into a local community which will provide facilities such as a school, doctor's surgery and shops which are accessible on foot, on bike, by bus and by car.

CONSULTATION ON GYPSY & TRAVELLER SITES FOR WARWICK DISTRICT

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

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

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

4. CPRE Warwickshire in summary supports the following locations:

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

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

Siskin Drive, E of Coventry Airport

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

GT19 Birmingham Road, Budbrooke

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


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

GT12 W of Barford Bypass N of Shepham Lane

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

Gtalt01 Banbury Road, Warwickshire

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

GT02 Land at Fosse Way / A425

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

GT05 Tachbrook Hill Farm, Bishops Tachbrook

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



Gtalt12 Land SE of Barford Bypass, Barford

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

GT06 Park Farm, Banbury Road, Warwick

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

GT08 Depot W of Cubbington Heath Farm, Cubbington

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

GT11 Hampton Road, south of Warwick Racecourse

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

GTalt02 Woodyard, Cubbington Road, Rugby Road, Cubbington

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

Gtalt03 Henley Road, Hampton-on-the-Hill

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

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

Part A
Part B

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

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

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

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

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


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

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

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


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

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

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

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

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

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


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

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

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


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

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

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

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

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

Part A
Part B

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

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

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

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

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


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

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

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


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

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

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

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

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

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


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

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

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


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

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

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

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

I am writing to object to proposals by Warwick District Council to site permanent Gypsy and Traveller sites near Barford, and suggest the Council considers the former Ford Foundry Car Park in Leamington Spa as a particularly suitable alternative site. The car park is discrete, relatively secure, close to employment opportunities, transit services, shops, schools, Health and Hospital facilities, and Catholic Churches.
In the 2011 census, Gypsy or Irish Travellers (over the age of 16) had the highest proportion of no qualifications for any ethnic group at 60%, higher than for England and Wales as a whole (23%). They also had the lowest proportion of people rating their general health as 'very good' or 'good' at 70% compared to 81% of the overall population of England and Wales. Proximity to good schools for all ages, adult education and health care services are essential if Gypsies and Travellers are to enjoy a more settled lifestyle and the benefits therefrom.
"Religion is of great importance to many Gypsies and Travellers, in terms of their daily lives and through rituals and gatherings. Irish Travellers are often devout Roman Catholics and their children attend Catholic schools. Many go on pilgrimages to Lourdes or in Ireland. Large numbers of Romany Gypsies are now Born-again Christians. They find love and solidarity in the Church and in meeting up with others from across Europe at large Christian conventions." [Bristol City Council's, Gypsies and Travellers - The Truth].
"The Government believes that everyone should have the opportunity of a decent home. Decent homes are a key element of any thriving, sustainable community. This is true for the settled and Gypsy and Traveller communities alike." [HMG, Department for Communities and Local Government, 'Designing Gypsy and Traveller Sites Good Practice Guide'].
"Warwick District Council is required by the National Planning Policy Framework (NPPF) and the Housing Act 2004 to meet the accommodation needs of the population within their area. This includes the needs of the Gypsy and Traveller community and that of Travelling Show People.
To meet this need Warwick District Council (WDC) is committed to allocating sustainable and affordable sites to meet the permanent residential needs of this District's Gypsy and Traveller Community and Travelling Show People through the Local Plan process." [http://www.warwickdc.gov.uk/info/20416/evidence_base/733/gypsy_and_traveller_site_allocations]
Given WDC's commitment to meet "permanent residential needs" I am at a loss to understand why a very small group of itinerant, nomadic people loosely referred to as Gypsies and Travellers, who apparently, in general, contribute less to local or national GDP than the majority of people, being the lowest proportion of economically active at 47%, compared with 63% for England and Wales as a whole, should be given special treatment with the provision of transit camps at which they can stop, do a little bit of business, dump their trash and move on. This seems to be completely at odds with the Government's belief, and WDC's obligations and commitment. Moreover, considering HMG, Department for Communities and Local Government, 'Designing Gypsy and Traveller Sites Good Practice Guide', against the identified sites near Barford, there is a significant mismatch with the Government's advice.
"Gypsy and Traveller families often wish to have small compact and well-managed sites located in areas where they have historically resided and have a network of local family support. Local authorities have in the past tended to provide accommodation in inappropriate areas and the sites have therefore not always been used to their full potential. As with the settled community, Gypsy families prefer clean well-managed sites where there is no fear of retribution from problem families and they can enjoy a peaceful coexistence. [...]. Caution should be used when seeking locations for sites to ensure that they are based on need in a particular area and not the availability of inappropriate land for alternative uses. Traditionally, Gypsy sites have been located on land which is inappropriate for alternative uses and this, in itself, has caused problems both for the Gypsy community and for Site Managers."
Is it racist to say that Gypsy and Traveller camps frequently cause an increase in crime and mess, or is it a statistically supportable statement of fact?
Is the Government's decree to Local Authorities to provide more caravan pitches for Gypsies and Travellers predicated on the view that with more authorised sites there will be less of a problem with land occupied illegally? Is this a policy of appeasement of lawlessness or perhaps a sop to wealthy land owners?
Surely, if people want to spend their lives travelling around in caravans then they must operate within the law and rely on finding people willing to accommodate them - not expect special favours from the state. This politically correct initiative is not only flawed in principle but allows little room for local flexibility where councils are told to find additional sites, even though neighbouring authorities may have surplus sites.
Councils may say that they are forced to carry out the Government's bidding, but that does not excuse genuine consultation and democracy. Simply writing to villagers, and providing displays and meetings, asking how they would feel about a Gypsy and Traveller camp on their patch is only valid if the respondents are acknowledged and their views genuinely considered, even to the extent that it may mean a significant change of plans.
Many decent concerned residents see Gypsies and Travellers as a threat to their peaceful way of life, expressing genuine concern over the impact on crime rates and on the local environment. Is simply expressing such concerns, of itself, unreasonable or racist?
Across Britain there is a grotesque game being played between bureaucrats attempting to force through new sites, against objectors feeling obliged to hire lawyers to make sure submissions do not breach some thought crime which could result in them being disregarded.
Is it racist to say Gypsy and Traveller camps may cause an increase in crime and mess? Not to say that all Gypsies and Travellers are the same - there appears to be an elaborate calibrated class structure with Romany Gypsies looking down on Irish Tinkers who in turn have little time for New Age travellers. It is not right to suggest that all Gypsies and Travellers are criminal or that none of them work for a living.
There is an old fashioned romance for Gypsies which can still exist in reality sometimes, with brightly coloured Gypsy wagons drawn by ponies, and people who undertake honest temporary work for local farmers.
But are there not others who are a complete menace to those in proximity to them? Rather than insulting those who warn of problems, the Government and local authorities should address peoples' concerns.
Obviously, my opinion is epistemological, based on a cursory review of information available through the Internet and observing such people across the country, including, latterly at 'Tournament Fields' [previously an RAF Station and now a housing and business development area], just off the Stratford Road heading southwest out of Warwick.
From the latest (2011) census data just 24% [>14,000] of the 58,000 Gypsy and / or Irish Travellers live in caravans or other mobile or temporary structures. The "Gypsy and Traveller caravan count - January 2011" records:
* The total number of Gypsy and Traveller caravans in England remained broadly level at 18,383 caravans, an increase of 46 caravans since January 2010.
* A total of 6,942 caravans were on authorised public sites, a slight increase of 72 (1%) caravans since the January 2010 an average of 22.2 caravans per site.
* The number of caravans on authorised private sites was 8,332, an increase of 484 (6%) caravans since the January 2010 count - an average of 4.5 caravans per site.
* Caravans on unauthorised developments, on land owned by Gypsies and Travellers, decreased by 195 (8%) to 2,200 since the January 2010 count.
* Caravans on unauthorised encampments, on land not owned by Gypsies and Travellers, decreased by 315 (26%) to 909 since the January 2010 count.
* The average occupancy of an unauthorised encampment is 4.9 caravans per site compared with 3.6 caravans on unauthorised sites on land owned by Gypsies or Travellers.
* Overall, the January 2011 count indicates that 17% of Gypsy and Traveller caravans in England were on unauthorised land and 83% were on authorised land.
* Overall, the count indicates an increase of around 2,500 Gypsy and Traveller caravans in England and Wales since 2005, with a reduced overall percentage on authorised sites and an increase in those on unauthorised sites, despite a significant increase in provision.
Considering Gypsy or Irish Travellers living in England and Wales[1]
The Office of National Statistics analysis of 2011 Census data in response to which 58,000 people selected the Gypsy or Irish Traveller ethnicity option or wrote the same under the 'Other White' category (excluding people who identify as Roma), made Gypsy or Irish Traveller the smallest ethnic group (surveyed) at 0.1% of the England and Wales population. As an ethnic group, they are recognised under the Equality Act 2010 and considered by government and charities to be a vulnerable marginalised group who suffer from poor outcomes.
A higher proportion of Gypsy or Irish Travellers are under the age of 20 (39%) compared with England and Wales overall (24%) with a lower median age of 26, compared with 39 overall.
99% were born in Europe (including 88% in the UK). Their main language is English (or Welsh in Wales) at 91%, similar to that for England and Wales (92%).
20,500 households identified as Gypsy or Irish Traveller and 60% were one-family households. For all households, 45% had dependent children, above the average for England and Wales (29%).
Nearly a quarter, 24% of Gypsy or Irish Travellers, lived in caravans or other mobile or temporary structures, well above the average for England and Wales as a whole at 0.3%. Whole house or bungalow was the most common type of accommodation at 61%. They were more than twice as likely to live in social housing as the overall population of England and Wales (41% compared with 16%) and less likely to own their accommodation outright (21% compared with 26%).
Gypsy or Irish Travellers had the lowest proportion of people rating their general health as 'very good' or 'good' at 70% compared to 81% of the overall population of England and Wales.
Gypsy or Irish Travellers (over the age of 16) had the highest proportion of no qualifications for any ethnic group at 60%, higher than for England and Wales as a whole (23%).
Just under half of Gypsy or Irish Travellers were economically active; the lowest proportion of economically active at 47%, compared with 63% for England and Wales as a whole. Over half of those who were economically active were employed (51% compared to 75% for the total of England and Wales) and 20% were unemployed (compared to 7% for the whole of England and Wales). They had the highest proportion of self employed out of the ethnic groups at 26% compared to 14% for England and Wales. Just over half were economically inactive; the most common reason was looking after the home or family (27%) which was higher than that for England and Wales (11%).
For Gypsy or Irish Travellers (16 and over) in employment, elementary occupations (such as farm workers, process plant workers or service staff) were the most common type of employment at 22% (11% for England and Wales). The second highest occupation was skilled trades at 19% such as agricultural, electric and building trades, higher than England and Wales and all other ethnic groups.
Gypsies and Travellers seem to carry what some might call, 'myths and stereotypes' which may give rise to the prejudices and fears which even some rational people have with regard to the location of camps. Let's consider the debate more closely:
"Travellers are thieves and criminals"
The response from Gypsy and Traveller advocates is to say that in every community there are individuals who engage in criminal activity, but this should not be grounds for making sweeping assumptions - why should all Gypsies and Travellers be associated with anti-social or criminal behaviour? Just because some Gypsies and Travellers are thieves and criminals, doesn't mean they all are - does it? Campaigners on behalf of Gypsies and Travellers claim there is no evidence of higher crime rates amongst Gypsies and Travellers. Perhaps unintentionally, however, such a claim seems to accept that there is evidence of crime rates amongst Gypsies and Travellers at least at the National Average, a view Police, Local Authorities and the victims of crime at the hands of Gypsies and Travellers might be inclined to agree with. It may be coincidental that when caravans park up in an area, reported crime seems to increase,
One bad apple...
The fear and trepidation as well as the social impact and damage on small communities of even just one determined, itinerant criminal, whether stealing from gardens and outbuildings or breaking into houses and business premises, terrorising individuals, can be harrowing to the point of catastrophic. The impact of organised groups taking valuable metals from roof tops, or more dangerously, cable theft, can be financially injurious, often with the brunt of the impact being felt by Churches, Schools, Local Authority and Business premises. The impact on individuals can be life threatening when cables are stolen from road lighting and signaling systems, or railway premises. The impact on the neighbourhood from adverse news and crime statistics discourages visitors from visiting, particularly damaging in an area where employment and economic viability are heavily dependent on tourism and business start-up and innovation.
It is a matter of fact that settled communities, especially relatively 'comfortable' rural and semi-rural communities, have very low or even negligible crime rates. The visitation of just one or two criminals on such areas can have a devastating impact on people as well as crime rates, and when those events coincide with the presence of Gypsies and Travellers it's hardly surprising that people and authorities might jump to conclusions. The juxtaposition of social itinerant transit facilities adjacent to more affluent neighbourhoods is a recipe for disaster - the potential for harm to the community and a consequential increase in crime rates seems inevitable even to the most charitable mind. Sometimes temptation is just too great, and with the provision of transit facilities, where people can stop, do a little business, and move on, perhaps into the jurisdictions of others, can only serve to fuel the untouchable feeling and behaviour of criminal elements. Furthermore, as groups come and go, not settling permanently, the constant feeling of trepidation caused by the natural human reaction to strangers, renders life uncomfortable.
A low crime rate and social amenability is so much a feature of the Barford area that is was recently rated one of the best places to live in Britain, an accolade it would be unlikely to retain if the crime rate rose, and unsightly and unhealthy dumping became a significant problem.
Does Warwick District council really want to site Gypsies and Travellers at Barford, ranked in the top 10 places to live in the Midlands category of The Sunday Times' annual 101 Best Places to Live in Britain? The guide combines crime rates, house prices and school performances to select places with the best quality of life, good local shops and attractive outdoor spaces.
Warwickshire and particularly Barford has a crime rate significantly below the National Average; introducing even a small number of statistically evident criminals into the area is likely to have a detrimental affect on crime rates, and the peace of mind and security of the neighbourhood and its populous.
Advocates say that constantly referring to encampments as "illegal" furthers the perception that travellers are to blame for everything that goes wrong in the neighbourhoods they live in. But then again, squatting at the side of the road or on private land isn't always legal; if it were legal, then how is it that the law moves them on? Making sites 'legal' on its own will not change the anti-social, and even criminal behaviour of determined villains, regardless of their ethnicity.
Campaigners cite the statistic of Gypsies and Travellers in the prison population, saying there are few in prison, however, a cursory review of Police and Court records will reveal another interesting statistic - the frequency with which Gypsies and Travellers fail to answer summonses, submit to arrest warrants and show up in court. When they do answer charges, the prospect they face may be a guilty verdict, but not necessarily a custodial sentence, and there is also anecdotal evidence that, despite alleged prejudices by the Police towards Gypsies and Travellers, Police tend not to prosecute Gypsies and Travellers for minor offences due to the fact that their itinerant lifestyle means they will simply move on.
Campaigners speculate that it may be that ostracising Travellers from the Settled Community has the effect of pushing them to the margins of society and makes them more vulnerable to poverty and anti-social influences. If that was the case, would Gypsies and Travellers not prefer to settle, and object to the provision of what are effectively transit camps.
They leave rubbish everywhere and destroy the countryside.
Humankind produces huge amounts of waste every day. In every community, there are people who are concerned about doing their part for a clean environment, and those who do not care. Press reports of Gypsy Travellers which fuel the stereotype that they destroy the places they stay always outnumber the very rare reports to the contrary - good neighbours rarely make the news.
Even though site residents pay rent and taxes, they do not enjoy the same rights as people in settled housing. Many sites remain poorly serviced, lack proper sanitation, and waste disposal facilities which leaves residents living in squalid conditions they can do nothing to change.
However, there are also a number of sites which are very well managed and cared for by Travellers and local authorities but that doesn't seem worth highlighting in the press.
Gypsy Travellers do not seek out places to live where they are in poverty without access to basic facilities such as water, electricity, and sanitation. Lack of temporary and permanent sites leaves them with no place to go and pushes many families to resort to the only option available - unauthorised encampments. Those then fan the flames of an already tense relationship between Travellers and the settled community resulting in stress and evictions.
Everyone has the right to an adequate standard of living, as enshrined in the Universal Declaration of Human Rights. They are also entitled to culturally appropriate housing that matches their lifestyle.
Due to the lack of interaction between the communities, the media is often the only source of information. Sadly, many journalists are passionate about pursuing negative portrayals of Travellers.
Evidence provided to Select Committee on the importance of site location:
"What is working [in Ireland] are small sites. And they are not placed under flyovers or pylons, or beside sewers, canals or tips; they are placed on proper positioned land, bang within the middle of a settled community, and they are working."
"We would make a strong plea for safeguards to be put in place to ensure that future site development is not located in polluted or hazardous locations, as... many sites are. Not only does this have a negative impact on Gypsies and Travellers health and access to services but it has a profound impact on how they feel they are perceived and treated by the wider community, likewise such locations reinforce the prejudiced perceptions that many in the settled community have of Gypsies and Travellers, such locations are therefore a major impediment to social inclusion.
[1] http://www.ons.gov.uk/ons/rel/census/2011-census-analysis/what-does-the-2011-census-tell-us-about-the-characteristics-of-gypsy-or-irish-travellers-in-england-and-wales-/sty-gypsy-or-irish-travellers.html
I could go on, but I think you get my drift.

Thank you for taking my thoughts into consideration.

New Local Plan - Permanent Gypsy site selection
GT12 / GTalt 12

As a local resident in Wasperton we wish to object to the possible choice of this site on the basis of safety, lack of local facilities and loss of valuable farming land.

1. The main road past the site is the major route to the Cotswolds. The site is on a long sweeping bend where most traffic travels above the legal speed limit of 60mph, even past the second Barford turning. This stretch of road is highly tempting to impetuous drivers who often overtake slower vehicles travelling at 50pmh. The only safe solution will be to build it as a dual carriageway.
2. The possible solution could be to put up traffic lights or a large pull-off stretch but then the Traveller will be faced with towing a long vehicle across the heavy stream of traffic with all the inherent dangers.
3. Travellers wishing to visit Barford, say to take children to school, will have to cross this major road with all the dangers of attempting to slow the traffic.
4. Vehicles and trailers exiting GT12 turning either right or left will face the danger of being rammed unless lights are installed.
5. Personally speaking we have been involved with three similar incidents when turning into Wasperton with drivers overtaking double lines to gain additional road space. Sight lines will be similarly restricted opposite the suggested GT12 site.
6. This site will require efficient drainage and a soak-away which will also require regular servicing. Can we trust the travelling community to commission this work or will seepage occur into the River Avon which is very close by?

7. The local plan suggests that there is a Doctors surgery in Barford. This is not correct, the nearest we believe is in Wellesbourne.
8. The local facilities are confined to a local shop in Barford and shops in Wellesbourne. The latter Town is currently been expanded with 1600 houses on the airfield and would be highly suitable for a traveller site as the Town sits in open countryside where traffic has to travel at slower speeds (4 Roundabouts currently on the main road).
9. The Local school in Barford is already at a maximum capacity and is located on a restricted site. Any further expansion will require the local authorities to relocate at considerable expence.
10. This GT12 site sits in the middle of highly productive farming land which has already been badly affected by the essential building of the Barford Bypass. This choice will have a detrimental effect on the local economy.

In conclusion, and certainly not on a NIBI basis, The choice of a site should surely be measured against just how well the Travelling community will fit into the local environment without endangering life and limb or that very environment itself. GT12 is in a dangerous position which will require considerable cost to make safe. It has not got local facilities to hand and will damage local industry. There must be a simpler and better solution to this issue and we look to you, our local government, to provide a sensible answer.

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

I am writing to register our objections and give our views on the suitability of the following Gypsy and Traveller Preferred Options Consultation.

GT12/GTalt12 - Land at north and west of Westham Lane
* Warwick District Council (WDC) Criteria states that the site should have "convenient access to a GP surgery, school, and public transport" - The nearest GP Surgery is nearly 5 miles away by road in Bishops Tachbrook and there is not an easy access from Barford.
* WDC Criteria states that the site should "avoid areas with a high risk of flooding" - This site sits within (part) and otherwise immediately adjacent to areas identified by the Environment Agency as having significant flood risk.
* WDC Criteria states that the site should have "Safe access to the road network and provision for parking, turning and servicing on site" - Vehicular access to this site is from the A429 trunk road (The Barford Bypass) which was constructed as a bypass to Barford. It is a 60 mph speed limit road and there have been a significant number of traffic accidents including a fatality. There is also inadequate pedestrian crossing facilities for safe access into the village. Access would be difficult and expensive whilst being very dangerous for both vehicle users and pedestrians
* WDC Criteria states that the site should "avoid areas where there is the potential for noise and other disturbance" - Noise levels from the By Pass and M40 roundabout can be heard through double glazing in the surrounding houses. The continuous noise from the Barford Bypass could not be reduced effectively or economically by constructing barriers.
* WDC Criteria states that the site should have "Provision of utilities (running water, toilet facilities, waste disposal, etc)" - There are no such services available in the area and the cost for supplying these for a small number of pitches would be considerable and therefore render the site uneconomical.
* WDC Criteria states that the site should be "Avoiding areas where there could be adverse impact on important features of the natural and historic environment" - The
proposed site is on the busy route between the historic town of Warwick and the Cotwolds, and the impact on the landscape and tourism of a Gypsy and Traveller site would be immense.

* WDC Criteria states that the "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" - The proposed site is green field and a satellite from Barford village, the development of this site could not take place without a material adverse effect on the landscape and could not be integrated without harming the visual amenity and character of the site.
* WDC Criteria states "Promotes peaceful and integrated co-existence between the site and the local community" - The A429 Barford Bypass isolates the site from the village and therefore presents a physical barrier to integration with the village.
* WDC Criteria states "Avoids placing undue pressure on local infrastructure and services" - This site does not fully meet with the provisions of Planning Policy for Gipsy & Traveller sites as it does not promote peaceful integrated co-existence between the proposed sites and the local community. It will also place undue pressure on the local infrastructure and services. It would have a material negative impact on the capacity of Barford St. Peter's School, especially given the village's status as a "Secondary Service Village" and its likely requirement to provide 70-90 new dwellings during the Plan period.
The Gypsy and Traveller community should be catered for and integrated into new, larger mixed development sites being proposed through the New Local Plan. Larger pitches would be more economical as opposed to smaller pitches which would drive down the pitch costs, gets economies of scale and has less impact on fewer communities and residents.

The following sites would seem eminently more suitable to a greater or lesser degree than the two proposed sites adjacent to Barford Bypass:

* Sites GT02- Land Abutting Fosse Way at Junction with A425 (part) already has an immediate access to popular route for Gypsies and Travellers.

* SiteGTalt03 Henley Road /Hampton Road - where the landowner is very keen to promote the site for the required purpose. The site is available and deliverable.

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

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