This is my responces to the Preferred options for Cubbington that are being suggested are:

* Both areas are too close to the Village & would cause considerable distress to nearby residents
* Properties would also be devalued due to the siting of these areas
* Green fields are not an appropriate use of land for such sites
* Local Schools would be made to accept an influx of disruptive children reducing the quality of education for our own village children
* Anti-social behaviour levels & nuisance would rise considerably
* Crime levels in the village would increase
* Litter & Rubbish would increase
* Shops & Pubs would loose business due to traveller presence
* Parish council costs would increase

This proposal is ill concieved & should definately NOT go ahead

Alternative Brown field sites away from existing established council tax payers should be considered ................

Potentially an ideal site but may be "not cheap" to achieve due to need to buy whole site - certainly worth exploring this option.

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.

Sites for Gypsies and Travellers - Preferred Options

I refer to your letter of 17th March 2014.

The Parish Council have now had an opportunity to discuss the above proposals and wish to submit the following comments.

It is noted that areas of land off Leicester Lane, Cubbington (ref. GTalt07) and Welsh Road, Cubbington (ref. GTalt10) have been discounted but that the depot area off Leicester Lane, Cubbington to the west of Cubbington Heath Farm (ref. GT08) and land off Rugby Road, Cubbington (ref. GTalt02) have been classified as 'Amber' sites and shortlisted as they could be made suitable if major changes were made. It is understood that these two areas are not deemed to be Preferred Options which will be brought forward during the life of the Local Plan.

As was pointed out in my letter of 10th July 2013 to you, the depot site is owned by the Cubbington Freeholders charity. The Parish Council strongly support the concerns raised by the Freeholders who are anxious to ensure that the charity are able to continue with the extremely valuable financial support that they have been able to provide to local organisations over many years. Their work is invaluable to the well-being of the local community and the Parish Council are opposed to any action being taken which would be detrimental to the interests of the Freeholders and, through them, the community and our local organisations.

The National Planning Policy Framework (NPPF), which sets out guidance on the government's aims in respect of sites for travellers, states that sites must enable occupants to access education, health, welfare and employment infrastructure and that local planning authorities must have due regard to the protection of local amenity and local environment. It is not clear what access to education, health and welfare would be available to the gypsy and traveller community in respect of the depot area. It is also questionable as to whether the site is an appropriate location given the highway safety issues that may result from accessing and egressing this site on to the A445. The Parish Council believe that this site is not sustainable in terms of access to public transport and health facilities. Currently there is no bus service accessible from the site and the nearest doctors' surgery is in Lillington.

In addition, the Parish Council also believe that the use of this area of land for a gypsy and traveller site would potentially create noise and disturbance to the nearby residents. The use of the area for this purpose would also have a detrimental impact on the wildlife and would, therefore, be in contravention of the NPPF guidance.

There is a suggestion that, as a result of a previous use of the land, it could be heavily contaminated and there would be significant expense in making it safe for residential use. It would require treatment before it was suitable for occupation.

For these reasons, the Parish Council, continue to oppose strongly the suggestion that the land could become a site for travellers and gypsies.

With regards to the area off Rugby Road (ref. GTalt02), the Parish Council are concerned that the possible future use of this land would involve incorporating an area of North Cubbington Wood. This is ancient woodland which is already under severe threat as a result of the HS2 proposals. The Parish Council believe that the site is unsuitable taking into account the criteria that sites identified for use must not have an adverse impact on important features of the natural and historic environment. The site also does not have convenient access to a GP surgery and public transport which would be in contravention of the National Planning Policy Framework referred to above.

The Parish Council are aware that if any of the sites which have been deemed suitable for further public consultation and comment are then rejected, the sites currently classified as 'Amber' could well come under consideration. We are anxious, therefore, that our comments should be taken into consideration with a view to these two 'Amber' sites in Cubbington being discounted.

Allied to this issue, we would question why it is necessary to provide sites within the district when there is, we understand, a site in the Ryton area which is underused? An explanation regarding this point would be appreciated please.

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