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.

Sites for Gypsies and Travellers - Objection to Preferred Options Removal of Site Ref GT08 from Allocation

I refer to your letter of 17th March 2014 regarding potential sites for occupation by gypsies and travellers.

The Trustees have noted that the depot area off Leicester Lane, Cubbington to the west of Cubbington Heath Farm (ref. GT08) has been classified as an 'Amber' site and shortlisted as it could be made suitable if major changes were made.

It is understood that this area is not deemed to be a Preferred Option which will be brought forward during the life of the Local Plan but we remain concerned that it could come under consideration if one of the preferred sites is rejected.

I would refer you to my letter dated 1st July 2013 addressed to Ms. Tracy Darke in which I explained the history of the area and how it is held in trust by the Freeholders' charity for the benefit of the residents of Cubbington. I would stress our view that the charity should be able to continue with the financial support that we have been able to provide to local organisations over many years. We remain opposed to the use of this land as a site for gypsies and travellers as this would be detrimental to the interests of the charity, the community and the local organisations who benefit from the charity.

The Freeholders charity remains very active and over the past eleven years we have been able to make grants totalling £121,000 to support the activities of a wide variety of local organisations within the parish of Cubbington.

We therefore request that the future of the charity should be secured by removing the site as a potential site for gypsies and travellers and that its Amber status should be rescinded.
When the possibility of the land being occupied for residential purposes was initially discussed there was a recollection that in the early part of the last century the land was used as a tipping site for local waste. The extent and the type of waste is not known but it is thought that the land would be heavily contaminated and would require treatment before it was suitable for occupation. As the Council will no doubt appreciate the statutory threshold under the Environmental Protection Act 1990 and supporting statutory guidance is very high. The costs associated with making the site suitable for residential gypsy and traveller provision would outweigh the benefits.

More generally, the Freeholders believe that, due to the relatively isolated location of this site, it is not sustainable for residential use due to the lack of access to public transport, health, welfare and educational facilities. These are required under the National Planning Policy Framework which sets out guidance on the government's aims in respect of sites for travellers.

The Freeholders' legal advisor has informed us that as the site formed part of a large site that had been mined and quarried for stone in the past it would have been classified as such under the Mines and Quarries Act 1954. It would therefore have to be safeguarded from any form of residential use.

Our legal advisor has also said that the need for the various proposed sites in the district under consideration has not in his view been properly or correctly analysed. He appreciates that the assessment of gypsy and traveller accommodation (GTAA) needs when carrying out a periodical review of housing needs under section 8 of the Housing Act 1985 is a statutory requirement under section 225 of the Housing Act 2004. The assessment and the strategy must be based on a full understanding of gypsy and traveller accommodation needs. The Council commissioned Salford University to carry out this assessment on the assumption that it would be reliable. However, his view is that the criteria and approach adopted by Salford University in carrying out the assessment is open to question as to whether it identifies the correct number of pitches. This is because he believes the assessment fails to include data from the neighbouring authorities in Warwickshire. Given the GTAA forms part of the Strategic Housing Market Assessment, there is a legal obligation to consult with the neighbouring authorities as required by the Localism Act 2011. As he understands that this data has been omitted it would mean that the GTAA is not reliable.

In conclusion, I must state that the Trustees will not agree to sell the this land now or at any time in the future as to do so would jeopardise the role of the Trust and the very valuable help it has given to the local community in terms of grants and funding.

We therefore respectfully request that, to safeguard the future of the charity to operate for the continuing benefit of the local community, this site is removed from the list of Amber sites for allocation.

see attached

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.

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.

see attached