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

WARWICK GYPSIES AND TRAVELLERS SITES - PREFERRED OPTIONS CONSULTATION
We write on behalf of Taylor Wimpey UK Ltd in respect of the Warwick District Council Gypsies and Travellers Preferred Options consultation document. Whilst there is an identified need to be met for Gypsies and Travellers either living in or passing through the area, it is imperative that the preferred sites are located where they embrace opportunities for community cohesion and maximise the accessibility of services for all.
Preferred site at land north of Westham Lane, Barford (site GT12)
We note that, despite our previous representations, site GT12 has now been recognised as a preferred site by the Council for meeting the Gypsy and Traveller need over the Plan period. In our view the assessment has remained silent on a critical issue in relation to this site, namely its location on the opposite side of the bypass to the village and subsequent separation from many of the services and facilities on which its residents will be reliant.
As noted in our previous representations, the A429 opened in February 2007 and is considered to clearly mark the western edge of Barford settlement in its current form. It is considered that the A429 has a significant impact on the ability of any sites to the west of it to meet the aims for future Gypsy and Traveller site provision as set out in the Planning Policy for Traveller sites (March 2012) document produced by DCLG. Whilst the DCLG guidance has been referred to in paragraph 1.2 of the Preferred Options consultation document we would draw particular attention to the following specific requirements, namely that the Local Planning Authorities should:
* promote peaceful and integrated co-existence between the site and the local community;
* ensure that children can attend school on a regular basis; and
* provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there or on others as a result of new development (Para. 11).
Taking the above points in turn, there are significant concerns as to how the allocation of the land covered by site GT12 can achieve 'integrated co-existence' with the existing community whilst being separated both physically and visually from the existing residents of Barford. Furthermore, the WARWICK GYPSIES AND TRAVELLERS SITES - PREFERRED OPTIONS CONSULTATION
We write on behalf of Taylor Wimpey UK Ltd in respect of the Warwick District Council Gypsies and Travellers Preferred Options consultation document. Whilst there is an identified need to be met for Gypsies and Travellers either living in or passing through the area, it is imperative that the preferred sites are located where they embrace opportunities for community cohesion and maximise the accessibility of services for all.
Preferred site at land north of Westham Lane, Barford (site GT12)
We note that, despite our previous representations, site GT12 has now been recognised as a preferred site by the Council for meeting the Gypsy and Traveller need over the Plan period. In our view the assessment has remained silent on a critical issue in relation to this site, namely its location on the opposite side of the bypass to the village and subsequent separation from many of the services and facilities on which its residents will be reliant.
As noted in our previous representations, the A429 opened in February 2007 and is considered to clearly mark the western edge of Barford settlement in its current form. It is considered that the A429 has a significant impact on the ability of any sites to the west of it to meet the aims for future Gypsy and Traveller site provision as set out in the Planning Policy for Traveller sites (March 2012) document produced by DCLG. Whilst the DCLG guidance has been referred to in paragraph 1.2 of the Preferred Options consultation document we would draw particular attention to the following specific requirements, namely that the Local Planning Authorities should:
* promote peaceful and integrated co-existence between the site and the local community;
* ensure that children can attend school on a regular basis; and
* provide for proper consideration of the effect of local environmental quality (such as noise and air quality) on the health and well-being of any travellers that may locate there or on others as a result of new development (Para. 11).
Taking the above points in turn, there are significant concerns as to how the allocation of the land covered by site GT12 can achieve 'integrated co-existence' with the existing community whilst being separated both physically and visually from the existing residents of Barford. Furthermore, the opportunities to safely access services and facilities in the village - including Barford Church of England Primary School - will inevitably be negatively impacted on and due to the nature of the road may be unsafe. This is referred to in the Preferred Options consultation document on page 38 where it states that, '... there may be some safety issues in crossing the Barford by-pass to access these (local facilities).' Given the number of the sites that the Council has to choose from it is not considered appropriate than one of the preferred sites has such a fundamental issue with its delivery, particularly as the time at which children in particular are most likely to be crossing the road - to travel to and from school - will coincide with periods of peak traffic flow.
It is also noted that there is a mixture of an earth bund and a fence structure on the eastern side of the A429, which has been designed to both reduce the visual impact of the road and also limit the noise impact from vehicles utilising the bypass on residents. It is a significant concern that any development of a Gypsy and Traveller site to the west of the A429 would not benefit from this structure and the environmental quality of any sites to the west of the A429 must be considered in this regard. Given the reference to this issue in section 7 of the detailed site assessment it is assumed that a likely method for responding to this issue would be to mirror the noise attenuation barrier on the eastern side of the by-pass. Nevertheless, this would have a significant impact on views across the area to the east of the by-pass and thus is not without disbenefits.
This potential noise attenuation feature is also relevant when considering paragraph 24 of the Planning Policy for Traveller sites document, which states that in considering planning applications sites should not be enclosed '... with so much hard landscaping, high walls or fences, that the impression may be given that the site and its occupants are deliberately isolated from the rest of the community.' It is considered that this site would be contrary to this site-level consideration at the application stage due to the distinct isolation as discussed above and should therefore not be favoured as an allocation by the Council.
Summary
Given the above, it is considered that the Council should ensure that there are opportunities to achieve community cohesion and access essential services for the travelling community on any sites included as future allocations. These matters should in our view restrict development of a Gypsy and Traveller site on the land to the west of the by-pass in Barford (site GT12).
We trust the enclosed representations are clear. If however you have any queries or wish to discuss the above in any further detail, please do not hesitate to contact me.