Gypsy and Traveller Site Options

Stratford-on-Avon District Council (SDC) makes the following comments in respect of Warwick District Council's 'Sites for Gypsies and Travellers' consultation document, dated June 2013.

SDC understands that this document is effectively a scoping consultation to provide a steer to Warwick District Council in order to assist them in identifying suitable specific sites for Gypsies and Travellers to meet their needs over the 15 year plan period. Following this consultation, Warwick District Council will further consult on its Preferred Options (i.e. sites). SDC draws Warwick District Council's attention to best practice and Government guidance, particularly in respect of optimum site size, use of strategic sites and the requirement for co-existence between the settled and traveller communities.

SDC supports the inclusion of a criteria-based policy for bringing forward suitable sites for Gypsy and Traveller pitches through a DPD. This should also apply to proposals bought forward via a planning application. However, SDC considers that this policy might be strengthened through the inclusion of further criteria, for example:
* The site will not be located on unstable or contaminated land that cannot be mitigated
* The site will have a good residential environment and be of good quality design
* The site will not adversely impact on neighbouring residential amenity
* Arrangements are put in place to ensure the proper management and retention of the site

The latter three criteria are particularly important given the close proximity of the broad locations to Stratford-on-Avon District. SDC considers that mechanisms should be put in place to ensure that the site identification approach takes account of the likely impacts on the wider locality, irrespective of administrative boundaries, and those residents in Stratford District affected by the proposals are engaged and consulted to the same degree as residents of Warwick District.

In respect of the broad locations, it is unclear how they have been identified since no assessment is provided and the benefits of these particular locations are not shown. This begs the question as to why these particular locations have been selected rather than, say, an adjacent parcel of land. Notwithstanding this, it is acknowledged that any Gypsy and Traveller site would only form a small parcel of land within any one broad location, and there would be only one site per broad location. SDC endorses this approach. However, some of the identified broad locations are in very close proximity with each other. SDC considers that some broad locations should be treated as mutually exclusive and the identification of actual sites in close proximity, albeit in separate broad locations, should be avoided. The following broad locations ought to be considered as mutually exclusive:
* sites GT03 and GT04
* sites GT05, GT09 and GT10
* sites GT05, GT06, GT09 and GT15
* sites GT12 and GT16

SDC is concerned at the proximity of many proposed sites where such a relatively high density of traveller facilities may create a disproportionately high concentration of caravan and temporary buildings that may impact adversely upon the openness and character of the landscape and otherwise impact on the balance between the settled and traveller communities. SDC note that many of the sites are for 12-15 pitches, which could result in 30 caravans plus facilities per site. Optimum site size is generally considered to be 5 pitches.

SDC is also aware that Warwick District Council is proposing two strategic allocations: the first to the south of Warwick and Witnash around the Europa Way and Harbury Lane junction, and the second to the south of Whitnash, east of the railway. Apart from broad location 15 which appears to abut the first on the A452, no broad locations are related to either strategic allocation. SDC considers that these options should be explored further given that locations in more rural areas may potentially be further away from services and facilities.

Until specific sites are identified as part of the Preferred Options consultation SDC, SDC does not consider it is in a position to provide specific comments on the suitability or otherwise of the broad locations. Notwithstanding this SDC would welcome the opportunity to work with Warwick District Council as part of the plan-making process. Finally, I draw your attention to a factual error. To avoid confusion, Site GT02 should be re-titled to read 'Land abutting the Fosse Way at its junction with the A425', not the B425 which is in Solihull.

SDC understands that this document is effectively a scoping consultation to provide a steer to Warwick District Council in order to assist them in identifying suitable specific sites for Gypsies and Travellers to meet their needs over the 15 year plan period. Following this consultation, Warwick District Council will further consult on its Preferred Options (i.e. sites). SDC draws Warwick District Council's attention to best practice and Government guidance, particularly in respect of optimum site size, use of strategic sites and the requirement for co-existence between the settled and traveller communities.

SDC supports the inclusion of a criteria-based policy for bringing forward suitable sites for Gypsy and Traveller pitches through a DPD. This should also apply to proposals bought forward via a planning application. However, SDC considers that this policy might be strengthened through the inclusion of further criteria, for example:
* The site will not be located on unstable or contaminated land that cannot be mitigated
* The site will have a good residential environment and be of good quality design
* The site will not adversely impact on neighbouring residential amenity
* Arrangements are put in place to ensure the proper management and retention of the site

The latter three criteria are particularly important given the close proximity of the broad locations to Stratford-on-Avon District. SDC considers that mechanisms should be put in place to ensure that the site identification approach takes account of the likely impacts on the wider locality, irrespective of administrative boundaries, and those residents in Stratford District affected by the proposals are engaged and consulted to the same degree as residents of Warwick District.

In respect of the broad locations, it is unclear how they have been identified since no assessment is provided and the benefits of these particular locations are not shown. This begs the question as to why these particular locations have been selected rather than, say, an adjacent parcel of land. Notwithstanding this, it is acknowledged that any Gypsy and Traveller site would only form a small parcel of land within any one broad location, and there would be only one site per broad location. SDC endorses this approach. However, some of the identified broad locations are in very close proximity with each other. SDC considers that some broad locations should be treated as mutually exclusive and the identification of actual sites in close proximity, albeit in separate broad locations, should be avoided. The following broad locations ought to be considered as mutually exclusive:
* sites GT03 and GT04
* sites GT05, GT09 and GT10
* sites GT05, GT06, GT09 and GT15
* sites GT12 and GT16

SDC is concerned at the proximity of many proposed sites where such a relatively high density of traveller facilities may create a disproportionately high concentration of caravan and temporary buildings that may impact adversely upon the openness and character of the landscape and otherwise impact on the balance between the settled and traveller communities. SDC note that many of the sites are for 12-15 pitches, which could result in 30 caravans plus facilities per site. Optimum site size is generally considered to be 5 pitches.

SDC is also aware that Warwick District Council is proposing two strategic allocations: the first to the south of Warwick and Witnash around the Europa Way and Harbury Lane junction, and the second to the south of Whitnash, east of the railway. Apart from broad location 15 which appears to abut the first on the A452, no broad locations are related to either strategic allocation. SDC considers that these options should be explored further given that locations in more rural areas may potentially be further away from services and facilities.

Until specific sites are identified as part of the Preferred Options consultation SDC, SDC does not consider it is in a position to provide specific comments on the suitability or otherwise of the broad locations. Notwithstanding this SDC would welcome the opportunity to work with Warwick District Council as part of the plan-making process. Finally, I draw your attention to a factual error. To avoid confusion, Site GT02 should be re-titled to read 'Land abutting the Fosse Way at its junction with the A425', not the B425 which is in Solihull.