Bishopton Action Group: Objection Letter Round 2


	Consultation 2 Bishopton Action Group Annabel Goldie Iain Langlands

Bishopton Action Group

LETTER OF OBJECTION TO THE ALTERATION TO THE STRUCTURE PLAN

2nd ROUND OF CONSULTATION

4 November 2005

Mr. Vincent Goodstadt

Structure Plan Manager

Glasgow and Clyde Valley Structure Plan Joint Committee

10 Killermont Street

Glasgow G2 3NW

Dear Mr. Goodstadt

ROF SITE BISHOPTON

GLASGOW AND THE CLYDE VALLEY 2005 STRUCTURE PLAN ALTERATION

On behalf of Bishopton Action Group (BAG), we wish to express our views and objections to the Draft Structure Plan 2005 2nd Round of Consultation, the Environmental Report and also reinforce our initial objections in our letter dated 17 June 2005.

A. PLANNING

In our letter of 17 June 2005, written in response to the Consultation on the 2005 Draft Structure Plan, we argued that the proposed inclusion of Bishopton in Schedule 1(c) as an urban expansion area was contrary to the guiding principles of sustainable development contained in the Structure Plan 2000.

Key considerations for sustainable development, set out in the Structure Plan 2000, are that development should:

- reinforce and support existing communities;

- ensure that there is an equitable balance between the costs and benefits of any development;

- be capable of implementation without adverse impacts on their physical identity or quality of life.

We raised concerns regarding the risk which development posed to the health and safety of the public. We argued that the issues related to contamination and remediation must be explored before the principle of strategic development is established.

We argued that the scale of development, effectively doubling the population, is not commensurate with the size of the existing village, the rural character of the area and the principles of sustainable development. It will swamp the village and totally destroy its character.

The Draft Plan stated that the development should enhance existing communities and not merely take advantage of services and amenities that they offer. The vagueness and lack of detail in the BAE Systems proposals (provided as a supporting document in the Draft Plan) for investment in infrastructure, the community and education facilities, fail to satisfy this requirement. We specifically asked you to clarify requirements for primary and secondary school provision, how problems of congestion and overcrowding of the rail network are to be sorted and how problems of road congestion are to be dealt with. Without answers to these questions, we maintain that the proposal can only have a negative impact and adverse effect on the quality of life of Bishopton residents.

Your responses to our objections of 17 June 2005, made firstly in your report to the Joint Committee in August and more recently in your response of 7 September 2005 to Bishopton Action Group, fail to consider any of the above matters in any detail. The current consultation and, in particular, the Assessment of Potential Expansion Areas (TR B/05) fails to answer any of the questions which we have raised. You suggest such matters will be for the next stage of the planning process (Master Planning). We maintain such matters should be addressed now, before the principle of the development location is established. Without this how can we be assured that development can take place without adverse impacts on our community and that a sustainable approach, which balances costs and benefits, has been undertaken?

In subsequent sections specific criticisms are made of the following reports:

Draft Finalised Supplementary Written Statement,
Assessment of Potential Area for Urban Expansion (TR B/05)

A(1) Response to Draft Finalised Supplementary Written Statement

Section 2 Urban Expansion Areas

Paragraph 2.10 states that Urban expansion requires appropriate services and infrastructure. This can best be achieved by a focus on larger longer term development areas which support the Metropolitan Development Strategy and are subject to Master Planning.

It is evident from the accompanying report on the Assessment of Potential Areas for Urban Expansion that there has been no serious assessment of the capacity of existing infrastructure to support further development or the need for additional infrastructure. Without an assessment of infrastructure requirements, how can you substantiate the assumption that appropriate services and infrastructure can best be achieved by a focus on larger longer term development areas? For example, it might be cheaper to have several smaller developments which use existing spare infrastructure capacity. No evidence has been provided of the benefits from a focus on larger, longer term development areas, yet this assertion forms the basis for a major concentration of development at Bishopton.

Paragraph 2.13 states that requirements for supporting infrastructure and services shall be established through the preparation of Master Plans. We consider that these requirements should be dealt with now and this would be consistent with the guiding principles for sustainable development in the Structure Plan 2000. These principles require that development should reinforce and support existing communities, ensure an equitable balance between costs and benefits and be capable of implementation without adverse impacts. In line with these principles, it would seem only common sense to have some idea of the availability and requirements for infrastructure and of who is to pay for it before establishing the principle of development. This has not been done.

Paragraph 2.14 claims that Bishopton's potential has been assessed. We consider the assessment of potential has been limited. The planning assessment has considered greenbelt and landscape impacts and proximity of rail stations as the main locational considerations for defining urban expansion areas. No assessment has been made of contamination, land remediation costs, infrastructure requirements or community facilities. Without such assessments the practicality of development and its economic viability are unknown.

Paragraph 2.14 states that "The nature and scale of development in these areas within the potential capacities set out in schedule 1(c) will be defined through local planning and Master Planning". This allows development for some 2,500 houses. It is noted that the local shortfall in the Renfrewshire sub market amounts to only 200 houses (TR A/05). The proposed development exceeds shortfall by 2300 houses. We would argue that the figure of 2,500 houses is therefore not justified.

We request that the Supplementary Written Statement should provide further clarification and information on the following points:

the basis for the assumption that appropriate services and infrastructure can best be achieved by a focus on larger longer term development areas, such as Bishopton;
the availability of, and requirements for, infrastructure, education and community facilities at Bishopton and who is to pay for such items;
the health and safety issues related to contamination and the practicality and costs of site remediation at Bishopton;
why the amount of housing that is proposed by the Structure Plan at Bishopton is set at 2500.

A(2) Response to TR B/05 Assessment of Potential Areas for Urban Expansion Strategic Assessment

Paragraph 5 states that the factors used to guide selection have been considered under the following headings:

(a)Urban Renewal and Regeneration

(b)Environmental Factors

(c)Transportation

(d)Relationship to Existing Communities

(e)Issues Raised in Consultation

(a) Urban Renewal and Regeneration

Bishopton Royal Ordnance is considered under this heading. However, we maintain it is not an urban site and note that paragraph 7.35 (A) of the Structure Plan 2000 agrees with us. It states "Although parts of the site are currently or were formerly industrial use, it has a largely rural setting and cannot be considered to be an urban site".

(b) Environmental Factors

Greenbelt Structure:Paragraph 9 identifies the Bishopton - Bridge Of Weir - Linwood area as a structural corridor sensitive to urban coalescence. Although Paragraph 12 considers that, at the Structure Plan level, the broad landscape categorisation of sensitive wedges or structural corridors should be the key criteria, no further consideration of the structural corridor is given in the assessment of development at Royal Ordnance. Indeed, the conclusion in paragraph 33 appears to contradict the key criteria when it refers to sensitive wedges and landscape setting as being the most sensitive green belt areas. It omits any reference to structural corridors. The failure to refer to the structural corridor of Bishopton - Bridge of Weir - Linwood ignores the important contribution it plays in preventing coalescence.

Greenbelt Boundaries: In addition to structural corridors and sensitive wedges, two additional criteria have been taken into account: landscape setting of settlements and conservation areas.

a)Under landscape setting of settlements, only two areas are identified in Renfrewshire; Paisley South and Houston. This appears a somewhat arbitrary choice given the generally high quality of landscape surrounding Renfrewshire's villages, including Bishopton. No reference is made to any objective landscape assessment to substantiate the argument made.

b)Communities previously recognised as being sensitive to urban expansion because of their conservation interest, feature only Kilbarchan and Langbank in Renfrewshire. For further information related to this matter, reference is made to decisions in connection with the 1990 and 1995 Strathclyde Structure Plans. The reference is somewhat opaque and does not allow us to understand the basis on which the list has been compiled. In view of the extensive conservation interests in Renfrewshire, the choice again appears arbitrary.

Greenbelt and Countryside Resources:Paragraph 13 indicates that urban expansion should not be proposed if it involves any threat to environmental resources as listed in Schedule 7 of the Structure Plan 2000. We would suggest consideration should also be given to the response made by Scottish Natural Heritage to the Consultative Draft Plan where it states that the Royal Ordnance Factory is valuable as a reservoir for mammal and bird populations. It is therefore vital that this wildlife resource is taken into account.

(c ) Transportation

References made to the transport network should be prefaced by "rail" since no reference is made to the bus transport network and the opportunities that it might offer to reduce reliance on the private car. The basis of the analysis of public transport is therefore restricted.
Paragraph 18 states that all major developments will require detailed transport appraisal through the Master Plan process. However, work undertaken by BAE Systems/CASS, and reported to Renfrewshire Council in March 2005, indicated that the Royal Ordnance proposals would only be viable and acceptable with improved access to the site via a new link from M8 (and that a decision on this matter by the Scottish Executive remained outstanding). The requirement for M8 access is also recognised in the Structure Plan Consultative Draft (paragraph 2.20). This is therefore a known requirement and one where a final decision has yet to be made. Without the interchange, Bishopton has poor links to the strategic road network and major expansion would exacerbate problems on the existing road network. Bishopton, at present, is therefore similar to Houston and Bridge of Weir, which are referred to as problem areas for expansion in relation to the strategic road network.

(d) Relationship to Existing Communities

Paragraph 22 states that "Educational provision is a strategic requirement on any development, but current school capacity is not a determining factor in the choice of locations". This statement seems at odds with the Scottish Executive's response to the Consultative Draft, which stated that consideration will need to be given to the planned provision of new school accommodation, particularly in the areas marked for urban expansion.
We would argue that a sustainable approach would look towards making best use of existing education resources, particularly in circumstances where Renfrewshire Council has embarked on a major PPP programme. With typical costs for a new primary school in the order of £6M, and in circumstances where the Bishopton proposal may require two primaries, plus additional secondary school accommodation, to ignore consideration of education provision as a determining factor is not a cost effective or a sustainable approach. Education should be a determining factor on choice of locations.

(e) Issues Raised in Consultation

Paragraph 24 states that Scottish Natural Heritage's concerns about the landscape and environmental impacts of urban expansion made in response to the Consultative Draft Plan have been central to the assessment process. In relation to Bishopton, Scottish Natural Heritage stated that the Royal Ordnance Factory "is valuable as a reservoir for mammal and bird populations. It is therefore vital that this wildlife resource is taken into account." There is however no specific mention of this in the technical report.
Paragraph 28 states that concerns expressed about the impact on the environment, amenity and the provision of adequate transport and community facilities are matters which have been taken account of in assessing all locations. This contradicts the statement in paragraph 22 which indicates quite clearly that education has not been taken into account as a determining factor in choice of location. We would argue that little or no account has been taken of the concerns expressed about the impact on the environment, amenity and the provision of adequate transport and community facilities, since no studies have been done on any of these matters. They are all unknown quantities.
Paragraph 28 also refers to a specific concern in Bishopton related to contamination. Assurance is given that remediation measures will be satisfactorily regulated and carried out in accordance with Scottish Executive guidance. We consider this approach is not sufficient.

The assessment should recognise the scale of contamination is exceptional. Scottish Executive guidance in Planning Advice Note 33 on contaminated land states that effective policy making should be made on adequate and accurate information. Any survey preparatory to drawing up development plans should identify as far as possible the physical and chemical constraints on land in the plan area(paragraph 28).

Dealing with the issue of contamination at the planning application stage is insufficient given the previous use of the site and size of proposed development. Some understanding of the nature of site contamination and the extent and costs of remediation is required before any decision in principle is made. This is essential for public health and safety reasons and to be assured of the reasonable viability of the proposals.

The BAE Systems/CASS supporting report in the Consultative Draft Plan makes very limited reference to any details regarding contamination and remediation. The Consultative Draft makes no reference to the EnviroCentre report commissioned by Royal Ordnance Factory trade unions in 2001. This report was highly critical of earlier contamination studies undertaken by BAE Systems/CASS.

Strategic Overview

Paragraph 29 suggests the Strategic Assessment has highlighted where future urban expansion could raise concerns in terms of the broad principles set out in the Structure Plan. We would argue that the assessment has ignored many of the guiding principles of sustainable development in the Structure Plan. It has failed to ensure that there is sustainable use of existing infrastructure, education and community facilities in the choice of its expansion areas. It has failed to demonstrate that the development would reinforce and support the existing community. There has been no attempt to balance costs and benefits. Most significantly, the assessment fails to consider in any way the potential adverse impacts on both the existing and future community arising from the contaminated condition of Royal Ordnance and its remediation requirements.

- Paragraph 33 appears to ignore the key criteria of structural corridors, when it refers to sensitive wedges and landscape setting as being the most sensitive green belt areas. The failure to refer to the structural corridor of Bishopton - Bridge of Weir - Linwood ignores the important contribution it plays in preventing coalescence. We would argue that structural corridors should also be included in the "most sensitive Green Belt areas" category. We have previously referred to this matter in section B, above.

-Paragraph 34 states that The Consultative Draft Plan advocated an approach which recognised the need for new development to make timely provision of physical and social infrastructure through proper Master Planning. Particular consideration has been given to locations whose scale allows a more planned approach€. We would reiterate the comments made above in our response to the Draft Finalised Supplementary Written Statement. We consider that requirements for supporting infrastructure and services should be dealt with now to be consistent with the guiding principles for sustainable development in the Structure Plan 2000. In line with these principles, it would seem only common sense to have some idea of the availability and requirements for infrastructure, education and community facilities and of whom is to pay for it before establishing the principle of development. This has not been done.

Preferred Areas for Urban Expansion

In response to the concluding statement, made in respect of the identification of Bishopton as a preferred area for urban expansion, we would comment as follows:

- No acknowledgement is made to the fact that the site has a largely rural setting and cannot be considered an urban site.

- No reference is made to the location of the site within a structural corridor sensitive to urban coalescence.

- No reference is made to Scottish Natural Heritage's concerns that it is valuable as a reservoir for mammal and bird populations.

- The conclusion emphasises contamination and dereliction within the site, but no reference is made to its rural qualities and its landscape character.

- It is claimed that development will facilitate remediation. This is a very optimistic claim given the limited consideration which the assessment has given to this matter. The extent of contamination and its implications in terms of health and safety and the costs of remediation on project viability should all be determining factors, when making a decision about Bishopton as an area of urban expansion. There is no information on these matters in the planning assessment.

- It is claimed that development could also involve the provision of new and improved social facilities for the whole community. No explanation is given of what this might entail, how this might be achieved, the extent to which it would rely on the developer or the extent to which it is dependent on public sector investment.

- It is claimed access to the M8 will be significantly improved by a new junction to the M8. There is no commitment to this, or approval for this, from the Scottish Executive. However, the development is fully dependent on it. Without it, road access into Bishopton is similar to that of Houston and Bridge of Weir. Bishopton also shares the same road network pressure points as Erskine, since they are located under 1km apart. Houston, Bridge of Weir and Erskine have all been excluded from the list of preferred areas of urban expansion because of road network problems. We conclude that Bishopton should also be excluded as it has similar road network problems. If the proposed development took place at Bishopton, it would exacerbate existing road network problems for both Bishopton and Erskine.

- It is suggested that expansion could enable the creation of a green network and a Bishopton forest park. Without some idea of the extent of contamination of the site and how much of the existing woodland lies within contaminated areas, the practicality of such a proposal is vague. Much of the existing woodland has grown up over previously used land, possibly contaminated. To ensure safe public access, woodland areas would likely have to be removed as part of the remediation strategy. The BAE Systems/CASS report BR/04 suggests 270 hectares of woodland or grassland fall within this category. This would have a detrimental impact on the landscape and wildlife. The BAE Systems/CASS report also suggests 150 hectares of woodland may have the potential to remain, but this would require to be subject to a full assessment for contamination. The forest park is a superficially attractive proposal, but the reality of development will mean a significant destruction of existing woodland to the detriment of landscape character and wildlife. This would take many years if not decades to rectify.

- It is noted that the local shortfall in the Renfrewshire sub market, which it is claimed the development will contribute to meeting, amounts to only 200 houses (TR A/05). The proposed development exceeds shortfall by 2300 houses.

- No consideration has been given to industrial or retail potential. The BAE Systems/CASS report identifies 36 hectares of employment land and 5.7 hectares for commercial purposes. The need for this land and the implications for existing industrial land and retailing in the locality have not been addressed.

We request that the report on the Assessment of Potential Areas for Urban Expansion should provide further clarification and information on the above matters before any decision is taken regarding Bishopton as an area for urban expansion. We are of the view that the assessment of potential areas of urban expansion has been very limited in its scope. It fails to do justice to the concerns we have raised, which represent the majority view in the village. We cannot understand why these matters have not been considered before making a decision on urban expansion at Bishopton. In our view these matters are fundamental to any realistic assessment of potential.

B. ECONOMY

The following makes reference to the document titled "The Economic Case for the Sustained Growth Scenario in the Glasgow and Clyde Valley Area" revised report 20 August 2005, produced by Regional Forecasts, as is relevant to this round of consultation.

It is our opinion that the current Glasgow and Clyde Valley Structure Plan objectives for the maintenance of existing in-migration levels might not be sustainable for the following reasons: -

- It is detailed within the document (page 46) "risks to the forecast", that the report defines working age migration as that which is "estimated as a function of annual differences between Scotland and London"(page 23). It assumes that the relative differential in house prices between the two areas will be such that it becomes more cost effective to live in Scotland compared to the South East.

What the report fails to make clear is that despite the increase in relative house prices in the South East compared to Scotland during the 80s and 90s, there was a continued decrease in population in the Greater Glasgow area. While it is understood that this could be a function of relative unemployment rates, it calls into question the link between house price differentials and in-migration. Even when there was a house price adjustment in the early 90s in the South East, where many properties suffered negative equity, there remained a net decrease in population in the Greater Glasgow area (page 7).

- The following makes reference to the "Barker Review", a document instituted by the Office of the Deputy Prime Minister (ODPM) to report on affordable housing and detail policy recommendations on how this might be achieved. Barker Report at: -

www.hm-treasury.gov.uk/consultations_and_legislation/barker/consult_barker_index.cfm

This document states that, should its recommendations be approved, there will be an increase in house building in the South East. The laws of demand and supply suggest that this should result in the relative differentials in housing prices at least, not becoming any worse and it follows therefore, it will be more attractive to remain in the South East.

On page 36 of the Regional Forecasts report it states that a significant number of extra jobs (26,000) would have to be created to induce the required level of extra migration. It suggests that much of this will be achieved by inward investment, notably call centres. However, the scale of inward investment is way out of alignment with targets of Scottish Development International (1500-1800 high value jobs each year). There is insufficient detail on the policies required to create and grow indigenous business which would help to make up this shortfall.

It is our opinion that more work must be done in order to justify the claims made in the Regional Forecasts paper.

C. ENVIRONMENTAL

We reaffirm our consistent and vigorous stand that, in accordance with PAN 33 and your own Strategic Policy 2, you are failing in your duty to ensure that the land is suitable for development. These aforementioned articles strongly suggest that, even at a strategic level, you should be assimilating the very best of information and acting upon it.

It would be irresponsible in the extreme to commence any form of development before a benefit-to-risk ratio in the assessment of the health of our community, and that of any future residents/community, has been thoroughly and appropriately investigated and found to be positive unequivocally.

The elements of such risk fall into two major categories as a minimum: -

Static - that is the risk from contamination as it exists (both locally and in potentially remote areas by transportation) without disturbance of the site.
Dynamic - the risk incurred by disturbance of the site during attempted decontamination and/or development.

A senior representative of BAE Systems, namely Mr G Vincent, has admitted in public (Bishopton Community Council Meeting, 3 May 2005, transcript at Annex A) that they do not have a complete inventory of all the potential toxicants (chemical and biological) which have been utilised, produced (advertently or inadvertently) or stored at the site since it was commissioned. Similarly, the same representative has admitted that they do not have a complete inventory of the sites for storage of such potential toxicants, the measures taken for their containment nor how effective/non-effective these measures have been, both locally and in more remote areas, since the site was commissioned. Therefore, in this context, the representative's statement, in public, that BAE Systems have a full understanding of the biological half-lives of all the potential toxicants is illogical.

Given this situation, it is impossible to know which potential toxicants to look for or where to look for them. From this it follows that it is then impossible to generate meaningful data to allow a realistic assessment of benefit-to-risk which will even remotely guarantee the protection of the health of our community or that of any future residents/community. Annex A has been included for your information, so that you may apply the relevance of its contents in accordance with PAN 33 and thus assimilate the very best of information before you make your recommends.

At another Bishopton Community Council organised meeting (21 June 2005) a senior representative from SEPA (Caroline Thornton) stated confidently, in response to a question from the floor, that SEPA was protecting public health by monitoring water supplies at, or emanating from, the ROF site. In response to a question from the floor concerning precisely what was being monitored by SEPA, the response was "phosphorus (which is chemically impossible and should have been phosphates), nitrates and oxygen burden". It was pointed out from the floor that these constitute part of the profile of farmyard chemicals and have nothing whatsoever to do with potential toxicants resulting from activities at the ROF during some 80 years or so. What does this do for the scientific credibility of presentations specifically designed to win over the community and gain support for the development of the ROF site? Such a statement from a representative of our national body for the protection of the environment may reassure the layperson but in scientific terms it is absolutely ludicrous. Moreover, SEPA's remit can only be related to superficial contaminants which leach readily into the surface water. This ignores potential deeper contaminants which will be exposed during any reclamation and building work.

During the 80 years or so from its commissioning to cessation of its activities, the Royal Ordnance Factory at Bishopton received/handled/produced/disposed of a wide range of very toxic chemicals. These included explosives and the substances used to make them, the wide variety of materials used in pyrotechnics (barium, nickel, chromium, cadmium etc), highly toxic industrial solvents (such as benzene and chlorinated hydrocarbons), possibly radioactives (such as materials used in luminous paint or in depleted uranium projectiles), asbestos, etc. Further hazard to public health arises from combustion products (such as dioxins, furans and polychlorinatedbiphenyls (PCBs)) resulting from disposal operations.

This is just another indicator (to add to all the others, including the thousands of letters from residents in Bishopton and elsewhere protesting against this development) of how low the confidence is of our community in your proposals right now. Far from convincing the community, it is apparent that your credibility has fallen drastically since you started to engage with us. The community and its representatives have always been proactive in seeking realistic and credible answers to alleviate our concerns; we have expected reassurance but instead our concerns have been exacerbated. We look to you now to gather your information carefully before you make any rash judgements.

At a meeting between Bishopton Action Group, GCVSP Team and Renfrewshire Council Planning Department (27 September 2005), Mr Sowersby stated that there were "silent killers" beneath much of the ground within the site. He also explained that, due to the Official Secrets Act, there was considerable current reluctance on the part of many individuals to speak in public of their first-hand experience and factual knowledge concerning what went on within the site over many years. Can you take the risk of causing your proposals to be implemented knowing what you know or, potentially much worse, from a practical and moral standpoint, what you don't know? In this context, it is imperative that an appropriately realistic survey be made in order to detect any potential risks before any rational planning is possible.

Developers and landowners have been, and always will be, money-orientated in this respect. However, when they move on and leave our community to take the consequences (severe, even life-threatening events) in the years to come, who will take responsibility for your actions? Will you - yes or no? If no, who will you nominate to do so? Your procedures are diametrically opposed to the logic and science of the protection of public health. In the event of failure, such procedures should always "fail safe" but BAE Systems/Redrow are driving an unsafe situation. In including Bishopton in the Plan, you give the green light for development and thus the disturbance of contaminated land. Your procedures inherently "fail to danger". During 2005, the press has reported on numerous such incidents in the UK. Do you propose to leave another such legacy in Bishopton? In this context it is imperative for you, or your representatives, to inform our community (and potential future residents) of any legal implications of such failure, together with the avenues which are available to present and future residents to seek redress for the liability caused to them. Each of the public health catastrophes (both local and far-reaching) caused by events such as Chernobyl, Bhopal and the recent huge escapement of benzene from Harbin (which subsequently entered Russia via the River Heilongjiang) was characterised by the same official response namely, denial and abrogation of responsibility.

We have, within and outside our community, unpaid and unbiased scientific experts who have no personal or non-personal interests (either specific or non-specific) in the development of the ROF site. Their only concern is the protection of the right of our community to its continued well-being. It is your duty and ours to protect the community's health.

Therefore, there must be transparent and open discussions in both the scientific agenda (with particular reference to the paragraphs above and to the fifteen issues raised by Tony Sowersby with Mr Vincent and Ms McKay on 3 MAY 2005) and the spectrum of representatives from interested bodies, BEFORE any alteration to the Structure Plan is approved. This is the very least that is required in order to commence reassuring the local community.

So far you have been unsuccessful in alleviating the widespread and intense conviction in the community that these plans are being railroaded through the planning process with undue haste, despite the overwhelming opposition and fears for the health and safety of our residents which exists. At this time it is utterly inappropriate, on public health grounds alone, to list the rural area of Bishopton as an "Area for Urban Expansion".

To conclude, there are many wide ranging factors that cause our community grave concern and call into question the sustainability of such proposals, not to mention the impact upon our community's health and safety and quality of life. It is therefore imperative that you take cognisance of such representations, prior to proceeding any further with this process, which considers Bishopton for inclusion within the Structure Plan as an "Area of Urban Expansion/Community Growth".

Yours sincerely

Stewart Ferguson Anthony B Sowersby

Chairman Vice-Chairman

On Behalf of Bishopton Action Group On Behalf of Bishopton Action Group

Annex A

Below is a transcript of questions posed by MR T SOWERSBY and responded to by BAe representatives, MR G VINCENT, Project Manager and MS A MCKAY, Environmental Manager. This session followed a BAe presentation organised by the Bishopton Community Council on Tuesday, 3 May 2005

T Sowersby	-	My name is Tony Sowersby and I am a very concerned resident of Bishopton. My concerns are for the long term health affects of the Bishopton people. My major concern is for your ability to effectively deal with the horrendous cocktail of chemicals that's resident in your site and I genuinely fear for public safety. So if you don't mind a couple of questions. Do you at this present time have a full audit, both type and quantity, of the chemical and biological hazards throughout the functional history of the site? And I'm just looking for a yes or no please.
G Vincent	-	We have a desk study which gives us a hell of a lot of information. We have this process which we may embark upon, site investigation process, to back up what we understand from the desk study information, and we work out our remediation strategy from that.
T Sowersby	-	Do you have full audit then?
G Vincent	-	No, we don't have a full audit, not at this moment in time we don't.
T Sowersby	-	How many uncontrolled incidents have there been during the operation of the site, and do you have a full audit, for the uncontrolled incidents again both type and quantity, of the various chemicals and biological agents in the case of such incidents? Just a yes or no.
G Vincent	-	Pass.
T Sowersby	-	You don't know?
G Vincent	-	Pass.
T Sowersby	-	So you don't know then?
G Vincent	-	No.
T Sowersby	-	There are contaminated waste dumps within the site. Is there a full audit mapping of all these sites, their location, the nature of the materials contained and the effectiveness of the present containment?
G Vincent	-	There's a tentative mapping already created subject to further site investigation.
T Sowersby	-	Nothing full and complete then?
G Vincent	-	Not yet.
T Sowersby	-	Do you assure us that you have a full understanding of the toxicities, both human and animal, and biological half-lives of all the chemical and biological materials involved? Everything? Yes or no?
G Vincent	-	Yes
T Sowersby	-	You have a full understanding?
G Vincent	-	We have expertise that has an understanding yes.
T Sowersby	-	A full understanding of everything involved?
G Vincent	-	Yes
T Sowersby	-	Thank you. Now many of the chemical contaminants within your site are extremely toxic; carcinogens, mutegens and as detailed from the relevant correspondence, limited to what I've seen. Will you conduct a full and complete analysis for all of the chemical and biological materials in all of the soil samples, taken according to the very best statistical acceptable sample procedures?
G Vincent	-	Yes.
T Sowersby	-	And you do realise that by carrying out by the best possible means that that will have huge, phenomenal financial implications on yourselves?
G Vincent	-	Yes. Phenomenal.
T Sowersby	-	You do realise that?
A McKay	-	Yes
T Sowersby	-	Ok well that raises a deep seated concern within myself that the amount of money involved, and because you are a political and, more importantly, resource led organisation, that in order to minimise your costs the risk assessment process will infact be flawed.
G Vincent	-	The risk assessment process will be undertaken under current guidance and best practice. That's all I can tell you. That's the way it will be done and we will demonstrate that by communicating that to your good selves in time as the information becomes available through the correct route.
T Sowersby	-	Thank you. Will a portion of each sample taken then be made available for independent analysis by truly independent experts? Yes or no please.
G Vincent-	-	We could by special arrangement do that but funding for that would have to be by a third party.
T Sowersby	-	Ok, so you would do it?
G Vincent	-	We would. If we were requested to provide additional samples from the samples that we take then yes we would provide it but I would warn you it's only done via analysis of soils. On a site like this they would need to demonstrate to us the Health and Safety - that they are completely aware of the Health & Safety aspects we use.
T Sowersby	-	Thank you.
G Vincent	-	There are severe implications in doing that.
T Sowersby	-	Will the identities of the contracted laboratories that you use, the analytes to be investigated, the methods to be used and the raw data generated, be made available for independent assessment?
A McKay	-	Yes.
G Vincent	-	Yes.
A McKay	-	They will be made available.
T Sowersby	-	You will make your raw data available?
A McKay	-	Oh yeah we are embarked in that anyway.
T Sowersby	-	Do you consider the Bishopton site unique with regard to risk benefit and hazard please?
G Vincent	-	No.
A McKay	-	No.
T Sowersby	-	You don't? So what other sites are there up and down the country?
G Vincent	-	Other sites that we've been involved in whereby we can demonstrate the level of knowledge and expertise are two sites in Essex and there's one site in Lancashire. Both have been through this process and both the Essex sites are now developed. The Lancashire site is now half way through the redevelopment phase, the remediation phase is finished and we've had regulatories on board ever since we started and we don't have any problems.
T Sowersby	-	And can we have access to that raw data and the information please? Not a watered down assessment in any way, but the raw data?
G Vincent	-	I will take that away and come back on that. I can't answer that question right now.
A McKay	-	It should be in the public domain. It would have been part of the planning application put through.
G Vincent	-	You probably can make applications to those Planning Authorities and get it.
T Sowersby	-	Who has the raw data then from those sites, was it yourselves that were involved?
A McKay	-	Yes.
G Vincent	-	Yes
T Sowersby	-	You were involved so you've got some raw data?
G Vincent	-	You would need to make applications to those councils. We can give you that information.
T Sowersby	-	Thank you I appreciate that. I'm nearly finished. Will you implement a sampling procedure, which is scientifically and statistically appropriate, for both soil and water, both ground water on the site and running water adjacent to the site?
G Vincent	-	Yes.
T Sowersby	-	You will implement such a procedure. Will you provide details of the proposed sampling programme in detail so that it can be subject to public scrutiny?
G Vincent	-	Yes, through the proper channels.
T Sowersby	-	You will do that?
G Vincent	-	Yes.
T Sowersby	-	What channels will you use to do that?
G Vincent	-	Well, we won't directly provide information to individuals - in this situation we will direct information through a body.
T Sowersby	-	Who are that body?
G Vincent	-	Well, we are hoping to engage the community liaison.
T Sowersby	-	So you will use the Community Liaison Group?
G Vincent	-	That will be the vehicle for two-way communication between ourselves and the community.
T Sowersby	-	So say for instance, I required, I act alone, the raw data, I would approach the Community Liaison Group?
G Vincent	-	And make a request through them.
T Sowersby	-	Make a request through them and that should be forthcoming is what you're saying. You'd see no reason not to?
G Vincent	-	Yes. If there's no reason for us to release information then the information won't be released. If we had an issue with releasing information then we'll tell you why and what that issue is and then we'll work on things to try and find a way round it.
T Sowersby	-	That would be agreeable. In the event that the site is developed and subsequently there are adverse effects within the community, who, with regard to public health, which public office will be held publicly accountable?
G Vincent	-	Which public office?
T Sowersby	-	Can you plan if all this goes to a ball of chalk - who?
G Vincent	-	The perpetrator of the problem, the originator of the problem will be the person who's accountable.
T Sowersby	-	Who is that?
G Vincent	-	which will either be us as the remediation contractor, us as the land contamination assessment expert or us as the landowner or whoever. If we are the perpetrator then we become accountable. If it's a contractor working for us they will become accountable - though that might lead back to us.
T Sowersby	-	I would expect it would.
G Vincent	-	A public body would become accountable if they were negligent in conducting what they are supposed to do. The public body.
T Sowersby	-	Which office though, within your own organisation then? I am not asking you to comment on the Council now. Which office in your organisation would be accountable for anything that went wrong on that site?
G Vincent	-	It would go to the Board. It would be the Director of the Business Unit responsible for whatever the works were, where the problem was.
T Sowersby	-	Thank you. I appreciate my time to ask questions. Thank you very much for that. A point to highlight at this time is that although samples will be taken, it is fundamental for BAe to know: what they are testing for within the samples; and the exact location of where they expect to find it. IN SHORT, IF YOU DON'T KNOW WHAT YOU ARE LOOKING FOR YOU CANNOT FIND IT. SIMILARLY, IF YOU DON'T KNOW WHERE TO LOOK YOU CANNOT FIND IT.