Bishopton Action Group

LETTER OF OBJECTION TO THE ALTERATION TO THE STRUCTURE PLAN

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 the Bishopton Action Group (BAG), we wish to give our views and objections to the Draft Structure Plan 2005. BAG is a large group of Bishopton residents who formed following the presentation by BAE/Redrow in February this year. There are many concerns and fears for the future of our village. There has been a distinct absence of information and consultation with our community over any proposed development of the ROF site.

We object strongly to the proposed alteration to the Structure Plan, and to the proposed inclusion of Bishopton in Schedule 1c "Established Urban Expansion Areas". We believe that the proposals contradict the guiding principles of sustainable development laid out in the Structure Plan for the reasons below.

Strategic Policy 9 of the 2000 Plan (Page 86) states that the location of a development should "avoid negative impact upon Health and Safety". There are real fears that this development will pose major risks to the health and safety of the local community. The 2000 Plan states that "a substantial portion of the site is currently vacant and derelict, with parts suffering from significant contamination". This is obvious from the fact that the site has produced explosives and munitions for a period of over 80 years, and that there are many substances and chemicals present on the site that will pose a threat to humans and the ecosystem should pathways become established. The EnviroCentre Report of August 2001 states that the ROF site has "significant possibility of creating significant harm to receptors, as defined in Part IIA of the Environmental Protection Act (EPA) 1990." As you are aware, there are houses currently located up to the boundary of the site with a significant population within a short distance. It is feared that the intrusive nature of the remediation works necessary to make the land "fit for purpose" will involve significant risk to Bishopton residents, especially from the release of airborne contaminants. The developers have failed spectacularly to dispel these fears.

BAG has pro-actively attempted to obtain pollution records from BAE. To date, nothing has been forthcoming. In open forum (Bishopton Community Council Meeting 3/5/05) a series of questions were asked of BAE specifically targeted at gleaning more information regarding contamination. It soon became apparent that any risk assessment carried out would, and could only ever, be flawed. The reason being that simply too many undocumented unknowns have happened over the many years. Anecdotal evidence can only provide so much, and up until now would appear to have been selectively taken. The site risk assessment should provide the basis for all further risk to benefit calculations. The site risk assessment is critical to public health and safety.

Since February there has been an overwhelming groundswell of public opinion against the proposals. BAE have indicated that a full site investigation and risk assessment will only be attempted after outline planning permission has been granted. Why do the local authorities wish to alter the Structure Plan to allow the building of 2,300 houses and a large industrial development on a site where the risks have not been fully explored, identified, and made available to the people who will be affected by it? The residents of Bishopton have every right to demand that the finest scientific techniques available to date are employed to safeguard their health. There is absolutely no substitute for hard scientific evidence gathered from the scene. Comparisons of other sites, to make a lottery of assumptions regarding the ROF site risk, will not suffice. It cannot be stressed strongly enough that the potential for disaster looms should things be managed in an incorrect manner. These issues must be fully addressed before the principle of strategic development is even established within the Plan. We contend that, in the light of the fears that exist within our community and the unanswered questions on how to protect the health and safety of our residents, it is inappropriate to designate Bishopton as an Urban Expansion Area.

In addition, BAE have indicated that the decontamination will be on a phased basis, with partial remediation and revenue from house sales utilised to fund further phases of the decontamination process. This surely poses an unacceptable degree of unnecessary risk not only to existing Bishopton residents, but also to new homeowners who will be living in close proximity to the extensive and potentially dangerous remediation processes. Are the local authorities prepared to accept legal responsibility for the health and safety of a population exposed to this high level of risk?

Renfrewshire Council has a statutory responsibility under the Environment Protection Act to "inspect its area in order to identify contaminated land and to designate special sites". The Council has not yet in fact designated the site as contaminated land despite the fact that the factory gates have, in essence, been locked for over 4 years. It is accepted by all members of the Bishopton Community Liaison Group (CLG, meeting 19/5/05) that Renfrewshire Council are a vested interest party due to, in part, the revenue they will obtain from thousands of new dwellings. Therefore, because the land is not a "special site" Renfrewshire Council is not required to enforce appropriate remediation. This state of affairs is indefensible and extremely unacceptable. It means that there is no truly independent body to ensure that remediation is monitored and controlled to the requisite standards of safety, without profitability and future gain being an influencing factor. Throughout Background Report 4/05 it is stressed that the development must be of such a large scale to fund the remediation of the site. This heavy emphasis on profitability as the key driver is alarming. It does nothing to dispel the mood amongst residents that the remediation operation is based on commercial imperatives rather than an identified need to make the land safe and protect the health and wellbeing of the community. It is on this basis that we argue that the planning method of dealing with contaminated land is inappropriate.

It also needs to be pointed out that all the information relating to Bishopton in the Draft Plan 2005 is contained in Background Report 4/05. This has been obtained from only one source i.e. the CASS report prepared on behalf of BAE. The original CASS report has simply been reproduced with a different cover, as a technical background report, Appendix to the Structure Plan, and is now presented as an independent proven statement of need. It is infact the aspirations of a profit-driven enterprise. We argue that the report, written by CASS Associates, represents the opinions of a group with a vested interest in the ROF development. It is therefore not objective and does not satisfy the requirement for an independent and unbiased assessment of future planning and development priorities for our area.

The 2000 Plan (Page 16) states that new developments should be located "where they will reinforce and support existing communities" and should be "without unacceptable adverse impacts upon the physical identity or quality of life" of existing settlements. The Draft 2005 Plan (Page 2) also mentions "strengthening communities".

We argue that the scale of this new development is not commensurate with the size of the existing village and population. Bishopton already has a strong physical identity and is a distinct community in its own right. The majority of people who live here have made a conscious decision to reside in a fairly small, close-knit community in a pleasant rural area, with the way of life and resulting benefits that this brings. They did not elect to live in a new town. The plans by BAE and Redrow to build a massive development comprising 2,300 houses and commercial premises, effectively doubling the population, will swamp the village and totally destroy its character and our existing community spirit. The strength of feeling against the proposals was shown by the recent referendum organised by the Community Council in which a massive 92% of the voters said "NO" to the new development. The referendum was organised in response to the unveiling of proposed plans by BAE in February. Prior to this date, no consultation had been given to the Bishopton Community Council (BCC letter to yourselves dated 3/6/05 Ref: BCC-IM48) or the wider resident population. The consultation that was offered in February by BAE was mainly in the form of a set of questions with boxed answers to choose from.  Without exception, all salient questions were loaded in favour of BAE's preferred course of action. It is the feeling of the residents that this one and only consultation was both insulting and demeaning. BAE continue to present the statistics of the exercise in a self-favourable light implying that the Bishopton people, in some way, desire a development of this magnitude. We will argue vehemently that this is absolutely not true.

Furthermore, it will create a new town which is physically divided in two by an elevated railway line, and a resultant "them and us" situation is inevitable. There will be little cohesion or integration, with two polarised communities of the "old" and the "new" Bishopton, and social problems will be created. Residents are also afraid that once the principle of house development is established and the proposed business and industrial units are not taken up, there will be even more houses built on the site than the current figures suggest. The people of Bishopton do not want this development because they believe it will most certainly have an "adverse effect" upon the character, identity and quality of life of their community. How can this not be the case?

The 2000 Plan (Page 3) states that its goal is to support and promote sustainable development by "promoting urban renewal and regeneration in preference to further urban expansion". We would argue that the creation of this new town and business premises is urban expansion and furthermore that it is not necessary. This is supported by the view of the Scottish Executive's Reporter into Renfrewshire's five year Local Plan, who stated in his conclusions that "there is no need - neither immediate nor in the longer term - for a new tranche of industrial or residential land to be introduced to the plan area". BAE and Redrow have mentioned a business park and the creation of 4,000 new jobs. This is purely a hypothetical calculation and since there are empty industrial units at Inchinnan, Erskine, Linwood, Hillington, Port Glasgow and Greenock, there is no evidence to suggest that there is any requirement for additional business and commercial land to be created. At a time when international investment in manufacturing is on the wane, with some companies in fact pulling out of Scotland, and given the expectation that demand for commercial land will fall over the next 5-10 years, we contend that you are creating a supply of land at a time when it is blatantly not needed. It would be more beneficial to concentrate on promoting and regenerating existing business areas as stated in the Plan instead of creating a "white elephant" under the guise of a business park at Bishopton.

A major principle of sustainable development contained in both the 2000 and Draft 2005 Plans is that new developments do not create hidden costs or problems for future generations. The Draft 2005 Plan (Page 14) states: "Opportunities will be sought to enhance existing communities and not merely take advantage of the services and amenities that they offer" and "new developments will be required to make timely provision of physical and social infrastructure through master planning". BAE's proposals fail to meet these criteria. It is quite obvious from the vague statements and lack of detail in Background Report 4/05 that the developers will build houses first to generate revenue, and take advantage of the infrastructure that exists within Bishopton at present. The developers have indicated that a new primary school could be built. We would argue that this would be an absolute requirement. However, no reference has been made to a new secondary school, which again would be absolutely necessary, given the increase in the school population that will result from the new town. Since the existing secondary school at Park Mains will be full to capacity, we would like you to clarify what extra provision will be made for Bishopton pupils of secondary school age. Is it the plan to transport pupils out to other areas such as Port Glasgow or Renfrew? Is there any guarantee that "old" Bishopton will remain in the designated catchment area for Park Mains School? In addition, we understand that there are no plans to build a new railway station to accommodate the massive increase in the population. It is quite obvious that the existing service and facilities at the station are already inadequate, especially at peak travelling times. Can you confirm what provision will be made to address the problems of congestion and overcrowding of the rail network? There is also the issue of road congestion, which will create future problems. The roads surrounding our area are already congested with the majority of the adult population travelling to work elsewhere each day. The new development will require an upgrading of main sewers, water, gas and electricity mains, with resultant road works and traffic disruption over an extended period of time. Our existing infrastructure is already stretched to breaking point, and will be unable to support this huge increase in the population, even for an interim period until new facilities are built to provide for the new community. For all these reasons, these proposals will have a negative impact and adverse effect upon the quality of life of Bishopton residents.

The 2000 Structure Plan (Page 33) describes the ROF site as follows: "Although parts of the site are currently or were formerly in industrial use, it has a largely rural setting and cannot be considered to be an urban site". The planners are now attempting to redefine this "largely rural setting" into an urban expansion area and this surely goes against the key aims and themes of the Structure Plan. Furthermore, the developers have indicated that houses will be built on the least contaminated parts of the site i.e. the green areas, and it is suspected that some of the very badly contaminated areas will be left. This is an unacceptable option, and we would argue that full site remediation is required. It is our belief also that Bishopton and the neighbouring town of Erskine have met more than their fair share of greenbelt release over the past years, and that this green land should not be released for further housing development. As much of the site is essentially green in nature, we request that all these areas be left as is. Housing and commercial development should not be allowed to exceed the existing blueprint i.e. only the land formerly covered by built development should be allocated for new building use only if a Benefit to Risk analysis determines that it is safe to do so.

For the past 80 years the Royal Ordnance factory has existed within our community, and our residents have lived with the potential dangers and risks associated with the production of munitions and explosives during two world wars. There have been accidents and lost lives during this period and many local people were made redundant as a result of the factory run down and eventual closure. We have proved as a village that we can be welcoming and forward-looking, and in the past have embraced smaller scale housing development. It would be a deserved reward to Bishopton residents if the land could now be remediated and given back to the people as a nature park, thus preserving the many species of wildlife that exists there. Instead we are now required to suffer major inconvenience and disruption to our lives during a 15-year period while this massive new town development is built on our doorstep. Even worse, we feel that our future health and safety is in the hands of the site owners who bought the land for a nominal sum and now seek to make profits from house sales in order to fund an 'adequate only' remediation process. Our view is reflected in the following statement from the Scottish Executive's Reporter into Renfrewshire's 5-year Local Plan: "I consider that there are substantial grounds for requiring the restoration of the land to its original condition, now that it is no longer needed for its stated purpose. The planning authority has the legislation on its side to enable it to achieve this. Undoubtedly, it is a considerable liability that rests with its current owners and I consider it to be unsurprising that they are investigating ways of capitalising on the obvious potential of the site to offset such costs." The reporter also went on to say, "I am in no doubt that there would be vigorous opposition to the use, and the potential overloading, of facilities or infrastructure currently used by the existing community." The Bishopton Action Group would agree with the reporter.

To sum up:

There must, therefore, be transparent and open discussions BEFORE any alteration to the Structure Plan is approved. This is in order to reassure the local community who feel 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 that exists. At this time it is inappropriate to list the rural area of Bishopton as an 'Area for Urban Expansion'.

We would wish to be kept informed of all future stages in the preparation of the Alteration of the Joint Structure Plan 2000.

Yours sincerely