ROF Masterplan, Planning Application 06/0602/PP

You can read below the full text of my representation to Renfrewshire Council in respect of the above planning application.

Dear Mr Darracott

ROF Masterplan, Bishopton

Outline Planning Application, Reference No 06/0602/PP

I wish to make representation on the development proposals for ROF Bishopton on behalf of Bishopton residents. Notwithstanding the detail of the comments described below you should know that all Bishopton is discomfited with the development proposals and the overwhelming majority of residents are opposed to the plans. All recent Bishopton-wide consultations consistently reinforce this.

I have referenced comments made to me to the planning documentation submitted to the Council in May 2006 from Cass Associates.

1. Masterplan Statement

a. Section 2.2, p2 describes "...the need to integrate the existing community with the new development…" This statement is not accepted – Bishopton clearly expresses a desire that any new development be built at Georgetown, separate from Bishopton.

b. Section 3.11, p6 welcomes the aspiration to develop waterfront facilities for public access.

c. Sections 3.8, p5 describes Station Road as a primary point of arrival. This is unacceptable. Primary points of arrival must be directed into any new development from the new link roads proposed elsewhere. Traffic must not be encouraged to access the site from Station Road.

d. Section 3.24, p8 acknowledges that the connectivity between Bishopton and the ROF site should not undermine Bishopton’s current state. The proposed links at Station Road, Rossland Crescent and Newton Road will place an intolerable burden on residents who enjoy their homes in quiet cul-de-sacs. These linkage proposals must not proceed.

e. Section 3.26, p8 proposes local traffic journeys through Station Road, Rossland Crescent and Newton Road. This is unacceptable.

f. Section 4.3, p10 discusses remediation and land reclamation. Bishopton is concerned that proposals must be described in greater detail and that appropriate regulation and monitoring is in place.

2. Public Consultation Statement

This document is widely discredited. It is felt that much of the attributed comment within is selectively presented to favour the developer’s aspirations. As a member of one of the participating focus groups and noting the comments attributed to that group, I agree with that sentiment.

a. Question3, p13 "Were you aware that regeneration of the site has been given a high priority by the Scottish Executive, Renfrewshire Council, Scottish Enterprise & Bishopton Community Council?"

It is misleading to include the Community Council in this comment since their participating representative in historical consultations was prevented from discussing meeting findings in public.

This is typical of the selective representation and comment found throughout this document.

b. Question 7, p15 fails to recognise the recurring requests for affordable housing and down-size retirement properties from the existing community.

c. Question 12, Other, p18 acknowledges the desire for open woodland access and the introduction of foot- and cycle-path networks to Bishopton.

d. Focus Group One, p24 claims that "...Bishopton was losing the feeling of being a village." There is no evidence to support that opinion. The quotation at top of page 25 contradicts the statement.

e. New facilities, p32 Bishopton did not ask for a "larger police station". The statement implies falsely that such a facility exists at present. What Bishopton asks for is a Bishopton police station.

f. Key Issues, p38 comments "The group was positive about the proposed re-opening of the M8 junction as they felt in some ways the existing village was stagnating." What is the link between a proposed M8 junction and the revival of Bishopton as it exists?

g. Transportation, p40 appears to imply at paragraph 5 that a road bridge may be built at the sports field. This would be an unacceptable intrusion to the long-standing and current "village green" use of the sports field.

h. Summary of findings, p41i. An extended health centre is universally agreed.
ii. Transport infrastructure must be in place before housing is released for sale.
iii. The Newton Road access agreement was for very local access, only after the main ring-roads on new site were in place.
iv. Gladstone Hill must be retained as open space.

i. The Response, p44i. Item 33 agrees that public transport should be improved. There is a strong and unmet demand for direct bus services to Renfrew, Braehead, Paisley and Port Glasgow/Greenock.
ii. Item 40 agrees with the Newton Road access. This was for very local access only and not as a primary route prior to the completion of phase 1 proposals.

j. Conclusions, p51 states the consultation has been long and involved. This is strongly disputed. The developers failed to engage with Bishopton and only disclosed their true intentions at the exhibition of February 2005. Any discussions prior to that date cannot be considered as ‘consultation’.

3. Public Transport Strategy

a. Section 2.16, p4 fails to recognise that peak rail services are already full. There is an unmet and present demand for additional rail cars on existing services.

b. Section 2.17, p5 refers to overflow parking by train users to adjoining streets. Developers claim that it has been difficult to distinguish between park and ride parking and local resident parking. This is ridiculous. If developers had asked the local community they would have been told that typically fewer than six cars represent local residents, the entire remainder being park and ride parking.

Such failure to engage with local residents at a micro-level is absolutely typical of the proposals under consideration.

c. Section 2.25, p6 describes a morning and evening Arriva peak period bus service 23. Bishopton disputes this is a peak period service at 07:15 a.m. The published Arriva timetable has no evening peak period return service as claimed.

d. Section 2.27, p6 describes the Marbill service 55 between Beith, Paisley, Erskine and Bishopton. This is not a public bus service but the school contract for pupils attending Park Mains High School, Erskine.

One questions the competence of professionals who make claims in their documentation implying such a service is a public service.

e. Section 2.32, p6 acknowledges the generally poor level of accessibility to and from Bishopton by bus. Bishopton has been poorly served by bus services for many years. Even without any new-build on the ROF site Bishopton deserves far better bus services.

f. Section 2.36, p8 describes that only 2% of all commuter journeys from Bishopton are by bus. It must be clarified that this low percentage is a reflection of the poor service provision and most certainly not poor patronage of existing bus services.

g. Section 2.38, p9 acknowledges the limited range of bus commuter destinations. Current bus service provision must be improved.

h. Section 3.43, p23 claims that bus links westward from Bishopton "would only duplicate the faster service available by rail." This fails to recognise the Scotland-wide free bus service provision for older and disabled people who are disenfranchised by the absence of choice in Bishopton. It is not just about destinations but also the preferred mode of transport.

i. Section 4.8, p29 describes "...very little travel by bus between Bishopton, Braehead and Renfrew." As in previous comments, this is a consequence of poor service provision. You will know that I have made frequent requests to your offices for more bus services to and from Bishopton.

j. Section 4.22, p31 recognises that the Arriva bus service 27 should be reinstated. This is welcomed and endorsed.

4. Transport Assessment

a. Section 2.6, p8 describes a taxi rank. This is not widely recognised locally whilst accepting that Bishopton rail station is a common taxi pick-up point.

b. Section 2.7, p8 implies that increased rail rolling stock has resulted in all peak hour services at Bishopton being increased to 6 carriages. This is not so, the only regular (but not always) 6 carriage peak hour service being the Bishopton 8:08 a.m. to Glasgow.Other services are regularly crowded with standing-room only. This is particularly prevalent during university and college term-time.

c. Section 2.15, p10 describes the Marbill 55 bus service. As noted above, this is the school contract service and so has no relevance to wider transport discussions affecting Bishopton residents.

d. Section 2.16, p10 describes a "...Shuttle Bus service known as the ‘Train Taxi’ …SPT have indicated this service has been very successful." This service was withdrawn in May 2004! There has been no similar shuttle service provision since.

e. Section 5.37, p38 appears to contradict statements elsewhere seeking to justify the use of Rossland Crescent and Newton Road as access routes to any new development. Additionally, Bishopton questions how Station Road can accommodate more parking and passing places?

Is Station Road to be converted to a single track route? Where will queuing traffic sit? What effect will the plans for Station Road have on business outlets at that address?

5. Environmental Statement – Non Technical Summary

a. Section 3.10, p2 fails to acknowledge the unacceptable congestion in Station Road at present. You will recall my persistent representation to you over many years seeking a solution to the parking and congestion problems at this location.

b. Section 3.15, p3 describes "around 2,500 units." Has Renfrewshire Council accepted this figure – an increase from the oft-quoted figure of 2,300 new homes?

c. Section 3.19, p3 claims that any new development will provide choice in the mode of travel by local people. Whilst the mode of travel is important, one must also consider the choice of route available. Offering a bus route to Erskine is not sufficient. The wider areas of e.g. Bridge of Weir, Houston, Port Glasgow and Renfrew must be offered.

d. Section 3.21 (6), p4 comments on the upgrade of bus services. Figure 3.6 suggests this will happen in Phase 3 of development proposals. Bishopton expects bus services to be enhanced long before then, recognising a current demand for improvements.

e. Section 8.2, p12 is not accepted. The use of Station Road, Rossland Crescent and Newton Road to access phase 1 prior to the construction of new access roads represents the revocation of a previous commitment and is universally condemned.

You should understand that Bishopton is united in its condemnation of this proposal and will not accept its implementation.

f. Section 10.4, p14 discusses noise levels associated with traffic arising from new development. If noise levels may exceed guidance, why will noise abatement action not be required?

6. Foul Water Drainage Strategy

There is widespread concern that any new foul water drainage facility might be installed under Station Road. Bishopton believes the resultant disruption and traffic congestion would be chaotic. If new infrastructure is required to access Erskine Water Treatment Works then the route of least disruption, at Barrangary, should be chosen.

7. General

a. School Provision

Statistical arguments supporting a new primary school but not a secondary school are not agreed. Bishopton is concerned that Renfrewshire Council does not appear to have grasped the scale of the proposed development and may have underestimated the school role projections. I have received several comments supporting an educational community campus facility providing facilities to school children by day and the wider community by evening.

b. Decontamination and Remediation

Bishopton is concerned with many aspects of these proposals. Further detail must be available to the community. The regulation and monitoring regimes should be explained in greater detail so that Bishopton may form a considered opinion of these matters.

c. Commercial Development Sites

What guarantees are in place that the proposed commercial plates will not be converted to housing at a later date should the proposed commercial opportunities not be realised?

d. Implications of Construction

What controls and regulations are available to ensure effective protection of the existing community whilst construction of the new development continues for 12 years?

The prevailing wind in Bishopton is westerly and will bring noise and dust pollution into the existing community.

Conclusion

The development proposals currently before you present one of the most contentious issues facing Bishopton for a generation. The residents of Bishopton look to your office to protect our homes and environment. It is imperative that the community is involved in future discussions relating to ROF Bishopton planning applications and you are encouraged to continue your present "open-dialogue" with our community.

On behalf of Bishopton, I will be pleased to discuss matters arising from this correspondence with you. The level of detail in representations to you sends the strongest possible message that Bishopton is not satisfied that these proposals have been researched properly and that many of the statements in the Cass Associates documents are inaccurate and cannot be substantiated.

I look forward to receiving your acknowledgement and further comment in due course.

Yours sincerely

Cllr Iain Langlands

______________________________________________________________________

7. General

ROF Bishopton - Exhibition 3/4 May 2006

So - what did you think of the revised plans as presented at the exhibition of 3rd and 4th March?

Some points you may wish to consider:

• Did you see any significant change from the original proposals? Has the developer really listened and responded to our concerns and comments?
• Is Phase 1 access through Station Road, Rossland Crescent and Newton Road acceptable? I certainly don't think so and have intimated my total opposition to this proposal to the developers and to Renfrewshire Council's Director of Planning and Transport.
• As for traffic lights on Station Road - only a computer programme could possibly think that's a good idea. Do you agree?
• Where are the developer's guarantees that any development will not increase pressure on existing Bishopton infrastructure?
• Can the completion of the proposed new health centre be accelerated?
• Why wait until 2009 before developing the station park and ride facility - it's already undercapacity.
• Do you want to see any housing built on Gladstone Hill? I had always thought that road - the "factory walk" - was to be left clear of new housing.
• Do you agree with the decontamination and remediation proposals?

There will be a lot more to discuss on this issue. Please keep up to date with development proposals and let me know what you think. I will continue to ensure that your views are heard.

Chair:              Cllr Iain Langlands - Bishopton Ward, Renfrewshire Council
Guests:            Mr Bob Darracott, Director of Planning & Transport, Renfrewshire Council, Mr Gilbert Wilson, Head of Consumer Services, Renfrewshire Council, Mr Pete Murray, Scottish Environmental Protection Agency, Ms Dorothy Simpson, Scottish Natural Heritage, Cllr Robert McNally - Erskine West Ward, Renfrewshire Council

Planning

The Glasgow & Clyde Valley Structure Plan Team is likely to recommend that Bishopton be designated a "Community Growth Area". The finalised paper from the Glasgow & Clyde Valley Structure Plan Joint Committee, if approved late January 2006, will be presented to Scottish Ministers who then have up to 40 weeks to consider the recommendations

Renfrewshire Council will not finalise or grant any ROF planning applications until Scottish Ministers have made their decision - this could be 2007. It is accepted however that BAE will lodge planning applications with the Council in Spring 2006, accepting that no early determination will be reached.

Various forms of "Planning Agreements" can be used to define and control the final outcome of any major project, the most common being Section 75 agreements. These agreements are legally binding and can include timescale and sequence issues. Infrastructure and facilities may also be described and controlled through such agreements.

Renfrewshire Council will secure such agreements with ROF developers, in consultation with the Bishopton community and the Council are in discussion with the Liaison Group about this matter at present.

Contamination and Remediation

Remediation methods will reflect the proposed use of the land. Several organisations, including SEPA, have been monitoring the ROF site since at least 1989. Dust and river sampling show no cause for concern.

The site is not defined as "Contaminated Land" as described in Parliamentary Acts. However, this is a procedural issue. The environmental issues associated with the site will be dealt with through the planning process.

Natural Heritage

Scottish Natural Heritage regulatory role is limited to some operations in Sites of Special Scientific Interest (SSSI) not normally regulated by other bodies such as SEPA or the Planning Authority. At ROF Bishopton, SNH has an advisory role to Renfrewshire Council, not regulatory. SNH has been involved in Bishopton for some time through the Local Plan process and commented on the Structure Plan recommendation that Bishopton be designated a "Community Growth Area". (N.B. This is the new term used in place of Area of Urban Expansion.) SNH will wish to know that the procedures are robust and will advise consultants if it considers efforts to be inappropriate. SNH may ask for more surveys if it is not satisfied with the information available.

The site is an unusual natural habitat having remained private, secure and undisturbed for some years now. Due to its former industrial use, there are no Sites of Special Scientific Interest (SSSI), however, many areas are noteworthy and efforts should be made to retain and preserve their character. Species are particularly relevant in the Bishopton issue due to the lack of human intervention for many years now.

Questions & Answers from the meeting

Q1       Do cancer clusters cause concern? Nothing untoward noted, although health issues are being sensitively addressed.

Q2       Who commissioned and paid for all the technical reports? No detail available.

Q3       What can a Section 75 Agreement be used for? For much more than simply Council services, it can be used to provide infrastructure and services required as a result of the proposed development. The Community has a large part to play in determining the content of any planning agreement. The Director of Planning and Transport is open to ideas from the community.

Q4       Why does the GCVSP team call for an additional 120,000 houses throughout the Glasgow and Clyde Valley Structure Plan Area? This is to help stop the falling population trends and to encourage population stability. Demand will come from new smaller households being created. Social trends affect the number of houses required, i.e. greater single occupation than before. The population assessments have been assessed independently and were verified as appropriate.

Q5       How can the Council consider a planning application when Scottish Ministers may take 40 weeks to determine the Structure Plan recommendations? Timetable is set by the applicant, not by the Council. Applications will not be determined until the Structure Plan is approved. If the Structure Plan is not approved then the applicant can still insist on a decision. The Council is making no assumptions on the Ministers decision on the Structure Plan nor on any planning applications. The Planning Director stresses that he had an open mind at this stage and would not start forming any views until he was in possession of a fully detailed planning application.

Q6       Why is Bishopton 121st on the Councils Contaminated Land Register? The Council determines each area as a separate entry. ROF Bishopton comprises several entries, the highest of which is at entry 121. If the whole site were considered as an aggregated single site then the entry would be considerably higher.

Q7       Will the site be fully decontaminated and remediated? The whole site will be treated to ensure that the decontamination and remediation is appropriate to the end use on an area-by-area basis. This approach accords with Government advice.

Q8       What Does the Council have authority to "move" the plan, e.g., can the Council insist on a remote development at the Georgetown end of the site? No. The Council responds to the plans as presented. The detail and footprint of development is a matter for the developer. Neighbours have a right to object and the Council will assess all representations and come to a view. There is a statutory process to be followed and an assurance was given that this would happen once the Council was in receipt of an application.

Q9       Does the community have a route to object? There is a planning process and residents can object to the Council as is normal in all other applications. Renfrewshire Council, SEPA and other agencies will be involved in assessing any applications for ROF Bishopton. SEPA will be looking for evidence that the proposals will break any links between remaining contamination and sensitive receptors. Contaminated materials may be disposed of on site or removed from site, both through controlled and licensed processes. SEPA will be a statutory consultee on any ROF planning application. SEPA will ask for conditions to be imposed and will seek to influence Renfrewshire Council.

Q10     What is being tested at Dargavel Burn? The Dargavel Burn is now good quality and has been monitored for many years now. Tests look at ammonia levels and insects in the bed. Insects inform more than the chemistry. There are fish in the burn too.

Q11     How can the developers prevent dust clouds during demolition? Approved method is to spray water to kill the dust.

Q12     Was SEPA a consultee to the Structure Plan? In general terms, yes, but not specifically on ROF Bishopton.

Q13      Does SEPA react only to BAE Systems surveys or does it ask for independent analysis? SEPA will consult with several independent consultants as well as with the Council. SEPA does not expect much air pollution. All foul drainage would be pumped to Bishopton pumping station and on to Erskine. SEPA is looking for wetland solutions to retain drainage water on site and so minimise flooding elsewhere. It is unlikely that SEPA will do more than sampling.

Q14     Is the site OK for now? The Dargavel Burn is now good quality and has been monitored for many years now.

Q15     Should the planning application fail, will the site be monitored continuously? The current situation is that BAE Systems are co-operating with the Council so far - there is no merit in serving notices on a willing participant.

Q16     BAE Systems are funding site surveys at present. How will SEPA and the Council know that subsequent reports are full and trustworthy? SEPA expects the site to be fully sampled. SEPA relies on the fact that consultants prepare the BAE Systems reports and the same consultants are professionals with appropriate experience and reputation. Council considers the level of study to be intense. The independent consultants studies will be presented to Renfrewshire Council who will, in turn, commission further independent expert analysis.

Q17     Have contaminant pathways been opened up? Will SEPA look to a zero-option and request that the site remain undeveloped? Dargavel Burn is OK. The flat nature of the site suggests there will be a considerable amount of pooled groundwater. There may be a requirement to look at the groundwater issue, it may need some work although it is unlikely that any groundwater has moved off site.

Q18     Have contaminants already left the site? Unlikely

Q19     Where can the public access relevant documents? Neither Renfrewshire Council nor SEPA have yet received any documentation in connection with a planning application for the site. Residents may consider looking to the Bishopton Community Liaison Group for information. Renfrewshire Council is investigating the possible future use of its website to disseminate information related to any ROF planning application. This is an issue the Director will discuss with the Liaison Group. There will be a lot of information submitted with any application and the Council needs to think about the most effective way of disseminating this.

Q20     Is SEPA not meant to lead where the site is a munitions site? The Council would need to define the site as a special site for SEPA to become involved in this way. The site has no such designation since all relevant issues will be dealt with through the planning process. However, details will be discussed with SEPA throughout.

Q21     Are there any Sites of Special Scientific Interest on site? Industrial use has ceased and some fantastic wildlife has taken advantage of the seclusion and a range of animals have moved in. However, the industrial damage means the habitat could not qualify for an SSSI.

Q22     Will STAG mean the motorway junction will be built anyway, regardless of the planning application? (Scottish Transport Appraisal Guidance) The new motorway junction is being promoted by BAE Systems and so would fall if the application fails or does not proceed.

Q23     Is it the old motorway junction being re-instated? The new junction is proposed on the site of the former junction, closed over 20 years ago

Q24     What pre-application discussions has Renfrewshire Council been involved in? Primarily with BAE Systems/Redrow Homes/CASS Associates. Issues discussed have included STAG2, environmental progress and the development Master Plan. Council has advised that it wishes to have complete copies of all supporting reports etc when the applications are submitted.

Q25     If an application is refused, can the developer and residents appeal? The applicant can appeal. Objectors cannot appeal - there is no 3rd party right of appeal. Also, objections must be relevant to the proposal - it is not simply a numbers game (in terms of petitions etc.)

Q26     What is the process for representation to Renfrewshire Council, objection or otherwise? The Community clearly have a right to object, however, Renfrewshire Council will not tell objectors what is the best approach. The Community Liaison Group may have a role to play in informing the community where guidance may be found.

Q27     What experience does Renfrewshire Council have in applications of this size and in BAE Systems previous track record? Renfrew Riverside is a large development that had contamination issues too. It is now progressing well following the approval of a masterplan application. BAE Systems own and manage a number of specialist companies with expertise in regeneration and decontamination. They have undertaken similar work in England, e.g. Chorley. Redrow Homes has a good reputation and can demonstrate an interest in quality and sustainability in its previous sites.

Q28     What benefits would our community get with any development? The submission of a planning application will result in wider consultation. However, Renfrewshire Council will not say what the community wants, that is for the community to advise. Mr Darracott asked "What does Bishopton want?" and stated that he wanted to know as soon as possible.

Q29     Who will make the decision on the Structure Plan? Scottish Ministers.

Q30     Would Inverclyde not welcome 2,300 new homes? Renfrewshire Council has not asked that question of Inverclyde Council although it is recognised that Inverclyde had a concern with the impact on their area of any Bishopton development. The Structure Plan is clear in that the number of houses required is for Renfrewshire, and not Inverclyde, by 2018. Inverclyde is a separate issue.

Q31     What is the Master Plan that has been referred to? The Master Plan will show broad housing areas, roads, junctions, etc. Detailed planning applications must follow on from the Master Plan. A Master Plan makes Section 75 agreements easier to impose.

Q32     Does Section 75 show phases of development? Yes.

Q33     What investigations have been done on transport issues? Renfrewshire Council will receive a transport assessment as part of the application process. It is required.

Q34     What about the railway? As for question 33 - there is a need to relate any development to existing infrastructure and assess its impact.

Q35     If groundwater is contaminated, how can SEPA be confident it is not seeping outside the site boundaries? Groundwater is unlikely to have left the site due to the flat nature of the site. However, there may be pooling near to existing on-site buildings.

Q36     SEPA said some waste would be removed from site. Will this be through the village? Yes (NB - BAE Systems has since shown plans showing a haul road exiting to the Georgetown end of the site, thus avoiding the need for significant construction traffic to move through Bishopton.)

26 September 2006