Views about our real wealth - the natural and social world, the source of our resources and the basis of our lives - and how it can and should be sustained for generations.
Sunday, February 10, 2008
Bristol's green and pleasant spaces and the council plans to flog them to developers
Many locals have lived in Bristol for a long time and have valued its open, green spaces very highly. Many have experienced the disappearance of areas they and their friends and family once roamed around and played in. There are self-evident leisure, tourism, recreational, entertainment, sporting and health benefits in open, green spaces. Green spaces also help attract and keep businesses and help them to attract and retain the staff they need. To these can be added key ecological and environmental function benefits. There is storm water drainage and thus flood protection, as the land soaks up, temporarily stores and then gradually releases rain. Green spaces take carbon dioxide from the air and thus help fight climate change (losing open space is thus as good as adding carbon to the air!). There is the provision of wildlife habitat and food supply, which aids biodiversity. This is by no means an exhaustive list.
In an urban area open, green spaces are vital to the quality of our lives, offering relief from the all too common congestion and other negative effects of development. They are a way of connecting with and appreciating the natural world – vital to wellbeing and to encouraging respect for nature. We sorely need this respect in order to build the green attitudes needed to fight extremely serious environmental (and thus security) threats. We would do well to remember that even the scrubbiest, scruffiest bit of land (called poor quality, low productivity, marginal or ‘surplus’ by Bristol City Council) will absorb, store and gradually release rain, absorb carbon and other pollutants, grow wildflowers, provide a perch and perhaps some food for birds, and provide people with a feeling of space.
Council spin on land classification -
How convenient for an organisation that wants to flog off 90 acres (2.4%) of our city’s green spaces to decide now, to describe the land that would be lost forever under developers concrete and tarmac as ‘marginal’, ‘surplus’ and of ‘low recreational value’. This is the, very highly subjective, view of Bristol City Council. The real truth here is not the type of land involved - that’s just the city council spin – it is that when land is, so say, ‘needed’ for development it is then made available! We would do well to remember that there is green belt land in Greater Bristol that is being made available to developers too by a number of councils run by different political parties. All are of course being pushed along by the Government's, and their unelected quango friends, policies. To sign the e-petition opposing the loss of acre after acre of green space in Bristol go to: http://epetitions.bristol.gov.uk/petition.php?id=166
Which land will be flogged? -
Bristol City Council has not yet given any idea which particular areas of green space and parkland will be flogged, so we are all unable to decide for ourselves, by direct consideration, whether we’d agree with their classification of it. The council have decided, so presumably they must know the candidate areas – so why don’t they tell us where they are so that we can look at it square metre by square metre? I suspect the earmarked land wont be in the wealthier parts of Bristol! If they don’t know the areas then how can they have made even the highly subjective classification?
The fact that discussions between the city council and the Bristol Parks Forum resulted in a drop in green space to be flogged is a clear indication of the rather arbitrary nature of the ‘low value’ classification. Originally it was reported that 200 acres would be sold, which dropped to 90 acres after talks, so did 110 acres of land suddenly ‘improve’ in value via negotiations ? If it has not improved in quality then what is the basis of this decision?
Judging by past reports and councillor pronouncements its likely that South Bristol’s open spaces are the most threatened. For instance the large Evening Post report ‘There’s room for hope in the south’ (March 17 2006) described how large areas of South Bristol are ripe for growth and development, including thousands of houses plus associated roads and infrastructure. The then Liberal Democrat Bristol City Council Cabinet member Councillor Anne White was quoted as saying ‘We have lots of open spaces in South Bristol which are not of great benefit to the local community…’. What a depressing lack of appreciation of the value of open spaces this comment shows. Are they of ‘benefit only when covered with brick, concrete and tarmac? What does the term ‘sustainable communities’, frequently used by Government and councils, mean in the face of what seems to be unbridled development pressure?
Council’s own words on the value of green spaces! -
We should not forget that land the council has now chosen to portray as ‘low value’ was until recently all counted as part of what the city website itself boastfully but correctly described as ‘450 parks and green spaces totaling over 1300 hectares, proportionately more than any other English city. 24 million visits are made to the city's parks and green spaces annually and, according to the city council's Citizens Panel, they are the third best thing about living in Bristol.’ The parks and open spaces section of the council website rightly waxes lyrical about the value of green spaces, saying ‘Parks are places to relax and enjoy the natural environment away from the stresses of city life. They are the ideal setting for healthy exercise, play, sport and recreation, and for enjoying the city's renowned events programme. You can also join in lots of fun outdoor activities to help you stay fit and healthy all year round!’ Fine council words, but not backed by actions as they hypocritically plan to cut the amount of what they praise.
Thin end of the wedge -
The original figure of 200 acres of green space loss seems to have gone down to 90 acres. Many will welcome the reduction, if it turns out to be actual as time passes, but it cannot be considered a U-turn as was reported because that would have to be a reversal of direction, that is, no loss. It’s more of an apparent and politically expedient slow down in loss. Still, there goes our ‘90 acres’ unless we act. The thin end of the wedge argument springs to mind – and the wedge is well and truly in, as the city continues the pattern of year on year loss of open space established in the past.
It would not surprise me to be told in the not-so-distant future that there is an unexpected funding shortfall meaning more parkland (or should I say more marginal/low recreational value/surplus land !) therefore needs to be sold. All this is clearly not the mark of an aspiring ‘UK green capital’.
How much green space might ultimately be lost? -
We just cant go on flogging Bristol’s green spaces to raise money and accommodate developers, though figures from the recent consultation documents sadly hint otherwise. So how much land could ultimately be flogged in the coming century if we don’t stop the year on year loss – what is the maximum scope? Bristolians have on average 38 square meters per person of green space, though the distribution is of course not uniform. Despite this relatively high average the council itself states that Bristol falls short of the National Playing Fields Association figure of 2.4 hectares per 1000 people of playing fields (Bristol has 1.6 hectares per 1000 people). The ‘Bristol Quantity Standard’ states that 27.8 sq m of green space would be sufficient. So the arithmetic shows that around 10 sq m per person could ultimately be made available to developers. With Bristol’s population currently at 411,000 this means 4.11 million sq m of land that could ultimately be flogged to developers. That’s 1015 acres or 411 hectares!
Land is of course needed if we are to build a sustainable society and so not all types of green space development under all circumstances should be opposed. Greens are much more likely to support and sometimes advocate, the development of land if that development clearly contributes to building the quality of life and sustainability of our neighbourhoods, communities and society (such as everything needed for local energy generation, food production, reuse, recycling, composting, skills development and small-scale local manufacturing). New green spaces should created to compensate for those taken and the land take should be relatively small-scale. There is growing evidence to show that having more green spaces is the best economic policy since it heavily influences crucial investment, productivity and organisational effectiveness issues such as whether businesses can attract and retain the best staff. We should for many, many reasons, therefore, try to avoid net loss of green space and indeed make the city greener if possible.
Tuesday, August 12, 2008
An introduction to green Bristol
There’s plenty of green space just outside the city boundaries, within easy reach, eg Ashton Court. As in many parts of the country green spaces are threatened by development. Bristol City Council has agreed a strategy to sell off of 2.4% of city green space. The future of green space is a key ongoing issue when there are plans to build many thousands of houses both within and around the city as well as a ring road around South Bristol. Bristol is a very popular place to live. Its population is currently forecast to rise by over 30% by 2031, exerting very significant additional social and environmental pressure at a time we need to cut it.
Bristol is also relatively green as a city as it gained its first Green Councillor, Charlie Bolton, in Southville, a few years ago. About time many would say, given the large number of organisations promoting respect and care for the environment that have for years been Bristol-based (CREATE Centre; City Farms; Transition Bristol; Farmers Market; Slow Food Market; local food advocates like the Better Food Company; Community Recycling Network; City Car Club…). What better example than the BBC Natural History Unit in Clifton, one key organisation behind June’s Festival of Nature and October’s Wildscreen the world's largest and most prestigious international wildlife and environmental film festival. The unit is responsible for world class television like Blue Planet and Planet Earth…playing a huge part in raising green awareness (http://www.bbc.co.uk/sn/).
Leading sustainable transport charity Sustrans, has, from its central Bristol HQ, been closely involved in some of the most discussed and controversial local issues this year. Bristol City Council had planned to build a bus rapid transit route over the Bristol to Bath Railway Path, the UK’s most popular cycle path, also used by a large variety of local walkers, until a 10,000 signature petition and a motion to the council from Green Councillor Charlie Bolton helped to cause a rethink. Going ahead with the plan might well have messed up the council’s bid to become the UK’s first ‘Cycling City’, which was ultimately successful. The council will have tens of millions to spend, wisely one hopes, on cycling.
Sustrans and other local greens, such as those at the Bristol Cycling Campaign or Bristol Friends of the Earth will continue activity on cycling but also on Bristol’s many transport problems. One of the major ways in which Bristol is very far from being green is the poor quality public transport (bus and train firm Firstbus are hardly fondly regarded locally!). Partly as a result Bristol’s air quality and noise levels can be poor at times and the city contribution to climate change needs to be cut by a factor of ten over the coming decades to approach sustainable levels! One small success of late is the rail service improvement on the ‘Severn Beach’ line – it’s a quick, efficient way to get around certain parts of the city, such as from Montpelier or Stapleton Road to Clifton.
There is ongoing scrutiny of how green Bristol actually is in a relative and absolute sense, eg whether or not it decides to mass incinerate much of its waste . The Bristol Partnership, the council working together with businesses, voluntary and community groups, has ambitions for the city to become a green capital ‘a low carbon city with balanced and sustainable communities enjoying a high quality of life’.
The eleven green objectives are commendable; leading Bristol-based organic food charity the Soil Association a leading light behind the September’s Organic Food Festival, is no doubt pleased to see the objective seven ‘healthier, locally produced food’ but the tension between green objectives and the Bristol Partnership’s other ambitions are great, in particular its economic thinking, which is still based on economic growth and a consumer society when environmental resources are finite. Bristol’s major current development is the huge new shopping area Cabot Circus. Green economics guru EF Schumacher, whose work is celebrated here every October at the Schumacher Lectures is probably turning in his grave.
Tuesday, August 17, 2010
Avonmouth biofuel plant: appeal to Secretary of State
Copy of email to Eric Pickles, Secretary of State for Communities and Local Govt and Chris Huhne, Secretary of State for Energy and Climate Change:I made a statement to a Bristol City Council planning committee on 09/03235/F, the application for a 50 MW biofuel power station to be built in Avonmouth, Bristol by the company W4B. The application was rejected by the council but W4B have since appealed and a Planning Inspector has therefore been dealing with the matter during August 2010 (ref APP/Z0116/A/10/2126342). I urge you to fully consider my view on this matter as part of your deliberations.
Bristol City Council and the applicant W4B have not supplied, early in the environmental decision making procedure, adequate, timely and effective environmental information and therefore provision for public participation has been inadequate – in fact completely absent for lengthy periods. The council has not complied fully and properly with either the letter or the spirit of Environmental Impact Assessment regulations, in particular as modified by the various EU Directives which enact the Aarhus Convention (see note 1 below). The council’s Green Capital/Green City policies clearly aim for best practice in this area but in this case at least it has not been forthcoming.
I look forward to your reply (please note that I have published this email on my blog and would like to – and plan to - publish your reply on my blog).
Yours sincerely
Glenn Vowles, MSc, PGCE, BA
Associate Lecturer in Environmental Studies and Environmental Decision Making
http://vowlesthegreen.blogspot.com/
Notes
Thursday, October 23, 2008
Bristol City Council policy on green spaces: flog any land whenever we see fit to do so
Tim, [Corporate Complaints Manager, Bristol City Council]
Thank you for your email about my complaint. There is description of and apology about but no attempt at an explanation for the delay in dealing with my complaint. There has been no explanation of why the communications I did have with the council were not in accord with council policy on handling complaints either. Perhaps you could address these issues.
Your latest email does not a provide a satisfactory resolution of all the issues I have raised. It lacks explanation throughout. As a result I cannot see how the 'cycle houses' planning application (ref 08/03862/F) can be fully and fairly processed at this stage. My view is that this complaint should be resolved first and I urgently seek your advice on this matter in particular.
I'm grateful for the confirmation that the green space in question is covered by the Parks and Green Spaces Strategy, as Richard Mond has previously stated. Area Green Space Plans do much more than you describe though and the strategy describes how they play a crucial role in defining the various land types, values and qualities in an area through the combined efforts of both council and local people via a consultation process. The strategy recognises that establishing the value of green space has social as well as scientific dimensions. Given that many Bristol to Bath Railway Path users and local residents feel strongly about their green space it is particularly important that an Area Green Space Plan is established before any land selling or processing of planning applications.
I very strongly object to the notion that
'it was always the case that there would be a small number of exceptions to this rule and that the Council would need to consider disposing of land where, for example, it might facilitate wider regeneration objectives to be achieved'
Where in the Parks and Green Spaces Strategy, which has been in place since February of this year, is this notion described? Where in the strategy are the criteria for deciding on exceptions outlined? Can you please provide references and/or quotes to justify and explain this assertion because it is a crucial matter.
You seem to be saying that there is some policy over and above the Parks and Green Spaces Strategy and that some Bristol green spaces are both covered by it and its processes but simultaneously can be dealt with outside its provsions! This is inconsistent, incoherent and unfair - how are people supposed to know which decision making processes apply to which green spaces? Is there in fact the openly stated and in fact lauded green spaces policy (which has been in place for ten months now) and another policy that allows the council to make decisions that go against it on an ad hoc basis? The council needs to address this matter urgently so that all green spaces are dealt with according to a clear, consistent, fair and open policy. Decisions on land disposal and planning applications wont be consistently handled until they do and the public could potentially be misled until they do.
I am somewhat confused as to what exactly this paragraph means:
'Due to public concern, council officers have now been asked by Cllr Mark Bradshaw to undertake a consultation with key stakeholders, including the Bristol Parks Forum, over the proposed disposal of this land and details of the consultation will be communicated to you amongst other concerned people, in due course.'
Yours sincerely
I note that you have had an exchange of emails with Richard Mond and that he has sought to respond to your enquiries. However, I recognise that these emails did not constitute a formal response. I hope this email remedies that situation.
Taking your numbered item 1 first, we acknowledge that the Bristol Bath Railway Path is recognised as accessible green space within the adopted Parks and Green Space Strategy, and that the strategy sets out a programme to produce 14 Area Green Space Plans to inform decisions over green space property disposals.
However, it was always the case that there would be a small number of exceptions to this rule and that the Council would need to consider disposing of land where, for example, it might facilitate wider regeneration objectives to be achieved. This is the case with the railway path land adjacent to the Chocolate Factory development.
In item 2 you point out that the area in question has not been subject to an Environmental Impact Assessment (EIA). However, an EIA is not needed for this development. Instead, planning officers issued the 'screening opinion' dated 30th May 2008 under Regulation 5 of the Town & Country Planning (Environmental Impact Assessment) (England & Wales) Regulations 999. A copy is attached for your information.
In your email to the Chief Executive today, you suggest that this matter is now at stage three of the complaints procedure and you would wish to go on to the Ombudsman if you remain dissatisfied. I don't know that I could agree that we are at stage three but if you believe that there would be little value in continuing to pursue this matter with the Council, then I would support your approach to the Ombudsman.
Tim Sheppard
Corporate Complaints Manager
922 2233
tim.sheppard@bristol.gov.uk
Monday, August 27, 2007
Renewed focus on environmental education is needed
( http://www.bristol.gov.uk/item/epetitionview.html?PetitionID=191 ) which is about enhancing environmental education and awareness through school/college environmental charters. I've written and used environmental charters in several of the places I've taught and they can work well.
My petition says:
The petitioner requests that, consistent with objective 10 in the Bristol 'Green Capital' pledge list to 'enhance environmental education and awareness', Bristol City Council circulates a 'Model Environmental Charter' to all Bristol schools and colleges, accompanied by a letter to governors urging them to adapt the model charter to suit, adopt it asap and agree to annually review progress related to it.
The model charter referred to goes like this:
The students, staff, governors and all friends of ...school/college will work to make annual improvements in:
* developing and improving grounds and buildings in a green way (like ponds, wildflower areas, tree planting, vegetable plots...)
* keeping the school and grounds clear of litter
* saving energy for example by sensible use of heating and lighting
* reducing waste, reusing and recycling
* using healthier, environmentally kinder products
* using recycled products and locally produced products
* efficient use of all resources, such as water, food, paper...
* travelling to and from school in low impact ways, like walking, cycling and public transport
* teaching care and responsibility for the environment, people and community, guided by a clear environmental education policy dealing with education about, education in and education for the environment
My experience tells me that schools and colleges need a focus for their environmental education work. Adopting an environmental charter can provide this focus in a school/college. It also takes forward the Bristol 'Green Capital' objective of 'Enhanced environmental education and awareness'.
Environmental education's profile surely needs to be substantially raised in all schools and colleges given that we all need to live more sustainably. In my view all of Bristol's schools/colleges should carry out environmental education: in and through the environment as a resource; about the environment by imparting knowledge; and for the environment by encouraging students to formulate caring values, attitudes and practical actions in their environment; and by developing the skills needed to study the environment in students.
One interesting development is that my petition has drawn a response from Kate Campion, Program Director, Children and Young Peoples Services, Bristol City Council, who wrote this in the discussion section of my petition:
All schools are expected to include environmental education as part of their citizenship agenda. Curriculum coverage is monitored by OfSTED inspections. The LA promotes environmental education through the work of a consultant, working with schools to develop the curriculum to ensure learning is about the environment, in different environments and through the environment, about 'real world' learning. Bristol City Council also provides support for schools to become Eco Schools and the Council has made a pledge to support the 'Learning Outside the Classroom Manifesto'. An Outdoor Learning Policy and strategy is currently in draft format. Within our new secondary school building programme, the council is seeking every opportunity to ensure environmental standards are being met and that the building programmes and the subsequent maintenance of sites can be used as a tool to support learning. We are also promoting school travel plans. Over 90 schools now have a travel plan that highlights the benefits of environmental awareness and positive action towards environmentally friendly options. Much of this work is also promoted through the Healthy Schools programme, for which BCC holds 'Beacon' status. We agree that all schools should be encouraged to be environmentally friendly, promote environmental education and ensure learning is of high quality. To this end we work with schools to promote the agenda. Each school must make a decision about how this work is undertaken, by becoming an Eco School, a bespoke charter is created which directly relates to a particular school. We think this is the best way of promoting and sustaining environmental education and practice.
This is a very interesting contribution which I will shortly be discussing with her. From what I know about getting eco-school status a school applying would need something similar to an environmental charter (or some other sort of statement of environmental intent at least) in order to be successful in their application (http://www.eco-schools.org.uk/). I thus hope that the council will agree to circulate a model charter, consistent with their policy of supporting schools to become eco-schools, encouraging schools to be environmentally friendly and promoting environmental education.
I do agree very much that each school must make its decision on how environmental education work is undertaken. Its important that each school, or in fact any team or organisation has ownership of its policies and action plans. This is why the petition says that schools/governors use the model charter as a basis, adapting it to suit them...
On the other hand by circulating a model charter I think the council would be signalling that they want schools to develop a renewed focus for their environmental education efforts, saying that they should have some sort of overarching statement on the environment. Some local schools will have an environmental charter or equivalent statement, sometimes a fully developed and operating specific environmental education policy (including one school and one college where I have worked as a science teacher).
I think all schools should be in this position however, and hope the council agrees, because of the critical importance of environmental issues. Why shouldn't all schools become eco-schools of their own design? In fact the model environmental charter could easily be adapted for all sorts of organisations.
Monday, April 21, 2008
'Save Our Caretakers' - lets hope Labour live up to their fine words in practice as city reviews caretaking
Labour campaigns to protect 'essential service' for residents, 2 Feb 2007
Dawn Primarolo, Labour MP for Bristol South, today joined with local people to protest against Lib Dem plans which threaten the position of resident caretakers across the city. Labour's councillor for Southville, Linda Salter, and local activist Sean Beynon were also there to launch Labour's petition against the proposals.
Dawn met with residents at Chalcroft House in Ashton to assure them that Labour was on their side. Afterwards, she said:
"Caretakers provide an absolutely essential service for people living in blocks of flats across Bristol. We fear this Lib Dem policy is a sneaky first step towards getting rid of caretakers altogether. These City Council proposals seriously affect the terms and conditions of new employees, and even those staff who have given many years of loyal service will only be protected from the Lib Dem axe for a limited time".
Frank Baker, Chairman of Chalcroft House Residents Association, agreed:
"Lots of people in Chalcroft House gave up three bedroom houses in return for a promise from the City Council that we would have safe and secure flats. If we lose our resident caretaker, then the security of every resident will be compromised. There is also no way that off-site contractors could keept the communal areas of the block so clean and tidy. We are very lucky here to have a fantastic caretaker and we aren't going to give up without a fight".
Commenting, Linda Salter, who is also Labour's Spokesperson for housing in Bristol, said:
"The council's plan was rejected by trade unions, and tenants have shown overwhelming support for their caretakers. It's a shame that the Lib Dems teamed up with their Tory friends on the council to pass this policy, but residents and caretakers know that Labour will stand up for them".
Sean Beynon concludes:
"The council wants to carry out a shake-up of the whole system next year, so it's vital that we act now. We will keep up the pressure on the council, and have started to distribute petitions and 'Save Our Caretakers' posters to residents in flats across Bristol".
and
Labour condemns 'backdoor privatisation', March 2007
Hundreds of residents have joined Labour's Sean Beynon and Linda Salter in fighting the Lib Dem City Council's attack on resident caretakers in blocks of flats across Southville and Ashton.
"We're very concerned that this drastic cut in the benefits available to new employees is actually a sneaky first step in getting rid of the caretakers and replacing them with the lowest bidding off-site private contractor", Sean explains. "We don't believe these agencies would be able to provide the service that residents rightly expect, which is why we are fighting these plans".
Over two hundred flat dwellers have already signed Labour's petition calling on the Lib Dems to reconsider their plan to cut caretakers' employment conditions. "Most of these residents are older people who really value the caretaking service", Linda says. "But they can't fight the Lib Dems on their own. We're doing our bit to back them, but we need everyone else in the area to rally round and show their support as well".
If you agree with us and think the Lib Dem City Council should urgently think again, text* 'Save Our Caretakers', together with your name and postcode, to 07835 751538.
* charged at your standard network rate
Wednesday, February 24, 2010
Biofuels in Bristol: decision day
The facts say you have to refuse permission for this power plant. Bristol City Council and the applicant have not supplied, early in the environmental decision making procedure, adequate, timely and effective environmental information and therefore provision for public participation has been inadequate. The council has not complied fully and properly with either the letter or the spirit of Environmental Impact Assessment regulations, in particular as modified by the various EU Directives which enact the Aarhus Convention (see note 1 below). The council’s Green Capital/Green City policies clearly aim for best practice in this area but in this case at least it has not been forthcoming.
The Aarhus Convention is a relatively new kind of environmental agreement and enacting it enables a decision making body to deal well with the interconnected, interrelated nature of environmental, economic and social issues, such as those posed by this planning application. The Convention: links environmental rights and human rights; acknowledges that we owe an obligation to future generations; establishes that sustainable development can be achieved only through the involvement of all stakeholders; links government accountability and environmental protection; focuses on interactions between the public and public authorities in a democratic context. Public authorities such as Bristol City Council are obliged, under the Convention, to actively disseminate environmental information in their possession – but this has not happened for this application.
The Area Planning Coordinator said this in an email to me on 16 Dec 09,
‘The applicant made a formal request to Bristol City Council as the
Local Planning Authority in February this year, to which Bristol
indicated in April that it did not consider the proposals as set out in
the request to be EIA development. Whilst the applicant has proceeded in
preparing their planning application on this basis, this position was
not however formalised until earlier this month (11 December 2009) when
a formal Screening Opinion was issued in accordance with the EIA
Regulations. I have therefore attached a copy of the formal Screening
Opinion of Bristol City Council as Local Planning Authority, for your
information.’
The council made no attempt to actively disseminate the fact that a formal request (note: formal request) had been made. It made no attempt to disseminate the fact that it was minded not to consider the proposals an EIA development. Yet the environmental decision process has very clearly begun and the applicant has had the benefit of early information from council planning officers! Opportunity for public opinion and participation, including non-council experts, early on in the decision process were thus lost. In fact, there was no opportunity for public participation in the screening process, the first stage in Environmental Impact Assessment, at all. The council gave its ‘formal’ opinion on December 11, identical to the opinion it gave the potential applicant in April 09, and only released the relevant letter to a selection of members of the public like myself on 16 December after we made a nuisance of ourselves through repeated phone calls and emails. So much for actively disseminating environmental information.
Almost a year passed by (ie Feb 09 to mid-Dec 09) with no opportunity for public participation. Keep in mind the fact that this committee was close to having this application on its agenda in January!! As a result, as you can see from the many contributions people have been and are seeking to make, there is a huge glut of observations and arguments – all presented over a very short period of time and all dealing with complex, interlinked, possibly unresolved issues. Properly abiding by environmental impact assessment procedures, as modified by the Aarhus Convention, taking on board the principle of early environmental information and public participation, is what the council in obliged to do, is what its Green capital policy says it should do, and it’s the best practice way to have proceeded.
Just some of the complex and interlinked issues (referred to above) are listed below:
*how to define what a renewable fuel from plants is (potatoes for human consumption are a renewable fuel source from plants if grown properly but another plant product like mahogany certainly would not be, or at least not on anything like the same basis);
*how to guarantee that any fuel supplied is renewable in practice (certification standards, inspection, independent verification…are absent for the fuels proposed by the applicant);
*what a total carbon footprint is and how the carbon accounting is best done (the carbon footprint figures supplied by the applicant are not a total carbon footprint as this would require all direct and all indirect carbon emissions to be accounted for – but there are no figures supplied for land use changes and methane emissions associated with the fuels proposed, a major omission, and in fact several processes);
*whether cumulative air pollution impacts on people’s health and on the health of nearby designated sites is sustainable and would allow the Environment Agency to permit any power station given planning permission to operate (Avonmouth is already heavily polluted – see below).
The council view that no Environmental Impact Statement needed to be prepared is incorrect as well as being established with zero public participation. Officers wrongly concluded that were no impacts of significance. Even within the council officers narrow system boundary this fails to account for the effects of the power-plant on the Severn Natura 2000 Marine site, which are in fact of significance. This area was selected against rigorous scientific criteria to protect the most threatened and important species and habitats in Europe, as described by widely respected organizations like the RSPB. No document relating to this application even recognizes any site with such a designation. Yet the site is of international significance (UN RAMSAR listed, up to 100,000 birds over-winter there, Slimbridge is just upstream). It is 450 yards from the power-plant site. It is protected with tough international limits for nutrient nitrogen deposition. Those limits are already exceeded in Avonmouth because of the traffic on the M5.
That means only insignificant levels of nutrient nitrogen can be permitted by the Environment Agency if they are to give W4B’s power station an Operating Permit. Insignificant is defined as less than 1% of the Environmental Quality Standard. W4B and their consultants have not provided ANY data relating to nutrient nitrogen emission impacts on ecosystems.
The Environment agency have written to me on this matter saying:
> “There are some areas of Natura sites within 10km of the proposed installation
> where the background deposition already exceeds the critical load. In this
> case it would be difficult but not impossible to justify emissions above 1% of
> the critical load. It is the responsibility of the applicant to provide such a
> justification. The figures in the planning application suggest that there may
> be such potential impacts but this is not certain at this stage."
Natural England, consulted by the council, has not raised the issue of nutrient nitrogen and the reserve (at least not until time of writing = 18:15 Monday 22 Feb ’10) thus failing to fulfill their role to provide statutory protection for it. The Joint Nature Conservation Committee the statutory adviser to Government on UK and international nature conservation, should, I believe have been consulted by the council but this appears not to have been done. Please reject this application.
________________________________________________________________________
Notes
1. Two Directives concerning the first and second "pillars" of the Aarhus Convention have been adopted by the EU; …. implemented in the national law of the EU Member States by 14 February and 25 June 2005 respectively:
Directive 2003/4/EC of the European Parliament and of the Council of 28 January 2003 on public access to environmental information and repealing Council Directive 90/313/EEC
Directive 2003/35/EC of the European Parliament and of the Council of 26 May 2003 providing for public participation in respect of the drawing up of certain plans and programmes relating to the environment and amending with regard to public participation and access to justice Council Directives 85/337/EEC and 96/61/EC
Provisions for public participation in environmental decision-making are furthermore to be found in a number of other environmental directives, such as Directive 2001/42/EC of 27 June 2001 on the assessment of certain plans and programmes on the environment.
Wednesday, September 10, 2008
Bristol to Bath Railway Path land sell-off: council response to my objection letter
Dear Mr Vowles,
Further to your e-mail dated the 4th September, I respond to your concerns with regard to the potential sale of the land as follows:
The potential loss of the green corridor along side the Railway Path was raised as a concern by Bristol City Council's Nature Conservation officer. As such, if this sale proceeds it will be on the condition that Squarepeg engage in dialogue with this officer to ensure that proposals provide the necessary compensatory measures for any loss of habitat and vegetation.
*Attempting to compensate for loss of habitat and vegetation is highly problematic and sometimes controversial. ‘Nature knows best’ is a great guideline for conservation. The council’s Nature Conservation Officer will know that a potentially big compromise has been made. We may be getting better at compensation but measuring the full value of the land before development is in itself an issue. Then you cant simply and easily ‘put back’ mature, fully functioning ecosystems and so there is likely to be a loss of quality for some time and quality may never return to its best. When land is back to an ‘equivalent value’, if at all, is often very hard to say.
Some say that habitat compensation is based on an economists view of nature not an ecologists. It thus serves to accommodate development interests not those of sustainability, attempting to legitimize damaging economic growth.
With regard to the lack of consultation over the potential sale of the land adjacent to the railway path. Bristol City Council has stringent procedures which it must follow when disposing of land, these procedures do not require the council to carry out public consultation prior to disposing of this land.
*I had the opportunity to object to the land sale only because of what I read online in various blogs (here and here). This means that very many members of the public locally, who own the land via the council, have not had the same chance. This is unjust and undemocratic. Please could you reply outlining the ‘stringent procedures’ you refer to as I’d like to see exactly why they mean public consultation is not required. Even if technically not required under current procedures I am dismayed that the council does not take the view that consultation is desirable on grounds that openness and public participation is to be valued (I note that developers Squarepeg are keen to stress that they value an open approach in the report on this issue in the Bristol Evening Post).
I can confirm this sale is not a 'done deal' and that whilst discussions have taken place with Squarepeg over the potential sale. No terms have been agreed, when seeking authority to proceed with this sale your objection will be presented along with the proposed terms.
*Not a ‘done deal’??? But today’s Bristol Evening Post story refers to a spokesman for the council saying: "The developer of the chocolate factory is negotiating with the council, which is finalising an in-principle agreement to sell a small strip of land…’ Sounds to me like a deal is virtually done - what else does 'finalising an in-principle agreement' mean!?!?
If you wish to discuss this matter any further please do not hesitate to contact me on 0117 9224028.
*Please pass on my further objections along with my first letter. I'd appreciate a response to my points about the highly problematic nature of habitat compensation, what council 'stringent procedures' are, the lack of opting in to full and open participation of the public on the land sale and when exactly a deal is or is not done.
Yours sincerely
Peter Webb
Peter Webb
Portfolio Management Officer
Valuation Practice
Floor 6, B Bond
Smeaton Road
Bristol
BS1 6EE
Tel: 0117 922 4028
Fax: 0117 922 4676
Photo of land near the area concerned, by Martyn Whitelock. Lots of great photos of the path on his site http://railwaypath.blogspot.com/ well illustrating its green quality.
Wednesday, October 15, 2008
Complaint about complaint!
All I have had is a brief indication in a few emails who would be dealing with my points (the last information I have is that Richard Mond would be dealing with it, though it was previously with another person) with some brief discussion on issues. I recently sent a reminder email to Mr Mond asking for the latest on the progress of my complaint but received no response to this. Complaints are very unhappy that the proper procedures have not been followed by those officers dealing with my complaint and I had a conversation early this afternoon with Tim Sheppard from Complaints who is now contacting Richard Mond on my behalf to speed the process up from here. I 've not been contacted this afternoon by Mr Mond.
I'm very concerned about time slipping by however (my complaint has a strong bearing on a planning application that I want to comment on and object to and the time within which I can do this is running out) and thought I would email you too. Mr Mond did not give me information on the stage my complaint had reached, thus this email, which I think means my complaint is at stage 3 (?). I've been advised by my local councillor to contact the local govt ombudsman on the substance of my complaint and the process by which it has (or rather has not) been handled - I'm in the process of looking into doing this now and this message is copied to the local govt ombudsman.
I look forward to your response with interest.
I have two complaints about what appear to be procedural errors on the
part of the council in relation to land on the Bristol to Bath Railway
Path (where the development of the former chocolate factory is now
proposed).
1. I am very concerned that the council's own procedures on green spaces
disposal or change of use has not and is not being applied to the green
corridor that is the Bristol to Path Railway Path.
The Parks and Green Spaces Strategy mentions the Bristol to Bath Railway
Path as an example of a significant and important green space. Yet it
seems that a strip of land which is council owned has either been sold-off
or is the subject of an in-principle agreement to sell before an Area
Green Space Plan covering the area has been drawn up and consulted upon.
This procedure is clearly outlined in the strategy and so I cant
understand why it has not been followed.
I'm also very concerned that a week ago I emailed Cabinet Member Cllr
Rosalie Walker for clarification of the status/designation of the land and
have not even received an acknowledgement, yet alone a prompt reply.
2. I am also very concerned that the plans for development on the strip of
land at Greenbank that I refer to above have not been subject to an
Environmental Impact Assessment as described by an EU Directive, even
though the directive is supposed to be interpreted and applied broadly in
order to make environmental protection effective.
Ensure that procedures outlined in the Parks and Green Spaces Strategy are
followed and applied to all green land along the Bristol to Bath Railway
Path.
Draw up an Area Green Space Plan, after public consulation, covering the
Bristol to Bath Railway Path green spaces, before any land is actually
sold and review urgently any in-principle agreement to sell council-owned
land on the path.
Inform me of the status/designation of the land in question, explaining,
if required, the reasons why the Parks and Green Spaces Strategy does not
cover the green spaces along the Bristol to Bath Railway Path.
Explain why an email to a cabinet member has not even been acknowledged, a
week after it was sent.
Urgently review whether the EU Environmental Impact Assessment procedure
should be applied to developments on/near the Bristol to Bath Railway
Path, interpreting the directive and its use as was intended by its
authors ie broadly.
Tuesday, June 30, 2009
Update on my Sustainable Communities Act suggestions - 14 out of 22 deemed eligible for Cabinet consideration!!
I am writing to thank you for participating in the Sustainable Communities Act process. We had a fantastic response, with 151 suggestions being submitted.
Suggestions made to the Council under the Act have now passed through the first stages of the Council’s evaluation process.
The Council’s Legal Services department has evaluated the suggestion(s) you submitted in order to identify whether they met the requirements of the Sustainable Communities Act, in that:
*It would need a change in legislation to be implemented
*It would contribute towards sustainability as defined in the Act
Your suggestion(s) listed here were deemed eligible under the terms of the act.
*Reduce commercial and industrial waste: give LA's responsibility for commercial waste; introduce NI for waste minimisation [this one submitted jointly with another person]
*20 mph default speed limit
*Carbon budgets and carbon trading for all
*Statutory biodiversity/eco footprint data in planning applications
*Government to assess capabilities of all technologies prior to implementation
*Ecological compensation for greenfield development
*Prioritising cycling and walking via a review of national and local transport policy and practice
*Immigration and emigration zero balance
*Broadening range of statutory planning considerations
*Criteria of fairness, openness and balance for government public consultations
*Transport costs to reflect total costs of travel
*Financial accounts to be accompanied by social and environmental accounting
*Councils to publish total ecological footprint
*Welfare or well-being index
75 suggestions overall were eligible to go forward and these have also been considered by the following:
Officer Panel – senior Council officers with appropriate expertise added factual comment where necessary. This panel did not recommend or exclude suggestions.
Local Panel - Bristol City Council commissioned VOSCUR (an independent organisation set up to support voluntary and community action in Bristol) to convene a panel including representatives from neighbourhood partnerships, equalities groups and councillors. This panel prioritised the suggestions prior to forwarding their views onto Cabinet Member, Councillor Jon Rogers.
Cabinet Member – all suggestions have been sent to Cabinet member, Councillor Jon Rogers. Recent guidance from the LGA has set out what sort of information will be needed to support a suggestion. Councillor Rogers will now use this guidance to review all the suggestions and comments made by the Local Panel and recommend a shortlist of the strongest and most feasible ideas to be worked up for submission to the Local Government Association. This shortlist and all other relevant information will be available on our website www.bristol.gov.uk/sca shortly.
The Council’s Cabinet will decide which suggestions the Council will adopt as its formal proposals. These will be forwarded to the Government via the Local Government Association (LGA).
The final decision will be made by Cabinet on Thursday 30th July at 6pm in the Council House. Cabinet meetings are open to the public, and any members of the public may present a statement or question. Statements must be submitted by 12.00 noon the day before the meeting, and questions by 5 pm 3 clear working days before (Friday 24th July). These should be sent to Ian Hird, ian.hird@bristol.gov.uk, tel. 0117 922 2384. Papers for the Cabinet meeting should be posted on the Council’s website on Thursday 23rd July.
The Council recognises the value of all suggestions received and appreciates the time that has gone into producing them. If your suggestion does not go forward, we will forward your ideas to the relevant council department for further consideration and respond to you in writing.
If you need any further information about this process, please contact Deborah Kinghorn, Policy Officer, on 0117 922 2792 or email Deborah.kinghorn@bristol.gov.uk or visit our Sustainable Communities Act page on our website www.bristol.gov.uk/sca
Yours sincerely
Deborah Kinghorn
Policy and Scrutiny Team
Deputy Chief Executive’s Office
Wednesday, June 24, 2009
Lib Dem fix for Bristol???
To give them credit, Bristol’s Liberal Democrats have performed extremely well in order to get into this position. They know how to fight elections very well indeed. They took four seats from Labour in the recent local elections in addition to successfully defending all eleven of the seats they previously held, including a threat to their Ashley seat from the Green Party. They were helped by the very poor Labour performance – they lost eight out of the ten seats they defended (four to Tories, four to the Lib Dems) and only narrowly held on to the two seats they won. Thus ended years of a ‘hung’ council where no party had overall control, which featured see-saw politics and two parties always ganging up on the other through unholy alliance – this is a very good opportunity to give Bristol some firm direction and leadership.
There are some tough problems to solve. The Lib Dems have said they want to ‘Cut congestion and get better transport for all’ (including backing suburban rail; more money for road safety, pedestrians and cyclists; introducing a cashless ‘Oyster Card’ for Bristol buses). Under the transport heading issues like residents parking and air quality wont go away. The key benchmark of progress here is congestion.
Lib Dem policy two is ‘A clean and green city’ (which includes more money for street cleaning, getting tough on flytipping; a ‘parkie’ in every major park and more play areas for children; fighting the green belt grab and preserving our green spaces). It will be very interesting indeed to see the extent to which the Lib Dems oppose building on Bristol’s green belt, particularly since Bristol City Football Club propose to build a new stadium on green land in Ashton Vale, where many houses are also proposed and at least part of which is green belt. All party leaders except the Greens have given public and enthusiastic support to the proposed new City stadium in principle and they are backing a bid to bring World Cup football to Bristol, which a new stadium would be necessary for. Amount of green belt and other green space built on is a key indicator here. I’d also add that the total carbon emissions of the city are a key indicator because everyone recognises that low carbon emissions are a key feature of being green – and the connection with cutting congestion is obvious.
‘Boost Bristol’s Bobbies’ says policy three (including a fair share of police; campaign against ID cards; new crime reduction schemes on repeat offenders and violent partners). Police and Community Support Officer numbers are easily counted and tracked but this does not necessarily mean more peaceful, orderly, lower crime neighbourhoods, so the benchmark is not so straightforward. Real, effective leadership would give us less crime and more peace and order.
*
The Lib Dems get very specific about policy 4, which promises ‘Three new libraries, a new school [North Bristol] and a new pool [East Bristol]’. This policy includes a promise to ‘fix Labours school places mess’. This year saw chaos for parents and pupils trying to find the school place they need and want for their child and so this pledge to ensure that 2010 sees no repeat of the previous fiasco. The local press has described this as a poisoned chalice!! We will all be able to see whether the various facilities are built and whether school places – but there is no promise on an overall improvement in the quality of education and it looks like the Lib Dems will implement most if not all of the plans to create bigger primary schools which wont be popular in many places and is seen by some as going against the quality of the educational experience. Real, effective leadership would improve the quality of education, not that this is straightforward to assess!
The pledges in policy five ‘Beat Gordon Brown’s recession in Bristol’ (including keeping the council tax as low as possible and campaigning for it to be scrapped; extra help on debt for small businesses and individuals; investment in training and apprenticeships) are more nebulous and designed to pick up votes during a time of recession. We all know that the council cannot make Bristol a recession-free zone and everybody would subscribe to the other policies under this heading the way they are worded!
Policy six ‘50% recycling by 2010 and no incinerator’ (which includes switching from a large, dirty incinerator to clean and cheap new technology; free corn starch brown bin liner bags; reversing the recycling rate drop under Labour) really should be under the ‘clean and green city’ heading. Mass incineration has already been abandoned, though putting alternative approaches into practice within a decent budget is doable but not straightforward. ‘Free’ corn starch bags will need to show that they can more than make up for the carbon cost of producing and consuming them and for their financial cost to the council but its uncertain that all the required data to make the assessments was sought by the council beforehand. Improving Labour’s recycling record wont be difficult because their work on this was poor – achieving a 50% [household waste] recycling rate by 2010 would be great (and a target with a timescale makes a change!). We still need to push on a lot from there if we are to have a low waste city though and someone (central govt??) needs to get a grip on total waste, most of which is not generated in households of course.
Tuesday, January 06, 2009
Further questioning Bristol City Council on green spaces and transport
Note that a 31 page, 13,000 word document of complaint was sent to the Local Government Ombudsman by me this morning saying: that Bristol City Council has not followed its own green spaces policy and procedures; that senior officers have taken ad hoc decisions; that prominent figures with a vested interest in developments have had undue access to officers and influence over decisions; that officers and councillors did not respond adequately and promptly to communications; that the decision on not conducting an environmental impact assessment on the 'cycle house' plans may not have been taken on a proper basis; that dealing with my complaint was consistently delayed, lacking in detail, lacking in references, lacking in explanation and lacking in direct response from those with the most specific expertise; that current consultations are sorely lacking compared to official policy.
I've been compiling this document as the issue has developed over weeks/months and every time I've thought it was complete another relevant development has occurred eg the 'consultation' referred to in the question below (very ably criticised by the Bristol Greengage and Green Bristol Blog).
Q. Consultations have begun over the sale/lease of land on the Bristol to Bath Railway Path to property developers Squarepeg, though the process appears to be a very, very poor substitute for the Area Green Space Plan process laid out in official policy, the Parks and Green Spaces Strategy and appears to focus in much more on the development issue via leading questions than on the land sale/lease: can you explain why the Area GreenSpace Plan process, now underway in several parts of Bristol, was not brought forward for the locality encompassing this land ??
Follow-up questions to Cllr Mark Bradshaw on transport issues in South Bristol also submitted to the same meeting:
Q1. In response to questions I put to the November Cabinet [see C2, C3, C4 on the link] meeting about the South Bristol Link you informed me that estimates of the impact on air pollution and congestion in the Knowle/Brislington area had not been released: what are your thoughts on the importance of information such asthis being made widely available asap during a consultation period??
Q2. In response to questions I put to the November Cabinet meeting you confirmed that you may use Cycling City cash to buy land along the Callington Rd Link (intended to be part of a strategic road network): will cash be returned to the cycling budget if a road is built there??
Further detail on previous green spaces and transport questions here and here.
Wednesday, August 04, 2010
BRISTOL City Council should know whether it can swap bendy buses for a light tram system by the autumn.
I've long argued that Ultra Light Rail (ULR) is a far better public transport technology choice than bendy buses. If the council do go for ULR this would be an improvement to local public transport plans - still issues about the system not being properly integrated, fairly priced, sustainably fuelled, on appropriate routes etc...
BRISTOL City Council should know whether it can swap bendy buses for a light tram system by the autumn.
Ultra Light Rail is essentially a tram that can run on branch rail lines and roads, is environmentally friendly and does not require electrification.
Unlike trams, the tracks can be laid down on road surfaces, which means roads don't have to be dug up to make it work, and overhead electric cables are not needed.
Currently the West of England Partnership – which includes the city council and its three neighbouring local authorities – has government funding bids in for £288 million of bendy bus routes across Bristol...
Tuesday, March 15, 2011
Green spaces sell-off? Bristol City Council has no Plan B
BRISTOL City Council has never looked at ways of paying for the £87 million parks improvement plan that didn't involve selling off green spaces, it has been revealed.
The authority has always maintained that disposing of up to 64 sites across the city was the only way that enough money could be raised to pay for improvements in up to 200 others.
But it turns out that in the last five years of the Parks Green Spaces Strategy (PGSS), the council has never costed or even considered a plan that doesn't involve land sales.
The original funding for the improvement plan was £41 million from land sales; £21 million of grant funding; £15 million of money from developers and £10 million from the council parks budget. Since these 2006 estimates, the council has dropped the amount it expects to raise from selling land from £41 million to £11 million...
Bristol Green spaces Bristol City Council Liberal Democrats
Wednesday, April 04, 2007
A 'Noise Strategy for Bristol' is needed to tackle this often forgotten pollutant
http://www.cpre.org.uk/campaigns/landscape/tranquillity/national-and-regional-tranquillity-maps
Bristolians are increasingly living with unacceptable and unhealthy levels of noise (city council website acknowledges this). The noise levels from traffic, which the council acknowledge as the main noise source in the city, often peak at what can only be described as 'industrial' levels at the busiest times, especially with heavy lorries. However, strategies to address the problem are available and should be enacted now - thus my attempt to highlight the issue and call for a noise strategy and action plan for Bristol modelled on London's.
I have been taking noise pollution readings with a sound level meter along the Wells Rd in Knowle at various times, dates and locations on the road. My findings: when roads have just a few cars a 50 decibel reading (at 4-5 metres distance) is typical, the level at which normal conversation is conducted. As soon as a steady flow of traffic is present readings are a steady 80 decibels - note that normal conversation is interrupted at 60 decibels and shouting is needed to be heard above 70 decibels. Its common experience in Knowle that you cant walk your child to Hillcrest School down the Wells Rd and hold a conversation or give an instruction without shouting and you cant walk to work listening to your MP3 player without turning up the volume more than normal.
When traffic is busiest and heavy lorries are on the road noise pollution reaches industrial levels at around a common 93 decibels. The highest reading I recorded was 97 decibels, from a particularly large, heavy lorry which rattled as it broke the 30mph speed limit climbing the hill opposite The George pub on Wells Rd. If in industry, where it is recommended in Health and Safety regulations that workers are not continually exposed to noises louder than 90 decibels during their day, exposure at 97 decibels would be strictly limited to around an hour or so and/or ear protection issued. If we are to have a truly better quality of life we need to get far away from industrial standards on our streets.
The Bristol City Council website states that the council 'do not have legal powers to deal with...traffic...noise' (or noise from aircraft, or rowdy behaviour for that matter). But there are things that could be done eg on quieter roads surfaces, better road maintainance, and crucially traffic reduction and weight limits.
Noise pollution issues should be heard much more on the political agenda. Noise has become another form of urban blight which we need to quell. It causes behavioural changes such as inducing irritability and annoyance, boosts stress levels and nervous disorders eg through disturbing relaxation and sleep. Noisier areas tend to have higher incidence of taking pills for blood pressure, stomach complaints, tranquillisers and sleeping pills. Noise also causes 'acoustic fatigue' in buildings, resulting in stress cracks and damage.
Noise is certainly a significant factor in Bristolians' list of quality of life concerns, but the powers-that-be have so far refused to treat it with urgency or give it the seriousness it deserves. Unlike the UK capital, which has had the London Noise Strategy for a few years now - the first in the country - Bristol has no noise management strategy or action plan yet, according to the city council website.
London's strategy contains some 100 policies designed to tackle ‘ambient’ or ‘environmental’ noise in buildings as well as from traffic, aircraft and other sources. Its a very good model to follow for Bristol.
In view of the forecast population and traffic increase in Bristol over the coming years, it is particularly important that we address noise pollution - in many respects the forgotten pollutant - effectively, now.