I'm with Jonathan on this one - the preceding discussion has shown a wide
range of views, and given that developers should (rightly) expect a level
playing field across the country, a wide range of views is perhaps not
acceptable. It also leads to uncertainty amongst ourselves, and individuals
(rightly) worrying about liability and appearing in court. We all need to
be singing from the same hymn-sheet. From my fresh (naive?) point of view
guidance can only come from the top, but if we don't let "them" know, how
(apart from through the hard-work of the SCLC) can we expect our concerns to
From: Jonathan Parr [mailto:[log in to unmask]]
Sent: 21 October 2005 11:50
To: [log in to unmask]
Subject: Re: PPS23 and Residential Developments
But surely the only way to make ourselves heard is to shout form the
I do think we undervalue our opnions and power (we do after all drive Part
IIA and try our damndest to improve quality of work in our areas), and maybe
we should all (that is all 400+ of us!) should bulk email ODPM with our
concerns, our issues and what we think needs doing.
Now im not saying its possible, but one email sent by someone from the list
and supported by every CLO in the UK should at least make them sit up and
pay attention. The Planning Inspector is up to them to sort out!!!
Look, I know I live in a hypothetical dream world sometimes; as Steve says
the Standing Conference is very busily and successfully lobbying on our
behalf; but maybe its time we added our voice as a majority to this lobbying
and began to make people listen to us as we all have the same concerns!!!
We all know that stopping kids shooting up with smack and supporting single
parent families (all worthy causes I may add) take precedence with every LA
in the country; and apart from some of the more proactive Council's out
there (usually those in large conurbations) land contamination isn't seen as
important. What we need to do as a body politic is begin to make everyone
aware of how important this issue is and even more, how important getting it
assessed correctly is! Would you want your health checked by a fully
qualified doctor or by some bloke who is a mate of a mate?! (unless of
course he is a fully qualified Doctor!!!) Whilst SILC status aims to
achieve this, and is excellent and I hope to one day achieve it for myself;
it doesn't do anything to stop the awful work we see being handed in by the
smaller Consultancies and the lack of knowledge and appreciation of the
issues by, probably, the majority of Developers. One example I have is of a
Consultant assuring his Client PAH's were not an issue as they were only
phytotoxins! Quite apart from the fact anything can be toxic to humans (too
much H20, air, pie's!) this Consultant was quite serious in what he said; I
mean come on!!!
And another issue I have come across is Developers handing in preliminary SI
work and a GQRA using Dutch/USEPA as screening levels to fulfil a planning
condition on a contaminated site that needs a DQRA! Now I dont want to tar
all small consultancies and developers with the same brush as there are some
excellent ones out there who are striving to improve, but we al know it goes
on and it needs to be stopped!
At the core of the work we do; first and foremost is Public Protection, and
that is how we should approach the job. If a developer doesn't like the
approach and decides to do a development somewhere else where the Planning
Policy isn't so rigidly stuck too, then the only person who gains is the
developer with his profit margins; certainly not the people who live in the
development that blows up!!! To me what this calls for is a countrywide
adoption of a policy that all us CLO's can put to DC and say this is how it
is/should/will be done across the UK; if not the liability lies with you!
And I know I bang on about liability but I have worked in LA's for too long
and seen too much to not have learnt that one of the most important things
is covering my own back!!!
Anyway; at the end of the day I am up for the challenge; is anyone else?!
Rant over lol!!!!
From: Guppy, Steve [mailto:[log in to unmask]]
Sent: 21 October 2005 11:16
To: [log in to unmask]
Subject: Re: PPS23 and Residential Developments
This forum and my thread have demonstrated once again that this might often
feel like a lonely task, but there's plenty of others out there dealing with
the same old problems every day.
The general consensus is that we should require a desk-study with all new
residential developments. Pragmatism has lost to fear of liability and that
would seem a sensible result if your heads on the block. Many, of you,
including myself have probably experienced sites with significant
contamination issues which were only brought to light by a good desk-study.
In most cases a desk-study I had to fight for too. However, planners do
seem generally reluctant to take this approach for whatever reason, and I
think we have a responsibility to raise awareness and ensure that workable,
PPS23 compliant policies are adopted at local level. This is not just
training at planninjg officer level but suitable briefings to the
mangers/directors responsible for making the decisions and allocating
sufficient resource. Lets not forget the spirit of the guidance; it's there
to promote environmental improvement not an epidemic of sloppy shoulder
syndrome. The planners rely on the opinion of the inspectorate who will
apply the usual planning condition tests of reasonable, necessary etc under
the circular and in my experience this means they expect a desk-study only
where contamination is already suspected. An approach not generally
supported by those writing to this thread (and apparently not in the spirit
of PPS23). So, if we want to make our planners more aware someone needs to
approach the inspectorate as well? Something beyond our remit.
A few of you indicated that the wholesale application of such a condition
could not be managed within their office. I do sympathise. The phase II's
currently sitting in my in-tray are probably sufficient to balance the
city's carbon dioxide emissions! But if the desk study's weren't so poor we
wouldn't have to spend hours holding developers hands. PPS23 clearly
indicates what is required of a desk-study. Awareness amongst developers and
those that supply information is required and without the support of our
planners that's a thankless task.
I'm not trying to make the situation sound all doom and gloom. I'm sure the
situation can be improved and those out there with an opinion can help.
Should we not be asking for additional guidance for PPS23, a national
training/awareness programme for planners and the inspectorate and an
industry standard for e-reports? Something that the standing conference
might want to add to their already packed schedule.
Senior Scientific Officer
Southampton City Council
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