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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 be addressed. Jason. -----Original Message----- 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 rooftops! 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!!!! -----Original Message----- 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. Regards Stephen Guppy Senior Scientific Officer Environmental Services Southampton City Council * [log in to unmask] > This e-mail is intended for the addressee only. If you are not the intended recipient, please be aware that the unauthorised use or disclosure of the information it contains, or the unauthorised copying or re-transmission of the e-mail are strictly prohibited. Such action may result in legal proceedings. If the e-mail has been sent to you in error, please accept our apologies, advise the sender as soon as possible and then delete the message. Under the Freedom of Information Act 2000 / Data Protection Act 1998, the contents of this e-mail, whether it is marked confidential or otherwise, may be disclosed. No employee, Councillor or agent is authorised to conclude by e-mail any binding agreement with another party on behalf of Southampton City Council. 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