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OBJECTION ON BEHALF OF

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									                               OBJECTION

      ON BEHALF OF ASHTON VALE HERITAGE
                    GROUP


           PLANNING APPLICATION NUMBERS

             09/02242/F (Bristol City Council)
          09/P/1061/F (North Somerset Council).

           BRISTOL CITY FOOTBALL STADIUM
                    ASHTON VALE

Ashton Vale Heritage Group object to the application submitted to Bristol City
Council for the following reasons:


   1. Poor performance under the Transport Assessment

   2. Concerns about the Flood alleviation mitigation

   3. Damage to the Ecology and SNCI and Wildlife Network

   4. Contravention of Green Belt Policy Regulations

   5. Contamination from the former land fill at Ashton Vale

   6. Loss of Historical and important Landscape

   7. Harm to the local community by damaging the environment where people
      reside

   8. Lack of Community Involvement




                                        1
Transport Assessment:

From the outset there have been serious concerns about the viability of the current
highways ability to cope with the additional transport demand generated by the proposed
football stadium. We have serious doubts about the impact of traffic and the apparent
lack of parking and public transport.

Ashton Vale Heritage Group commissioned an independent Transport Assessment
which significantly undermines the assessment undertaken the Bristol City Football Club
Proposal.

So fundamental to the application is the Transport Assessment that this independent
assessment calls into question whether the applicant‟s proposal can be taken any further
at this stage.

We ask that this independent report is considered urgently by a senior transport
assessor at the earliest opportunity to ensure that a more accurate estimation of the
projected traffic flow and junction use is submitted by the applicant.

The Supporter Travel Survey undertaken was poorly executed and therefore, the results
of the survey appeared to be adjusted to reflect the transport impact of the proposed
stadium in a more positive light.

A gross underestimation has been made regarding the number of car trips that will be
generated by the proposed stadium on a matchday. The actual number of cars on the
local road network and searching for a car parking space will be 4,971 (rather than the
1,411 cars quoted in the Transport Assessment). This results in an on-street parking
impact of 3,921 cars (instead of the previously quoted 361 required on-street spaces).

This gross underestimation has also filtered through to the junction assessments
resulting in incorrect traffic flows being used. The more realistic trip generation figures
quoted in this document would render the junctions and links surrounding the proposed
stadium inoperable.




                                            2
Flood Alleviation:

Local knowledge and experience cannot be underestimated when assessing the
potential harm from flood risk. At a DEFRA Conference in 2008, „story telling‟ was
acknowledged as important in sharing fields of experience with communities. It
advocated communication based on „mutual respect or humility, valuing practical
knowledge and recorded experiences. It was felt that this collaborative approach would
assist analysis and decision making in the future when considering areas of potential
risk.

Ashton Vale residents have documented, photographed and made video recordings of
flooding which has occurred over the last forty years which demonstrates the
unsuitability for large scale development, particularly housing and leisure facilities.

There is a wealth of evidence and research available which documents the projections of
climate change and flood risk in the future. There is clear advice against continued
development on active flood plain.

In a Draft document, Sustainable and Urban Regeneration Executive - Draft (10 April
2001) it states that “ A clear statement that building, in functional flood plains, where
excess water flows and is held at times of flood, should be wholly exceptional - and
limited to essential infrastructure that has to be there”.

It is hard to argue that the Stadium is an essential structure and even more difficult to
argue that a hotel, fast food restaurant and houses are also essential, their main
purpose is to financially bolster the application which would appear not be financially
viable without the additional developments.

In December 2008, flooding occurred in Ashton Vale fields after one night of heavy rain.
Due to the excessive rain in August 2008, the land was already waterlogged and one
night of rain overwhelmed the drains, ditches and culverts. The flood water did not
recede for several months, so much so, that in January and February 2009 local people
used ice skates to skate on the frozen impromptu lakes.

This flooding covered four fields and saturated the sedge beds; water in the drains
remained high for several months. Since the 1980‟s Ashton Vale fields have flooded
each winter and during the summer when there has been heavy rain. There has been
some alleviation by the drains around the perimeter of the fields, but in recent years
these have become inundated and are often to capacity, which leads to the fields
flooding. This happens throughout the winter months and sometimes during heavy
rainfall in summer. In August 2008, the fields were saturated after exceptionally heavy
rain during the month. Presumably this led to the fields becoming inundated again in
December. In the main the impromptu lakes have been an attractive addition to the
landscape, attracting an array of birds to feed and bathe, but the frequency this occurs is
increasing and very worrying.

Recently In July 2009, heavy rain has again led to flooding in the field and to Colliters
Brook being breached in several areas and flooding to local garages. The brook is just
ten feet from some gardens and homes. The water levels rose very quickly and the
stream became very dangerous and deep with fast running water.



                                            3
A Department of Environment Circular 30/92 (2.4.28) provides guidance on taking into
account flood risk issues in planning decisions. It sets out the Government‟s aim for
Local Planning Authorities to use their powers to guide development away from areas
affected by flooding and to restrict development that would increase the risk of
flooding. It suggests that new developments should not lead to danger to life, damage
to property and wasteful expenditure on works as a result of flooding.

The flooding in Tewksbury in 2007 accounted for fourteen people losing their lives. The
flooding which occurs in Ashton Vale fields has increased since the development of the
landfill during the 1980‟s, with run off water going into the fields, Longmoor Brook and
Colliters Brook. It is inconceivable to consider that a development on this scale will not
increase the risk of flooding and we have little faith in the mitigation being proposed as
from experience developers are willing to build on flood plain.

“Climate change is the greatest environmental challenge facing the world today. Rising
global temperatures will bring changes in weather patterns, rising sea levels and
increased frequency and intensity of extreme weather. The effects will be felt in the UK;
internationally there may be severe problems for people in regions that are particularly
vulnerable.” Defra (July 2009)
In July 2007 hundreds of houses flooded after being built on a flood plain and heavy rain
caused a surge of water from local rivers. Residents were given some refuge in an
Oxford Football Stadium after homes were deluged when local brooks and rivers peaked
after several days of heavy rain. At the same time, homes built on known flood plain in
Tewksbury also flooded with some householders being unable to occupy their homes for
up to two years afterwards. Despite all the advice to the contrary developers built houses
on the flood plain, Civil Engineers continue to believe that they can control the elements
and mitigate against such disasters and members of the public continue to purchase
them.
Despite civil engineering assurances at the planning and developing stage, nothing
protected the housing developments from serious flooding. Many parts of the area did
not have power restored for weeks and in some parts for several months. Contaminated
water was a serious problem and there were problems with supplying the area with
sufficient clean drinking water. Despite this, the current proposal is seeking permission
to build 243 houses in the exact area where flooding has regularly occurred over the last
thirty years.

A report written in the Observer (2000) stated “a growing body of scientific evidence,
culminating in a detailed European Commission report, suggests the effects in Britain of
global warming will mean more sustained bursts of intense rainfall.”

The Environment Agency (EA), claims four million new homes are likely to be built by
2016, it is estimated that a quarter are zoned in active flood plains. Observer
Sunday (5.11.2000) yet in 2007 The Pitt Review, commissioned following extensive
flooding in Tewksbury and other areas around the country recommended “Wherever
possible, new developments should not take place in flood risk areas and there should
be a strong presumption against building on the flood plain.

Residents of Ashton Vale who have knowledge of the area and the behavior of the water
courses do not have confidence in Civil Engineers who assert that water courses can be



                                            4
managed, flood risk mitigated and tides, rivers and streams monitored. You may feel
that a tidal pond will alleviate any potential flood risk, but you will be wrong.

The Ashton Vale flood plain acts as alleviation to the River Avon. Should there be any
tidal surges; water is pushed back along the waterways and brooks, protecting parts of
the city from flooding. If the water course is undermined then it risks potential flooding in
Ashton Vale and elsewhere. If you consider the knowledge and experience of residents
who know the area well, you will reject this proposal on the basis of the serious
likelihood of future, regular flooding to both existing homes and land and to new
developments.

Reservoir No 3 – Barrow Gurney

Ashton Vale is the designated flood inundation area in the event of a serious breach of
reservoir No 3 at Barrow Gurney. The reservoir was developed in the 18th Century and
is subject to constant reviews and remedial work. Ashton Vale and the surrounding area
would be deluged with over 1 million tons of water should it breach. The Secretary of
State for Environment, Food and Rural Affairs, stated in the House of Commons in 2007
that: “On reservoir safety, we will now go ahead to prepare flood maps for reservoirs
coming under the Reservoirs Act 1975, and to ensure that where these are not already
available, they are provided to local emergency planners before the end of 2009. They
will decide the best way to ensure that communities are informed. We will also
modernise reservoir safety legislation”.

We may have become complacent about the risk of inundation but in 1984 the 1,250m
long Carsington Earth fill Dam in Derbyshire collapsed during construction, the reason
for the collapse was never fully published.

In June 2007 The Ulley Earth fill Dam near Rotherham nearly collapsed during torrential
rain the problem was thought to be a defective spillway. This resulted in the evacuation
of hundreds of people from three villages. It is important that we do not underestimate
the potential risk associated with large scale development and the impact they have on
flood plains.

In July 2009 there was a potential “risk of failure” of Renfrewshire Dam in Scotland after
two days of heavy rain which compromised the dam leading SEPA, (Scottish
Environmental Protection Agency) to issue a flood warning and prepare to evacuate
residents.




                                             5
Wildlife Network and Green Corridor Site of Nature Conservation Interest

Ashton Vale Heritage Group opposes this application due to the negative impact it will
have on the Wildlife Network, SNCI and Wildlife Corridor at Ashton Vale.

We believe that this area at Ashton Vale qualifies for special consideration due to the
diversity of the wildlife, flora and fauna and the special ecological features which have
naturally developed there.

Ashton Vale is biodiversity rich, has been studied by many ecological groups and by the
developers own admission is host to an abundant range of visiting birds and wildlife,
including, peregrine falcons, buzzards, snipe, reed bunting, owls, bats, deer, badgers,
newts, dragon and damsel flies, together with habitats including reed beds, grasses,
sedge, hedges, waterways and streams. There are signs that Otters are using the area.
The UK Biodiversity Plan (2008) states the importance of maintaining the otter
population. Brought to almost total extinction during the 1950-170‟ they have started to
breed again and it is the intention to restore breeding otters to all catchment areas where
they have been recorded since the 1960‟s. Ashton Vale fields could become one of
these important areas.

Reed and Sedge beds are a priority for protecting and enhancing the Reed Bunting
population and Reed and Sedge beds are protected under UK BAP policy. The prospect
of tearing up the sedge beds in order to replace them, would destroy the existing wildlife
and habitat for these important species.

The area has sections of sedge beds which act as a sponge and also filters the water as
it passes through effectively cleansing the water from pollution already being produced
in the area from present local businesses such as the car auctions site and roads etc.

It is also home to many different grasses and reeds together with hedges and a vast
variety of plant life which in turn supports different varieties of butterflies/moths and
dragon and damsel flies. The local brooks have very clear water and we are aware that
the Environment Agency were considering introducing the Cray Fish into these waters,
but this has been put on hold due to the possibility of development work.

The Bristol Plan (1997) recognizes that there is a need to “conserve the environment
and protect local amenity will override development concerns, for example in specially
protected areas such as nature conservation sites or in sensitive locations such as
residential areas.

Despite the developer‟s assurance that wildlife will be treated sensitively and
sympathetically, residents have no such confidence, especially following the destruction
of important hedgerow in September 2008, just weeks after the developer became the
new owner of the fields and contravening the Hedgerow Regulations (1997). Hedgerow
is important in providing food source for up to 150 species and the destruction of the
hedgerow undermined the wildlife in Ashton Vale destroying nesting habitats, fox and
badger habitats essential feeding and protection areas for birds, field mice, water vole
and grass snakes and provides a feeding corridor for bats.




                                            6
Set away from main roads and co-existing with the community the wildlife has flourished
here. Tucked into the bottom of the valley and sitting alongside an active natural flood
plane has made this area a site of Important Nature Conservation Interest.

The developer asserts that they will remove the existing wildlife from the area, but plans
to reduce it in size to just 25% of the current value. The assumption that wildlife will
return to this habitat, once it has consistent noise, light pollution and traffic is at best
optimistic and misleading and at worse a total fantasy. The current wildlife area will be
dominated by a 110 foot structure which equates to a block of flats eleven stories high
along with 243 houses, a drive through fast food and retail outlets and other planning
applications for as yet undetermined building. Add in Rapid Transit bus routes and you
begin to see that the reality of preserving or retaining wildlife is very unlikely.

The BCFC Ecology report also recognises the importance and diverse wildlife
present and states: “4.12 Importantly, much of the northern and eastern parts of the
core site are Identified as a Bristol Wildlife Network Site. Network Sites are areas
identified By Bristol City Council as important corridors for wildlife. All SNCIs, for
example Ashton Vale Fields SNCI, are also included as part of the wildlife network,
meaning that much of the core of the study area is a Bristol Wildlife Network Site. Bristol
Local Plan policy NE6 would be relevant to network sites”.

The wildlife network and biodiversity in Ashton Vale has taken over 40 years to evolve
but could be destroyed within days if this application is granted.

At a consultation meeting for the Bristol and Bath Railway Path Consultation (January
2009) Mrs. Jan Walters, Conservation Officer warned of the dangerous precedent which
might be set if there was loss of land within an SNCI. At this meeting there was also
considerable discussion about the importance of preserving the hedgerow. Yet this
same destruction is proposed for this area, which in addition to being an SNCI has also
been described as the Lungs of Bristol and is a recognised Wildlife Corridor.

If you consider the Bristol Plan (1997) amended in 2003 to be a workable and
knowledgeable document based on sound ecological practice you will have no
alternative but to reject this proposal if only because of the damage it will cause to the
environment.




                                             7
Green Belt Policy

Our reasons for objecting to this planning application in its entirety are based on a sound
policy review and environmental concerns.

2.1.1 By controlling the location, type, scale and design of development, land-use
planning has a major determining influence over the quality of the local environment
(Bristol Plan 1997)).

According the UK Land Registry (2009) only 12% of land in the UK is now retained
under Green Belt, yet more and more Green Belt is being handed over for development.
Tony Blair, former Prime Minister, Gordon Brown, Present Prime Minister and our Bristol
Liberal Democrat Council have all said that Green Belt should be protected from
development, but all have then been instrumental in handing over large swathes of it to
developers.

In order to deliver these developments, alteration is required to Bristol‟s Green Belt
boundary at Ashton Vale. The PPG2 clearly justifies the retention of Green Belt land
when it fulfils the purposes of Green Belt. Ashton Vale Green Belt currently fulfils the
purposes of Green Belt land.

Further, we draw your attention to the Strategic Green Belt Review (Buchanan‟s, 2007)
which is referenced in both the draft South West Regional Spatial Strategy and the
Secretary of State‟s Proposed Changes to the Draft Regional Spatial Strategy. The
Strategic Green Belt Review concludes that a more rigorous approach is required in
order to withstand examination and justify any Green Belt alterations. In particular, it is
stated that; there is no rationale for any alteration at Ashton Vale.

Green Belt alterations that do not pay due regard to PPG2 and supporting technical
documents namely the Strategic Green Belt Review [Buchanans 2007]

The five purposes of including land in Green Belts are set out within PPG2 as:
    To check the unrestricted sprawl of large built-up areas;
    To prevent neighbouring towns from merging into one another;
    To assist in safeguarding the countryside from encroachment;
    To preserve the setting and special character of historic towns; and
    To assist in urban regeneration, by encouraging the recycling of derelict and
       other urban land.

The Green Belt at Ashton Vale has been in place for over forty years fulfils four of the
five of these purposes; checking unrestricted sprawl, preventing neighboring towns from
merging into one another (namely the urban areas on the borders of Bristol and North
Somerset), safeguarding the countryside from encroachment and assisting in urban
regeneration. A key issue is the risk of Bristol and North Somerset borders becoming
blurred and the City of Bristol merging with the villages of Long Ashton and Backwell. In
addition, the release of the Green Belt land could undermine the opportunity to develop
brownfield sites and thereby the potential to regenerate other areas within the urban
areas of Bristol and North Somerset and maintain Bristol‟s role as a „core city‟.




                                            8
A structure the size and magnitude of the proposed stadium (height 34 meters) cannot
reasonably be described in any way as enhancing the natural environment or
contributing to the biodiversity of the local area. The proposal by the developer does not
give a detailed and analytical rationale for reasons the current stadium cannot be
developed and modernised. Further more it does not give a detailed account of the
requirements of FIFA in order to host a World Cup game and so it is not possible from
the application to assess whether or not the current stadium at Ashton Gate could, with
development and financial investment be brought up to the required FIFA standard.

Further more the application does not give a sufficiently detailed account of why other
sites were both chosen for consideration or discarded. In order to demonstrate that an
alternative site is not suitable there must be a more detailed account of the criteria it was
being assessed against. Presumably there was a scoring of audit system for both
choosing sites for consideration and for discounting them, but this needs to be reflected
more clearly in the planning application. Simply applying that the alternative sites were
“not suitable or not available” is not a sufficiently detailed account of the reason why
some sites were both chosen for consideration or why once chosen they were deemed
unsuitable.

An additional site at Hengrove Park has been considered on a previous occasion and
was discounted due to traffic congestion. We do not understand why Ashton Vale a
small residential area could possibly be considered a suitable alternative.




                                             9
It is our assertion that it has not been adequately demonstrated in this application that
the current location of Bristol City Football Stadium cannot be re-developed to meet
modern standards. We further believe that alternative sites have not been fully explored
as potential opportunities.

Very special circumstances are required in order to allow development on Green Belt
and it must be demonstrated that these circumstances outweigh the harm to the Green
Belt. It is an important departure from the adopted policy. Ashton Vale Heritage Group
does not believe that it has been proven that very special circumstances have been
demonstrated.




                                           10
Harm to the environment: Local conditions and distinctiveness.


A development of this scale and size, together with regular matches, concerts and other
events will swamp this small residential area.

Many people reading about Ashton Vale will think that the stadium will be in local fields
and away from residents, but they will be wrong. This is in the heart of the community.
Thousands of people will walk and try to park in these roads. Some people might feel it
is justified as an „out of town‟ area, but of course it is not, its in the heart of Ashton Vale
and if the houses proposed are built, it will be in the middle of two residential areas and
totally unsuitable.

The scale and size of the building will dominate the community, in more ways that just
visually. Ashton Vale will lose its identity and become known for whatever crowd control
problems arise, whatever crime becomes associated with football, will be associated
with Ashton Vale. It‟s a stigma we don‟t want.

For generations, Ashton Vale Fields have been an important part of our community.
Natural green fields on the urban edge of the city. Within just a few minutes from any
part of Ashton Vale you can feel that you are in the middle of the countryside.

Beautiful views of the Suspension Bridge, Observatory, Ashton Court and Long Ashton
Church can be seen in a panoramic view. The bells chiming at the Church can be heard
quite clearly and gives that sense of village life, the area has in effect been our „village
green„.

Balloonists have used these fields for a very long time and skim over Ashton Vale when
the wind is not strong enough to elevate them quickly enough from their take off from
Ashton Court. As children many of us have helped pack away balloons which have not
quite made it to their destination.

Picnics have been enjoyed around the three large oak trees and families enjoy Sunday
strolls, taking their dogs for a walk or fishing in the many waterways in the area.
Children fly kites; pick blackberries in the open space or ice skate on the frozen flood
plain in cold winter months. Children and adults have learnt so much from this small
area of natural space and that is why so many people have stayed here all their lives
and why their own children have also settled here.

It has been stated that “access to good quality green space can have a beneficial effect
on the reduction of stress”. Julia Thrift, Journal of Mental Health (2005)

These fields help to support and are part of the whole Biodiversity system and in this
small area there are so many of the species and plant life supported by the newly
adopted Bristol Biodiversity Action Plan. From red list birds, badgers, roe deer, foxes
with their cubs, water vole and hedgehogs to reed beds, grasses, rushes, sedge and
fruit and berry bushes which make up the hedgerows, some of which were sadly
vandalised and destroyed by contractors at the end of summer this year.

Ashton Vale is a unique community, where third and fourth generation families reside.
This is an area which has low crime, a good mix of private and social housing, respects


                                             11
its older residents and where many families have been brought up in Ashton vale, settled
and raised families and is now grandparents for their own families. It‟s a stable
consistent community.

It has endured so many assaults from developers over the years and yet has remained
constant and retained its village atmosphere. Because you can only enter Ashton Vale
under a bride or over a bridge, people who come here only come for a purpose, to visit
family, or to go to the local trading estate for work.

It has also endured the three landfills developed nearby. Ashton Vale will be destroyed
if this development is permitted. It will lose its distinctive community network and
become under siege, not just on match days bit once the stadium is used as an arena,
which will be often.

At a time when so many communities are struggling, coping with drugs, unemployment,
rising crime, Ashton Vale is an area which should be held up as a successful community.
Employment is high, families live near each other and share in child care, enabling
people to work, older adults are assisted to stay in their own homes because their
families are in hand to assist with caring. It is a cradle to grave community. There are so
few of these communities left that they should be nurtured and protected.

The local school is easy to walk to and is completely integrated with the community. The
bus route is just a five minute walk from any house. So rather than take a huge risk on
altering and potentially damaging not only the wildlife but also the community the Council
should be looking at why this community works and how they can emulate it in other
parts of the city.

The Lancet (Nov 2008) reported a correlation between good health and access to
natural green space and nature, especially for deprived families. At a time when natural
green space is so important to health and wellbeing we are confronted with a planning
application, which has not only increased stress and anxiety in the community, but
potentially deprives the community of much valued open fields and space to breath and
is an important factor in promoting a healthier lifestyle, promote social inclusion, society
and wellness which improves the sickness/health ratio in communities.

The Bristol Plan (1997) – amended 2003 Section ME2 0- Development –
States clearly that: “Development which has an unacceptable impact on the
environmental amenity or wildlife of the surrounding area by reason of fumes, odour,
dust or other forms of air, land or water pollution will not be permitted”. Bristol Plan (1997
– ME2)

We consider that Ashton Vale comes into this category and that the proposed
development for Ashton Vale is wholly inappropriate as it includes all the above impacts.

During the development stage, residents, who are a predominantly older adult age
group, followed by young families, would have to endure constant and prolonged noise,
dust, pollution from light, fumes and exposure to potential hazards contained I the landfill
which will be unleashed. In addition there will be heavy plant machinery entering the site
from different directions, including over the small single lane bridge and under the small
single lane railway arch. There has already been a considerable increase in traffic in
Ashton Vale with the regenerated interest in South Liberty Lane Trading Estate.


                                             12
Residents have also had to endure prolonged housing development in the area for the
last four years whilst prefabricated houses were replaced. There is currently a significant
development in Ashton Vale with the building of houses and flats and this has already
had an impact on the roads and houses are often very dirty and dusty as a result of plant
machinery. This machinery is present on all work days giving little respite. To have to
endure a further two years of constant construction in the area, particularly on this scale
would have a significant impact on residents.

There is no current timescale for the completion of the developments, already, although
unspecified the developer has stated there are additional pockets of land which they
intend to apply for permission to develop within the area, although details of this are yet
to emerge. One of the problems with a hybrid application, where both planning
permission and outline planning permission are sought is that land is divided up and
once precedence has been given for development on one part other developments soon
follow.

Once the development is complete, residents will rarely have any time when the area is
not full of visitors, for either football matches or other events. With all types of events,
bring police, helicopters, increased traffic, noise and light pollution. The flood lighting
during evening matches will be seen for miles and will have a direct negative impact on
local residents. The back up of traffic leaving the various sites will cause considerable
congestion and disruption.

It may be envisaged that residents will be issued with parking permits on match days,
but what about residents, family and friends visiting. Are they to be excluded from
visiting friends and family on match days? What about professionals, visiting, doctors,
district nurses and care providers. This is a predominantly older adult community and
health service personnel are present often.

What about normal deliveries, people who are working have to have appliances
delivered at weekends, how will this be accommodated. How many residents‟ permits
will be provided per household? Will they be free of charge and how will this be
monitored. All of these issues infringe on the liberties residents have taken for granted.

The adopted Bristol Plan states:

Quality of Life – to recognise and act upon local, national and global environmental
issues by adopting and implementing a long term environmental strategy to ensure a
cleaner, greener, healthier and safer city both for present and future generations. Bristol
Plan (1997)

To protect and enhance Bristol‟s important green open spaces including its wildlife
habitats and network of green corridors, recreational and amenity spaces, and historic
landscapes and parks, balanced with the need for development.


Ashton Vale Fields are Ashton Vale‟s last remaining natural area and open space for
the whole community. The community has had to endure many landfill sites in past
years, with the Yanley landfill only just coming to an end.




                                            13
Due to the fields being largely a flat area, it makes them accessible to all ages and
abilities and if promoted could act as the Bedminster/Southville Ward‟s natural green
space. It is very important that communities have access to natural space to ensure
wellbeing. The area can be used by groups and schools. Loss of the Green Belt and
natural green space would have a devastating impact on the community. According to
the Parks and Green Spaces strategy our natural green space is envisaged as being
within an 18 minute walk.

Looking at the suggested maps in the Strategy document, Ashton Vale‟s natural green
space would be accessed via a trading estate and across or under railway track/bridge,
this area, near Bedminster Down is mostly uphill, not so accessible and very secluded,
We would not feel safe using this area alone or for our children to play freely. Estimated
time to walk to Ashton Court would be is 35-45 minutes and to enter Ashton Court, it is
all up hill. Loss of this natural area would be against the current strategy and to the
detriment of residents.

In addition to the potential loss of green fields, we also oppose the planned housing
development on the former allotments. There is a long waiting list for allotments in
South Bristol and this area has been allowed to fall into disrepair by the Council whilst
many people waited to be allocated allotments. With the loss of more and more green
space, allotments are essential for people to have the opportunity to grow their own
food. With more and more green belt being sacrificed for development, this country will
be reliant for its food source from abroad. This is a poor legacy for future generations
who may well wonder how in less that one generation we managed to squander green
space which had been protected and preserved for generations




                                           14
Landscape at Ashton Vale:

The Landscape and Vista at Ashton Vale is unique and much valued by residents of
Ashton Vale and visitors to the city. The natural green space and open fields have been
an integral part of community life, hosting picnics, nature walks, dog walking and other
family activities, including fishing and den making. It provides a natural place for
children to play.

Many parts of Ashton Vale have uninterrupted views of the Suspension Bristol, Ashton
Court, Long Ashton Church and the surrounding hill overlooking Long Ashton. They
further have an outlook over open fields which enhance the environment. It is a
recognized fact that living near to open spaces and natural environments enhances
quality of life and contributes to a healthier life style.

“For every 10% increase in Green Space, there has been a reduction of health
complaints”. Dr Williams Bird - Natural Fit (2004).

The North Somerset Green Belt Scoping Report (June 2009) identifies the importance of
identifying and preserving important and historical landscapes and names Ashton Court
and Long Ashton Church, also described as a landmark building, as key historic
landscapes.

Ashton Vale is reported to perform well in meeting all five criteria for the retention of
green belt status, even taking into account the RSS and its recommendations. It
has been recognised as an area which should be protected from development on either
a small or large scale, acknowledging that even small scale development cumulatively
change the character of an area. The report recommends that areas of land within the
study area (Ashton Vale) that have had some development should be protected to
prevent further encroachment into the countryside.

Environment Assessment under Circular15/88 states: „the principles of environmental
assessment should be undertaken on all schemes, to weigh the costs and benefits of a
proposal. This should be done, ideally, not after a design and location has been chosen,
but as a pre-requisite to location and design choice”.

A stadium structure which dominates a previously open country space, cannot possibly
be sympathetic to the environment, however it is developed. Bristol City Football Club
wants this structure to be an iconic building, which will be lit up and will be seen on the
approach to Bristol.

Placed opposite the beautiful and prestigious Ashton Court, we cannot think of a greater
insult to the Ashton Court Estate. To have spent millions of pounds to restore the views
of Ashton Court and then have them ruined by this building is unthinkable.

The loss of this landscape and views can be considered as harmful to the environment
and well being of the residents of Ashton Vale. These views are special and important.
These landmarks are historical features of Bristol and contribute to the city‟s prominence
as a tourist attraction. To be deprived of this landscape will cause untold distress to
residents. “Walking is the most popular activity by both men and women with over 1/3 rd
of the population taking part regularly”. National Survey of Culture, Leisure and Sport
(2006)


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In the introduction to the Biodiversity Action Plan – For People for Wildlife, Helen
Holland, former leader BCC and Simon King President of the Avon Wildlife Trust state
that” everyone should have the chance to enjoy and benefit from nature, but biodiversity
is vulnerable to Habitat Loss, neglect, pollution, development and other pressures. We
have a responsibility to protect, conserve and enhance Bristol‟s precious diversity for the
benefit of Wildlife and People.

This statement appears to be in direct conflict with the proposed application, which will
negatively affect the biodiversity in Ashton Vale, unleash a closed landfill site and
expose the community and wildlife to levels of pollution and contamination which are
regarded as significant and create habitat loss for rare red listed birds and wildlife.

One of the roles of planners is to ensure that the management of the environment and
the quality of new development in the city is sustainable, conserves and reinforces
Bristol‟s attractive and varied environment, creates a positive image and identity for the
local area, enhances the quality of life for local residents.

Planning therefore is to ensure that any damage is kept to a minimum and within
acceptable limits. At the same time it is important to identify opportunities for improving
the environment through good design. Bristol Plan (1997), it is therefore is beyond
imagination to assert that this planning application will do anything to enhance the local
biodiversity, protect habitats or conserve and reinforce Bristol‟s attractive environment.

Many of the reasons expressed by people moving into Bristol are that they can reach the
countryside within minutes of leaving the city centre. Destroying the last piece of green
belt and open space in south Bristol will impact on everyone in South Bristol and the
surrounding area and bring about a loss of a much valued amenity.




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Land Fill Contamination

During the 1980‟s Ashton Vale Residents endured being surrounded by Landfill sites on
two sides of Ashton Vale. This caused incalculable distress to residents, some of whom
lived just twenty feet from the landfill and who were unable to either sell or rent their
houses as a result.

Despite this Bristol City Council continued to allow a licence. During this period Bristol
City Council did little to support or protects residents from the exposure of harmful waste
and illegal tipping and took little action to rectify complaints about breaches. It is not
surprising therefore to find that residents have little confidence in Bristol City Council
monitoring the development if passed and ensuring that contaminants contained within
the landfill will be monitored carefully.

The Land Contamination studies produced have raised a number of questions for
residents which to date have been unanswered.

“2.4.14 the potential risk of groundwater pollution will be a material consideration in
determining planning applications. The risk of pollution varies according to the type and
scale of development and the presence of any hazardous substances. Developments
involving contaminated or potentially contaminated land, various noxious industrial
developments and those which involve the storage of hazardous substances and the
building of major infrastructure work such as roads etc will be of particular concern.”

The risk is not always confined to the site itself. Toxic gases from landfill sites
For example can travel to surrounding land. Liquid pollution may also leach through soil
and underlying geology and contaminate groundwater supplies (see Policy ME5). Bristol
Plan (1997)

We have yet to be able to have a detailed debate on the presence of Radon Gas at the
site and how this will be managed.

The developer‟s proposals state that a significant pollution incident occurred on the
Landfill site. 41 M to the North side, ( 5.8 – page 23 of the application, however
residents have not been able to get advice about this incident as the only person
available to offer advice has been on leave during the period of consultation and no
other person was deemed to be available.

There is however much published about the instability of gas within Landfill sites and a
record of serious incidents between 1980 -1997 records a number of serious incidents,
including loss of life, from spontaneous landfill explosions.

For an explosion to occur there should be:
   1) A source of flammable gas.
   2) A confined or enclosed space.
   3) A source of ignition.
   4) Sufficient oxygen to support combustion.

A recent report suggested that migration of gases into structures posed an explosion risk
and that leakage from landfill sites into water courses could be harmful.



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5.65 - Page 23 discussed potential hazards if the landfill material were to be re-worked,
the proposal does state that the landfill waste will be contained within the site, but will
have to be opened/re worked to move it to a different area. We have concerns of the
potential hazard to health of the community if this was undertaken.

Additionally point 5.73 – which considers Gas Screening Value, has been classified as
CIRIA 3, but documented information in the proposal suggests this should have been
recorded at the higher CIRIA 5, but unfortunately at the time of submission of this
document we have been unable to have these queries answered.

The report also mentions that significant contamination arising from 'off site sources' was
considered to be high given the historical and current use? Again we have no
knowledge of the background to this and again we were unable to get a response by the
time of submission of this objection, but would wish to know what this information relates
to.

The report also refers to 'a potentially significantly high level of hydro carbon, which
appears to be large quantities of diesel or some other industrial contaminant. Without
further advice which was again not available to us, we have no way of knowing what
these values were, if they were within a safe and expected range and if this scale of
contaminant is safe. Finally, the report also notes that there was a significantly raised
ammonia cal nitrogen level, thought to be due to the degradation of organic matter. Our
understanding was that the Landfill site was licensed to contain only builders waste and
so it is surprising to find that there is such a high level of organic matter present.




                                            18
Non-conformity to Community involvement

Ashton Vale Heritage Group oppose this application due to:

Lack of conformity to Community Involvement requirements outlined in PPG11 and
PPG12;

Plans and proposals in the area of Ashton Vale are currently gathering momentum and
yet, the Ashton Vale Heritage Group has had limited consultation opportunities to input
our concerns about the way these plans and proposals are progressing and the
environmental and social impacts such major developments will have

Community Involvement means more than the provision of information and the invitation
to respond to consultation documents”. From the earliest stages of consultation Ashton
Vale residents have been excluded from consultation venues and invitations. On two
occasions it has been brought to Trimedia (Consultants acting on behalf of the
developers) attention that residents had only learned of consultation days through local
media. Given the potential impact on Ashton Vale Community it was felt it should have
an opportunity to be involved at the earliest opportunity. Although it was asserted by
Trimedia that over 11,000 letters of invitation had been sent and many of these had
been hand delivered to Ashton Vale, our survey showed that less than 35% of residents
had received a formal invitation letter. Some residents had received three letters and
many had received nothing. This was immediately brought to the attention of Trimedia
who doubted the validity of our complaint. However at the third consultation the same
problem occurred. A survey of residents again revealed many had received no
notification; some had received more than one notification.

When recent excavations surveys were carried out, some residents were informed by
letter, others received a letter three weeks after the work had been competed.

We have asked on several occasions if the consultation boards could be brought to
Ashton Vale Community Centre, but this had been declined, until we requested again
recently but could not be accommodated on the day we had secured a booking at the
hall.

It was considered that Bristol City Football Stadium was a suitable venue for
consultation, but we feel that as the most significant impact of this development affects
Ashton Vale Residents that more effort should have been made to include the
community. Valuable opportunities were lost for residents to understand the impact of
the development which can only be to the advantage of the developer. It has fallen to
Ashton Vale Heritage Group to keep the local neighbourhood advised of
developments.

We assert that the developers have fallen far short of true community involvement and
moreover have alienated the residents by ignoring requests for more involvement.

Whilst we appreciate that The Council Planning Department has involved two members
of the community in a meeting with developers, this was only offered once the
application had been submitted and therefore allows only very limited time to understand
the planning application or to comment on it. An opportunity to be involved much earlier
would have allowed residents to have made a contribution to the planning process more


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Meaningful.

Predetermination and Bias:

Bristol City Council has published its own comprehensive policy on Predetermination
and Bias. (Code of Conduct for Officers (2009)

Throughout the process of this proposal, there has been consistent and widespread
publicity which has often been generated from with Bristol City Council stating that the
Project must go ahead and planners should not prevent the stadium being built. News
reports suggest that anyone who is anti this project is both anti Bristol and anti football.

Ashton Vale Heritage has no alternative but to have faith in the planning process and to
hope that issues of predetermination and bias can be effectively managed and that
Officers will have the courage, if they feel this application does not warrant approval, to
reject it.


In summary:

The time scales provided to submit an objection on such a complex application,
especially for a group with little knowledge or experience of dealing with matters of this
magnitude has meant that some questions could not be answered in time by officers and
some research could not be applied without additional evidence.

We reserve the right to make further submissions as required until the close of
comments when the planning hearing is commenced.

Ashton Vale Heritage opposes this application, including the Stadium, housing
development, restaurants and houses on the allotments in its entirety.


Ashton Vale Heritage Group 4th August 2009.

For acknowledgement or reply please address to Ashton Vale Heritage Group email
mail@ashtonvaleheritage.co.uk.

August 2009




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