Issues of Health and Safety
A Scoping Report is written by developers in the pre-planning phase. It highlights areas of potential concern and states how these will be dealt with so as to achieve planning permission. It also seeks to `knock out’ issues which it states are not of concern.
The St William and Quod (planning consultancy) Scoping Report dated July 2020, describes some of the toxic elements in the soil and groundwater that were found in previous soil tests. The tests showed the presence of benzo(a)pyrene, lead and asbestos at high levels. Benzo(a)pyrene and asbestos are known to be carcinogenic (cause cancer) and according to the World Health Organisation there is no known 'safe' blood lead concentration; even blood lead concentrations as low as 5 µg/dL, may be associated with decreased intelligence in children, behavioral difficulties and learning problems. As lead exposure increases, the range and severity of symptoms and effects also increases. Ref: World Health Organisation, 2019
A Scoping Report dated July 2020, written by Quod, a planning consultancy, on behalf of St William, gives more grounds for concern as it describes some of the toxic elements in the soil and groundwater that were found in historic soil tests. These have remained in the soil since gas was produced on the site over 100 years ago. The report states that contaminated dust will become airborne during “remediation” and will fall on the surrounding area for up to 500 metres, which may be a conservative estimate, given how windy Brighton is. Link to Scoping Report here
St William do not plan to test the soil to fully understand all the dangers that these toxic elements pose before applying for planning permission, thereby concealing from Councillors the exact nature of the pollution that may be unleashed when they start excavating the foundations for tower-blocks. The Council is not currently requiring up to date tests to be done, despite what we all know about the dangers of air pollution and the responsibilities of councils to protect human and environmental health. At the moment the site is capped in concrete. Two gas holder tanks lie buried in the ground in the northern part of the site and one guide frame still stands where daily flocks of starlings gather.
The Scoping Report 2020 states that historic soil tests show the presence of asbestos, lead and benzo(a)pyrene at high levels. These tests were random and there may be other areas either more or less contaminated, or affected by other pollutants. The Report states that results from 2019 indicated that the groundwater contained concentrations of ammonium, sulphate, complex cyanide, iron, naphthalene and benzene which exceeded UK drinking water standards and that amounts of ammonium, chromium, zinc, aromatic hydrocarbons C5 to C7, C10 to C12, naphthalene and benzene exceeded Environmental Quality Standards for coastal waters in three or more samples.
This is bad enough but the proposed development risks releasing, and then spreading, even more toxic chemicals into the air, over the ground, and into the groundwater and the sea. Despite the work continuing for up to 8 years the toxic dust effects are described in the report only as "temporary". Although St William sought to eliminate or “Scope-Out” from their planning application matters of human health and odour (from toxic gases escaping from the ground) the Council has properly insisted that the developers must consider these points. Link to BHCC Scoping Opinion
WHY ABANDON THE COUNCIL’S CITY PLAN?
The Brighton Gasworks site was allocated for redevelopment under City Plan Policy DA2.C.2 to provide “...approximately 2,000 sqm of business floor space to the north of the site, a minimum of 85 residential units on the southern part of the site and some ancillary retail development.” It was expected that 30% of the homes would be allocated for affordable housing. However on adoption of the BHCC City Plan Part Two (CPP2), these policies may be replaced.
We think that this DA2 plan is good, and the best one for the site. High-rise buildings do NOT provide more homes. Instead, by building only 3-4 storey homes, disturbance of the toxic land may be avoided while at the same time providing sustainable, ecologically sound housing that is, Covid-safe, pleasant to live in, and fits in with the local architecture without blotting out the sun, causing wind-tunnels, or spoiling the landscape.
We are fearful that the Council might try to evade its responsibilities for human health and the environment in order to tick boxes on the numbers of new homes built. We must hold the Council to its promise to maintain its protective and precautionary regulatory role to keep us all safe, as it promised to do in the 2005 Local Plan, later adopted into City Plan 2 2016. This states:
"Planning permission will not be granted for the development of polluted land or land adjacent where the nature and extent of contamination is such that even with current methods of remediation the proposed development, people, animals and/or surrounding environment will be put at risk".
INCREASED STRAIN ON LOCAL SERVICES & INFRASTRUCTURE
Berkeley/St William's proposal is for 553 flats with only 160 parking spaces provided. Besides the threat to our health, to tourism and local business, this will also bring a large increase in traffic and put a strain on local GP services and schools, in addition to the pressures it will naturally place on already-stretched sanitation and parking.
LACK OF GENUINELY AFFORDABLE & SOCIAL HOUSING
St William has stated that the costs of remediating the site will be so high that no affordable housing provision will be possible. Yet the Council owns 2 areas of this site which it proposes to sell to the developers instead of using them to provide some form of affordable or social housing of its own. Therefore we fear that the development, as currently planned, will not provide affordable homes for any of Brighton’s residents.