BRISTOL’S GREEN[WASH] CREDENTIALS

Without a hint of irony Thursday’s Bristol Evening Post published another instalment in its increasing thick portfolio of promotional literature for Bristol City FC, this time about how important Bristol's "green credentials" might be in capturing the World Cup 2018 for England. A World Cup bid in which Bristol’s contribution so far consists of proposals for a superstore that will generate massive numbers of car journeys and the building of a new stadium, hotel, drive-thru restaurant, and 250+ houses on statutory Green Belt.

To heighten the hypocrisy, the article refers to Bristol's "green spaces" as being a major factor in boosting the city’s chances of becoming a host city and even illustrates the story with a photo of a green space, followed by a picture of the stadium.

It refers to FIFA's "green goal" campaign and then tells us that the greener England’s bid is the greater the chance of England being chosen to host the 2018 World Cup. It then goes on to talk about Bristol having a head start because of its “fine reputation on environmental issues”. An eclectic list of various areas where Bristol is perceived to be green ensues, before the obligatory quote from cheerleader in chief Stephen Wray:

"This is a key part of the England bid team's strategy to be ahead of the opposition. We are fortunate to have experts within the city and we are already setting new standards.”

And just in case anybody is in any doubt, the paper reminds us that “Bristol's bid hangs on the provision of a brand new stadium in Ashton Vale”.

It becomes blindingly obvious that the Evening Post and Stephen Wray have either not read the available documentation on the Green Goal programme or have simply failed to understand it. Either that or they are hoping that nobody else bothers to read it.

Let’s clarify what the Green Goal programme is and what it isn’t.

Firstly, what it isn’t. It isn’t about how many parks you have, it isn’t about how much recycling of domestic waste you do, it isn’t about how many wind turbines you have built in the city, it isn’t about how many people cycle or walk to work and it isn’t about how much of the city’s waste you send to landfill or incinerators. It isn’t even really about the level of carbon emissions per capita produced by the city – it is about the carbon emissions generated by the World Cup itself.

Green Goal is about the environmental impact of preparing for, and delivering, the World Cup. It seeks to reduce the environmental impact of the stadia themselves (construction has to be carbon neutral, materials should be recycled), the environmental effects of the usage of the stadia (carbon emissions from the stadium itself, water recycling, energy efficiency, reusable drinks and food containers) and of how fans travel to the stadia and to fan parks (minimisation of private cars, free public transport with matchday tickets).

By basing its World Cup Bid on the building of a brand new stadium on a green field site with a large amount of enabling development including a car-hungry superstore, Bristol is entering the campaign with a major handicap compared to those cities that will be extending or rebuilding existing stadia. Contrary to the Evening Post report, Bristol is already behind the game if the new stadium is, as proposed, built on green fields, and further handicapped if it is funded by the building of a giant superstore.

In Germany in 2006, only one stadium (Munich) was newly built on a new site and as a result its carbon emissions were, at 100,000 tonnes, twice as high as the next most carbon expensive stadium, and three times as high as the third. In addition another 60,000 tonnes of carbon emissions were produced constructing the car parking for the Munich stadium. As part of the Green Goal programme, the German World Cup Bid team had agreed to offset any net carbon emissions by paying for carbon offsets. Based on the 2006 financial figures, offsetting 160,000 tonnes of carbon emissions would have cost the organising committee close to £2 million. They could have reduced that risk to £380,000 simply by choosing a redeveloped stadium over a new stadium. Unfortunately for them, Munich is home to Germany’s most famous football club with a status in German football similar to that held by the Manchester area in England. They could not contemplate a World Cup without Munich, as England could not without Manchester, and thus they had to work hard to find other means to reduce the climate impact of the tournament. Bristol, on the other hand, holds no such status in English football – the easy option would be to drop the lame duck.

The Green Goal programme has four main themes; Waste, Water, Energy, and Transport which all together are targeted to provide a Carbon Neutral World Cup. As we have limited space lets look at Energy.

Energy

The Sustainability Statement for the proposed new stadium at Ashton Vale calculates that its annual energy consumption will be in the region of 2,200 mWh and that it will emit 694 tonnes of carbon emissions per year after its proposed completion in 2012/13 as a 30,000 seater stadium. The architects proudly boast that its passive design technologies and highest levels of energy efficiency will see an 11% reduction in energy use from standard stadia.

Sounds good until you realise that the Green Goal programme was published back 2004 and set a target of a 20% reduction in energy use for World Cup stadiums, which means that the Ashton Vale stadium would need to reduce its emissions by another nine percentage points to meat targets that were considered attainable 6 years ago, equivalent to an 80% increase in the level of anticipated reduced carbon emissions. In addition, the figures for energy use and carbon emissions are for a 30,000 seat stadium whereas the stadium will need to have its capacity boosted by 40% to host World Cup games, with a related increase in energy use and carbon emissions.

During his recent tax-payers funded trip to Hannover, presumably Stephen Wray visited the city’s World Cup stadium – if so, he would have had the opportunity to see the District Combined Heat and Power (CHP) system used in the stadium to improve energy efficiency, an innovation that is especially significant as District CHP is currently being promoted by his employer Bristol City Council as making a major contribution to its Climate Change Policies for the Development Framework that will guide Bristol’s future development. District CHP could have a major impact on the energy efficiency of a new stadium, despite this the Sustainability Statement for the proposed stadium at Ashton Vale says “it is not proposed to install a district energy system at this stage of design”

To avoid carbon emissions altogether Renewable Energy was also a key component of the Green Goal programme for 2006. Several stadiums had photovoltaic plants installed with the Kaiserlautern stadium seeing the largest plant ever installed in a German stadium, covering three of its stands (an area of 6,000 sq m) and generating 720,000 kWh of electricity per year, enough for 200 detached houses and eliminating 500 tonnes of CO2 emissions per annum. Furthermore Kaiserlautern municipal council used the Green Goal initiative as an exemplar model for the installation of photovoltaic plants on public and industrial buildings as well as on private houses – as of 2008, 4,300 mWh of electricity was being produced by photovoltaic plants with associated carbon emission reductions of 2,600 tonnes per annum. Despite this, Kaiserlautern did not consider entering itself for the title of European Green Capital.

As for Bristol City’s proposed stadium? “Renewable energy technologies have not been incorporated into the building design at this stage”

Meanwhile we haven’t even touched upon the energy produced in running an 110,000 square foot superstore. A 30,000 seat football stadium is quite an act to follow but a supermarket is in a different class. The proposed stadium’s 2,200 mWh per year is easily surpassed by the 4,800 mWh per year that would be produced by the size of superstore proposed for Ashton Gate (based on figures from the Royal Commission on Environmental Pollution).

Carbon Neutrality

Germany aimed to be carbon neutral for 2006 – they missed their target by 92,000 tonnes of CO2 equivalent. If just one stadium, Munich the only newly built venue, had not been selected, they would have hit their target. England’s World Cup Bid team will be aware of that, as a result those stadiums which are newly built and thus bring with them the largest carbon emissions are those most likely to hear the words “thanks, but no thanks”, especially if their efforts at energy efficiency and use of renewable energy technologies are, umm, outdated.

Bristol does indeed have a high level of expertise in environmental technologies – as normal they are being totally ignored with the result that if, indeed, green credentials are as important to the England World Cup bid as the Evening Post says it is – Bristol is in the process of entering a bid that will make England’s bid less likely to be successful.

To use another sporting analogy – if the race to become World Cup Hosts is like the Epsom Derby, Bristol look like they are about to offer a carthorse as their entry.

Three graphs that tell a story.

1) Where the new Tesco expects its customers to come from;

2) Where those who have signed the No petition live;

3) Where those who have signed the Yes petition live;

It would seem that those who are supposed to “benefit” from the new store are the ones that least want it, whilst those who are outside the catchment area of the store and thus not expected to “benefit” from it are those most in favour. Or could there be another reason why so many people from North Bristol and South Gloucestershire have signed in support of a supermarket in Ashton Gate?

Ashton Gate and subjective objectivity

Are Trimedia deliberately misrepresenting the results of the public consultation over the proposed Tesco at Ashton Gate or is it just a problem of lack of objectivity?

Trimedia are the PR Agency and Communications Consultancy who prepared the Community Involvement Statement (CIS) for the proposed Redevelopment of Ashton Gate Stadium on behalf of Ashton Gate Limited, the stadium owners.

In the CIS, mention is made of over 160 completed feedback forms and representations from the public. On Page 7 of the CIS, Trimedia provide a Summary of Feedback, which “considers the responses provided to each question on the feedback forms.”

The first question on the form was not about the proposal for a superstore at all, it was a leading question about supporting Bristol City’s ambition for a new stadium, and thus part of the ongoing effort by Bristol City to encourage the public and councillors to think of the separate applications for Ashton Vale and Ashton Gate as if they were one application. The second question (and the first about the development itself) was;

Q2 What are your views on the proposal to develop a food store on the existing Ashton Gate site?

In the CIS, Trimedia summarise the responses as follows;

A range of views and opinions were submitted on the proposals to develop a food store on the existing Ashton Gate stadium site. On the 153 feedback forms received, 375 separate comments looking at various aspects for the proposal were noted. Where there were clear themes, they have been grouped into headings below.

Of these, 18% of comments submitted expressed concern about or opposition to a food store on the site, and felt there was no need for this amenity in the area. This equates to the comment being made on approximately 40% of forms submitted.

After reading the above I was left a little confused, did they mean that 18% of respondents were concerned about a food store, or did they mean that 40% of respondents were concerned about various aspects of the development of which 18% were concerned about a food store? Or did they mean something else entirely?

Luckily, the feedback forms have been scanned onto the Bristol City Council online planning portal – so I decided to look at the feedback forms myself and do my own analysis.

This proved a little more difficult than anticipated – several of the feedback forms have been copied twice, and a few have attached sheets with additional comments. One or two have also only had only part of the feedback form scanned in. In the end, I managed to collate information on 151 feedback forms, with the following result;

63% of the forms objected to the proposal to build a food store at Ashton Gate.
10% of the forms, apart from those above, included comments that might be taken as objections to the proposals but either needed clarification or were associated with other comments on the same form that might be taken as supporting the proposal. Some example quotes;

"Bound to affect other stores and local shops"
"Not sure about needing another food store so near to Asda, Sainsburys and Aldi"
"I am not sure we need another supermarket"
"concerned over additional noise and traffic"
"24 hour opening must not be permitted"
"Worried that there are already lots of retail outlets and also the impact it will make on small shops in the area. Don't think it should be 24hrs"
"[prefer] new stadium on the same site"
"it will surely impact on Sainsbury, Aldi and the shops in North Street"
"Do we need another supermarket in the area?"
"Housing is needed [more] than a retail store"

9% of the forms supported a food store but expressed reservations or conditions;

"we have no objections to a store, however we would not like 24hr opening hours or 24hrs delivery
"I am in favour of a food store providing traffic concerns are solved"
"I am not opposed but concerned about 24 hour noise"
"We are happy for the food store to be built provided the new link road from the A38 to the A370 is in place, there is currently far too much traffic on Winterstoke and increased volumes would bring it to a standstill"
No objections "if provision for residents parking can be accommodated"
"I don't like the thought of a petrol station close to a residential area"
"I am concerned that your proposals show delivery vehicles/plant is situated right behind the gardens of residents like myself in Raynes Road"
"fine provided the local residents are happy with it"

Finally, 18% were fully supportive of a food store. The graph below summarises the result.

So we find ourselves in a situation where Trimedia’s analysis of the feedback forms would appear to indicate that at least 60% of respondents have no objections to the store whilst only 18% of comments were against it - whereas my own analysis shows that only 18% of respondents are fully supportive and over 60% of respondents are against the superstore. An interesting comparison!

This difference in the results of the analysis could be due to subjectivity – I have made no secret of my opposition to the superstore proposal and it may well be that, despite my best intentions, I may have allowed a certain bias to colour my reading of the comments – although it is quite hard to misinterpret the phrase “No Tesco at any cost” scrawled all over a form! Equally, Trimedia have been employed by those in favour of the proposal and may similarly be predisposed to interpret the feedback forms as being in favour of the development.

This is why we need independent and unbiased analysis of the facts – not just for comments on feedback forms in a consultation process but also for transport assessments, retail studies, environmental impact assessments, economic studies and so on. Only in this context can we have some confidence that the data is not being manipulated in some way (either consciously or sub-consciously) to fit a pre-determined conclusion. Studies funded directly by the developers themselves are unlikely to be objective. I am sure that those behind the proposal for a superstore would be unhappy if the only reports used to determine the application were based on my own efforts, because I am sure that however much I tried I would be unable to completely eliminate any element of bias against the proposal. Yet, at present, we are in a situation where the opposite is allowed – with most of the reports being used to assess the suitability of the application being provided by those with a financial incentive for supporting the application.

I would anticipate that the councillors who will be asked to make the decision regarding planning permission are unlikely to read each and every feedback form – and thus they will base their decision on the assumption that Trimedia’s conclusion that 60% of local residents held no objections to a superstore at Ashton Gate is accurate. In my view, however, Trimedia's conclusion is simply not supported by the evidence, which in fact demonstrates almost the complete opposite with over 60% of respondents to the consultation process voicing opposition to the proposed superstore.


NOTE: The feedback forms are available online here, so anybody else with a few hours to spare can trawl through the forms and make up their own minds about what percentage of respondents are for or against the superstore proposal.

Sympathy for the Devil

On Saturday, Bristol City beat Crystal Palace 1-0 however the game has made the headlines nationally for a "goal" that wasn't given. A Palace shot hit the stanchion at the back of the net and shot straight back out again - this deceived the match officials who failed to award the goal. Ian Bone, on his blog, wondered if this was the hand of Bansky but, other, less forgiving views have taken hold, with the Palace chairman and several national newspapers being less than charitable and calling Bristol City cheats.

Bristol City and its fans now find themselves besieged from all sides. The press have come out in favour of the other side, providing plenty of column inches to anybody who wants to pour scorn on the Robins. Even the refereeing boss, Keith Hackett, who is supposed to take an even-handed approach and wait for the referee's report, pre-empted the normal process by apologising to the Palace manager. Bristol City meanwhile point out that their players were just doing their job and playing to the referee's whistle.

Meanwhile they ponder how different the reaction was a few years ago when the Manchester United goalkeeper Roy Carroll pulled a ball back over the line and the referee failed to award the goal. Bristol City might point out that none of their players behaved in the way that Carroll did, yet there were no similar outcries at that time in the press for the match to be replayed - it seems there is one rule for the small guys like City and another for the giant corporations of the Premier League.

At this point, Bristol City fans must be wondering if there is anybody who can empathise with their situation.

They might not have to look far: there is another group who have done nothing wrong, have merely tried to get on with their jobs and abide by the rules but now find themselves in the position of being the small guys battling against a giant corporation whilst the press runs a massive media campaign against them and even those who they hoped would take a balanced view already seem to be pre-empting any decision by making supportive comments in the press.

Somehow however, I doubt if Steve Lansdown and Gary Johnson will be contacting BERATE to say "I know just how you feel!"

INSULTATIONS: How to win funds and alienate people.

As part of their plans to build a new football stadium and associated enabling development, Bristol City Football Club and their partners say that they have delivered 23,000 letters of invitations to local residents and key stakeholders inviting them to consultation events - in response they received 250 feedback forms over the three stages of the consultation process. In the first stage of this consultation process, 11,000 letters of invitations were sent to local residents regarding exhibitions of the proposals, and the events were also advertised in local libraries, community centres and the media – 450 attended the events and feedback forms were distributed, of which 104 were returned along with 20 responses by phone.

At this first stage and only at this stage was the question asked “What are your thoughts on the idea of the provision for a new stadium for Bristol City Football Club, in south Bristol? Note that the question does not ask specifically about a stadium in Ashton Vale nor a stadium on Green Belt land, merely about the concept of a stadium in south Bristol (see Framing)

Analysis of the 124 responses showed that 46% (about 57 respondents) were in favour of the new stadium, another 15% were generally in favour of a new stadium but had concerns about the proposed location (they obviously chose to interpret the question more precisely than the questioner may have wanted them to). Another 11% were against and 28% were undecided.

In other words just 124 people out of 11,000 felt that it was worth responding to the consultation, and of those only 57 people were potentially in favour of the new stadium in its proposed location. Nevertheless the 124 responses are seen by the developers as evidence that “the level of involvement in the consultation has been high throughout the process, and residents of the areas nearest to the site have contributed at all three stages” whilst the 57 people who were in favour of the new stadium in the (loosely specified) location “indicates that there are high levels of support for the proposal”. (Statement of Community Involvement)

In the meantime, in a separate but related development proposal, Tesco PLC are looking to put forward a proposal for a superstore on land that they don’t own; the Ashton Gate stadium that Bristol City FC will vacate if the new stadium is approved. In response, concerned local residents set up a campaign group – BERATE – and a paper-based petition that has attracted more than 600 signatures against the proposal. After canvassing houses around the stadium site and getting an overwhelming response against the proposals, the local Green Party councillor set up an e-petition against the superstore proposal in support of BERATE; this has now been signed to date by over 730 people of whom the vast majority live in the Bedminster or Southville wards. A counter e-petition in support of the superstore proposal, set up by a football fan living in Knowle has attracted some 70 signatures so far with only a dozen identifying themselves as residents of Bedminster and Southville.

One suspects that whilst 57 people out of 11,000 is seen as “high levels of support” for the new stadium, over a thousand against the separate superstore proposal will be labelled as unrepresentative of the local community rather than “high levels of opposition” to the superstore.

This anticipation of the developer’s response is not entirely speculation. Back in 2006, concerned about the level of bad press it was receiving, Tesco launched its “good neighbour” policy promising more community consultation when proposing new stores. But when asked what would happen if the consultation response was that a new store wasn’t wanted, Sir Terry Leahy (Tesco CEO) responded that the company would have to seek out the "silent majority" who would be in favour. In other words, the community response was only valid if it was in favour of a new store, otherwise it was unrepresentative.

The above highlights one of the fundamental flaws of the public consultation process for a specific development; by the time the developer has reached the stage where they are ready to look at consulting the public they have already decided that the development is valid: thus the question asked in the consultation process is “what modifications might you suggest for our development?” whereas the question that the petition signatories want to answer (both for and against) is “do you want this development at all?

In Bristol there is of course a structure intended to guide developers as to what sort of developments would be appropriate or acceptable to the local community – a structure that, in theory, has been created by a process of consultation with the local community. This structure is the Local Plan and consists of a series of policies covering various aspects of the potential development of the Bristol area, which have been informed by a series of expert studies and public consultations. It “provides the statutory basis for decisions on land use and development in the city” (Helen Holland, Executive Member, Environment, Transport and Leisure).

The Local Plan includes the following policies ;

S1 Protection of Shopping Facilities – which emphasises the importance of existing shopping centres and the need to sustain and enhance their vitality and viability.
S7 Local shops – which emphasises the need to restrict retail development outside of existing shopping centres if it may harm the level of shopping service provided.
S9 Out of Centre shopping – which says that the development of new retail stores outside existing centres will only be permitted where it will not affect the vitality and viability of existing centres, and
L8 Sports Stadia – which says that existing sports stadia, including Ashton Gate, will be protected from development which would erode the community’s opportunity to participate in sport and will be promoted as sports stadia.

If the Local Plan is intended to guide what type of development is put forward, at the other end of the Planning process is the Development Control Committees (DCCs) which are intended to ensure that planning applications for development are consistent with planning guidelines including the Local Plan. DCCs are made up of elected councillors who are expected to make unbiased decisions about whether complex or contentious planning applications should be Granted or Refused planning permission. For the Ashton Gate area this is the Development Control (South and East) Committee. Since June 2006, this committee has considered 105 planning applications. Of those 105 Planning Applications, Planning Officers have recommended refusal of just 10 applications. Planning Officers recommended that permission be granted on 86 occasions and the committee has refused permission against officer advice on just 7 of those 86 occasions. The conclusion has to be that, on the main, councillors serving on the Development Control (South and East) Committee generally rely upon the recommendations of the City Council’s Planning Officers who themselves are likely to be in favour of a planning application by the time it arrives at committee level..

Planning Officers are also tasked with doing their best to ensure that developments are successfully brought forward and implemented successfully. At an early stage, a developer will contact the Planning Officers to discuss a proposal, and from that stage a symbiotic relationship is established in which both developer and Planning Officer are looking to ensure the development proceeds smoothly to a successful approval of a planning application, along with any S.106 funding associated with the development.

Not only is the Planning Officer judge (they provide most of the expert opinion used to develop the local plan to guide the planning process) and jury (they provide the expert opinions on which DCC members base their decisions), they are also the lawyer advising one of the litigants essentially on a “no win – no fee” basis. Win the case (achieve planning permission), win the funds (S.106).

What of the other litigant? By this we mean the local community – who represents them?

Bristol City Council’s Code of Conduct for Members and Officers - Planning Matters includes the following statement;

“The aim of the planning process is to control development in the public interest”

The public interest obviously includes the views of the local community so the local community is represented by Councillors and Planning Officers – but as Councillors tend to follow the recommendations of Planning Officers, this means that the local community is effectively represented by the Planning Officers. Not only are the Planning Officers the judge, jury, and representing the other side, they’re also representing you, but in your case they are doing it pro bono – it is not hard to imagine a conflict of interest and also a conflict of client priorities.

The Code of Conduct continues;

“The role of members and officers in the planning process is to make planning decisions openly, impartially and with sound judgement for justifiable planning reasons.”

“When this code applies – to all members of the development control committees and officers at all times when they are involved in the planning process”

At this point it is worth noting that planning process also includes any discussion at the “pre-application stage”. In other words, as soon as a potential developer discusses proposals with the planning officer regarding a specific site the code applies and the officer is required to be open and impartial.

How does this work out in practice?

The first that the general public knew of the proposal for a new superstore at Ashton Gate was when it was leaked on 29th April on the Bristol Blogger website, but it has become apparent that Planning Officers knew of this proposal some considerable time before this, possibly in November/December of the previous year. There was thus a time-period of several months when it could be argued that Planning Officers were not operating in an “impartial and open” manner within the planning process because no attempt was made to inform the general public of the proposal for a Tesco superstore at Ashton Gate.

If the aim of the planning process is to control development in the public interest and members and officers are required to make decisions openly and impartially throughout the planning process, including the pre-application stage, then the only way to conform to this is to ensure that the general public are kept abreast of all meetings as they take place. It cannot be open and impartial to engage in discussions with one side of the process (the developer) whilst failing to inform the other side (the local community) that these discussions are even taking place.

It is bad enough that Planning Officers are both judge and jury AND the lawyer representing each side but to then find out that the lawyer whom you assumed was representing your views had been having regular face-to-face meetings for several months with the opposite side to help them build their case without your knowledge whilst you had to rely on a brief note from a third party to let you know that there is even a case against you does not meet the criteria of impartiality and openness.

Consultation on the planning process appears designed to insult our intelligence - it might help Planning Officers to win funding for required infrastructure but, in doing so, it is likely to alienate the very communities whose interests it is supposed to be representing.