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Wednesday, 8 January 2020

THE MINERAL HOSPITAL Planning Application 19/04933/FUL


The applicant seeks consent for change of use from hospital (D1) to a 169 bedroom hotel (C1) with ancillary uses including a restaurant/cafĂ© (A3).  The proposal appears, in general, to be consistent with the Council’s Core Strategy Plan (2014) and Placemaking Plan (2017) and we have no objection in principle to the change of use.
However, the proposed disposition of buildings on the site is a different matter. We contend that the application be REFUSED on the following grounds
  • It fails adequately to take into account the potential loss of amenity currently enjoyed by residents living in the area.
  • It fails to take the opportunity provided by the removal of one of Bath’s most cherished institutions to provide benefits to the wider community
  • It would result in the removal of mature trees which should be permitted in a Conservation Area in a city centre only under exceptional circumstances
  • It proposes an extension at the rear of the existing hospital building in an area which is currently a Scheduled Ancient Monument with un-resolved archaeological issues.
  • It relies for vehicular access on surrounding streets including Upper Borough Walls and Westgate Street where the council is evaluating major changes to traffic management and the use of road space which are, as we understand it, still under review.
Our particular concern relates to the extension which would be positioned at the rear of the existing Grade II listed hospital buildings.  We contend that this four-storey block is over-bearing, encroaches too close to residential buildings to the south and, though the term escapes precise definition, represents over-development of the site.  As a result, local residents are likely to be confronted by
  • Substantial loss of amenity including daylight and sunlight
  • Overviewing from hotel rooms (the applicant shows more concern about the view from hotel windows than from the windows of neighbouring homes and the suggested angled louvres proposed in mitigation seem entirely unconvincing).
  • Risk of noise and disturbance from hotel rooms
  • Light pollution from hotel rooms at night
To date there have well over eighty objections to the application, most relating to the loss of trees and of amenity at the rear of the property and many from among the eighteen households that are the immediate neighbours of the hospital to the south and east. The consultation process entered into by the applicant, comprehensive as it may in some respects have appeared, seems to us to have been flawed in that while most households were leafletted and informed about the public presentation of the proposals, there is no evidence that the applicant has responded positively to any of the concerns raised.  As the principal residents’ group in the area, TARA should arguably have been invited to participate in the consultation process but was not.  To this extent the applicant failed to take account of the interests of residents living adjacent to the site, contrary to policies D.6.a and D.6.b of the council’s Core Strategy and Placemaking Plan which state respectively:  
Development must…allow existing and proposed development to achieve appropriate levels of privacy, outlook and natural light
and
 ‘Development…must not cause significant harm to the amenities of existing or proposed occupiers of, or visitors to, residential or other sensitive premises by reason of loss of light, increased noise, smell, overlooking, traffic or other disturbances. 

We, therefore, contend that, unless it is withdrawn or reconsidered, the application as it stands should be REFUSED.  An alternative proposal which reduced the damaging impact of the proposals on local residents, particularly at the rear of the existing buildings, while providing a valuable resource to the wider community, funded if necessary by a Community Impact Levy, would be likely to receive the support of this association.

Saturday, 21 December 2019

The Bath City Forum

The Bath City Forum emerged out of a discussion about ways in which it might be possible to address the “Democratic Deficit” issue. This was the fact that although it is the largest town in BANES it did not have its own democratic forum unlike all the other towns in BANES and that it is represented by a relatively small number of councillors compared to its economic and cultural impact on BANES.

The discussion focused primarily on two scenarios based respectively on parish models or Winchester Committee model. The Bath City Forum, loosely based on the Winchester model was what ultimately emerged from this process.

The City Forum failed to deliver:

  1. It is perceived as undemocratic because of the appointment of 13 members selected by a largely opaque process using undisclosed selection criteria
  2. It has failed to achieve any significant level of public recognition
  3. It has failed to achieve any significant level of public participation or attendance
  4. It is widely perceived a talking shop which has failed to create any vision for Bath or identify solutions to its problems
  5. A number of public bodies have used the existence of the forum as an excuse to withdraw from other forms of public consultation and engagement
Alternatives for moving forwards seem to be:

  1. To go down the route of creating a Bath City/Parish Council
  2. Create a unique structure or structures to address the original problem but incorporating lessons learned from the failure of the Forum
  3. Reform the BANES council structures and processes to properly acknowledge the central role Bath plays in the economic and cultural success of BANES as whole 
From the point of view of Bath City centre residents, we would prefer BANES to go down the route of reforming BANES structures. However, if this is considered to be too radical we would support the creation of a Bath City/ Parish Council.

Wednesday, 4 December 2019

TARA's response to the proposed extension to the Abbey Footprint Hoardings

We are very concerned that this will result in serious constraints to pedestrian flow at a critical location at the height of the tourist season in 2020.

What is your modelling showing? Where do you think these pedestrian flows will go? What plans do you have for managing congestion at the site of the proposed hoarding and in areas affected by displacement?

Wednesday, 6 November 2019

In adequate assessment of fireworks on the Rec

We have just received the impact assessment for the fireworks display plan for the Rec.

We are disappointed to see that once again this document does not cover the environmental impact.

The impact assessment does not properly address the issues of environmental impact. Big fireworks displays always create a large spike in particulate pollution across the city and most concerningly a spike in the very dangerous PM 2.5 levels.

Saturday, 19 October 2019

TARA’s response to the CAZ consultation

Class D is the only option that even on the basis of the council’s own technical advice is likely to achieve a quick reduction in pollution levels. We would have expected a responsible council to want to stop poisoning people in the centre of Bath as quickly and as certainly as possible. We would also expect an administration that has declared a climate emergency would want to act as fast and effectively as possible in all areas of environmental management.

We welcome the inclusion of more of the city centre in the revised boundary and particularly the inclusion of the Pulteney Estate.

Whenever Queen Square has been partially closed in recent years it has displaced disruption and pollution elsewhere in the City. Spreading pollution over a wider area is not really pollution reduction it is playing with numbers. The disruption such schemes cause to residents and businesses in the city centre is always significant and this combined with the increases in pollution and disruption which will as ever, happen in the rat runs which will be exploited by drivers seeking to avoid Queen Square make this proposal unacceptable. Once again we are discussing ad hoc traffic management schemes in the absence of any vision or strategy for managing traffic in the city centre.

BANES have never managed to enforce current weight limits or most other motoring regulations such as the 20mph speed limit. What now makes you think you can enforce new ones? Have the police commented on this and to what effect? If the answer to these question involves extending the role of the proposed CAZ camera network to cover issues other than emission standards is this accounted for in the proposed budget?

A commitment to monitoring the scheme is essential to get residents’ to have any confidence in this watered-down proposal. We also need a commitment to the swift enhancement of the CAZ regulatory framework and boundaries if monitoring shows it is failing to meet its objectives in a timely fashion.

We also need assurances that current monitoring will be reviewed as many badly affected sites do not appear to be being monitored properly, for instance, key city centre canyons such as Broad Street. 

We would welcome any proposals to increase the capacity of the Park and Ride provision particularly to the east of the city.

We would welcome concrete proposals to improve the amount and affordability of public transport but remain unconvinced that what appear to be gimmicky advice services and apps can a be anything other than a minor and potential confusing diversion. 

Pedestrians and cyclists have very different needs particularly in dense urban contexts so please stop lumping them together in this sort of document.

Pollution in the city centre has been a scandal for more than a decade and for all that time people have been having their health damaged and their lives shortened. 

Politicians and pressure groups over this period have held numerous workshops, seminars and written countless papers. The few solutions which have got as far a the planning and feasibility assessment phase have been variously cancelled or watered down to the point of being ineffective often to appease some small but electorally significant group outside the city centre. 

If this council is really committed to environmental protection then they will put the proposed CAZ in place as soon as possible and be prepared to swiftly introduce tougher regulations if and when monitoring shows it is not meeting its objectives.
Once this is achieved we then need as a matter of urgency to address other forms of pollution, such as small participate as well as other sources of pollution.

Saturday, 28 September 2019

Supermarkets and the problems of the nighttime economy

One of the biggest issues in the management of drink fueled anti-social behaviour in Bath's nighttime economy is pre-loading. This is where drinkers buy and consume cheap alcohol prior to their night out. Often the symptoms of drunkenness from this practice only become apparent after they have been admitted to licenced premises when they have topped up.

Licensees often have, in addition, to deal with the problem of customers smuggling cheap alcohol into their premises which as well as fueling increased drunkenness hits their profits and therefore damages a sector of the Bath economy.

Latenight revellers can regularly be seen drinking alcohol in the streets and on public transport in defiance of laws and regulations. Little of this drink is supplied by clubs and bars who are strictly regulated and who's drinks are relatively expensive but it is readily available from supermarkets and off-licenses at very low prices.

In addition off-licences and supermarkets often offer multi-buy discount encouraging people to buy larger quantities than they may have intended. They also supply high strength drinks in pocket-sized containers.

Off-licenses and in particular supermarkets are in comparison very lightly regulated and under the current legislation, as interpreted by the licensing authority, hard for residents to object to or get conditions imposed on. They also fall outside the scope of the Cumulative Impact Policy.

Saturday, 21 September 2019

Council representation in city centre wards

It is widely known that due to the bizarre way in which BaNES is structured, of the fifty-nine Councillors in BaNES only twenty-six (44%) represent the fourteen wards that comprise the City of Bath.  Eleven Councillors, about one in five of the total, have Bristol Post Codes.

It is less well known, but apparently the case, that not a single Councillor with the possible exception of Sue Craig (Liberal Democrat, Kingsmead) whose address is not posted on the Council website, lives within in the area covered by the three main city-centre residents' associations, TARA, CARA and PERA which comprise the City Centre Action Group.  This area contains not only an unusually high resident population for a city centre but all of the city's main visitor attractions including the Roman Baths and Bath Spa, the iconic mainly 18th C. streets, terraces, crescents and squares, the city's main churches and museums, its commercial core and principal shopping centre.  It is a thriving community which underpins the BANES's economy as well as its global reputation.

Could such an imbalance in representation partly account for the sorry state of the heart of our city when compared with peer cities such as York and Chester which do not have the advantage of World Heritage Site status.  The physical infrastructure of our city-centre is way below current European standards and comments by visitors on its messiness and unkempt appearance are common in the media.  There is no police station or post office worthy of the name (Melksham and Wells have both).  Waste collection and litter removal have serious unresolved issues, traffic management is incoherent and air quality in many parts of the city centre below legal standards.

All of this underpins, the importance of having active local residents' groups to speak up for the interests of the city centre to the Council.  And there is no substitute for having your local Councillor as a neighbour as residents in communities such as Norton Radstock and Keynsham, who having ten Councillors between them.  The Bath City Centre Forum has entirely failed to address any of these issues.

The 'parishing' of the city has been discussed and although the process of achieving this might be lengthy and difficult it is one we would support.