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Friday, 15 September 2017

CCTV issues still unresolved

1. We still do not have a clear method for proposing and getting approval for new CCTV cameras or indeed getting existing cameras moved

2. BANES commercialisation programme is not delivering investment where it is needed or as quickly as it is needed

3. The police contribute little or nothing

4. Residents and businesses will not fundraise or sponsor without:

o   Getting a say in how the network is managed

o   Getting a convincing explanation about why the police don’t contribute

o   Without public bodies taking responsibility for ongoing costs

5. The PCC appears to suggest that the police regard CCTV as a “nice to have” while officers on the ground, and common observation, say it is increasing essential. She still not explain how she is planning to address residents’ concerns without CCTV
6. BANES has failed to get agreement to link Network Rail's CCTV at and around the station




Friday, 8 September 2017

"Putting residents first" in practice

BANES should be customer/resident focussed in the way it operates but too often it is not.

The frontline staff often lack authority to act and there are often too many layers of management between them and decision makers.

Resident impact ought to be an early consideration for any project plan or policy creation discussion but to often impact on residents and residential amenity is only addressed when complaints and criticisms arise. By this stage electors are unhappy and the cost of resolving any issues will be high.

Some parts of BANES and some officers are much better at customer service than others but there appears to be no effective process for spreading or rewarding best practice consistently.

This has allowed a culture to develop in to many areas where instead of looking for ways in which to address residents' issue officers fall back on using regulations and custom and practice to find reasons  for not confronting problems or being creative,




Tuesday, 5 September 2017

Policing and Enforcement

We think that strengthening and improving local policing teams should be a priority because funding reductions and decision by senior people in Avon and Somerset have weaken local policing teams and connections between police and the communities they serve.
We agree with the PCC that ensuring Avon and Somerset Constabulary have the right people, right equipment and right culture should be a priority but would note that while CCTV is increasingly important in effective policing Avon and Somerset invest little or nothing in the network.
The Police working effectively with other agencies should be a priority but it appears to us that there is little coordination or pooling of funding with local government enforcement teams and that while the PCC took control of a number of BANES budgets including public protection there is little sign that this money has been spent in improving policing or public safety in BANES. 

There are a number of ways in which the police and environmental protection service can use the powers of the Anti Social Behaviour, Crime and Policing Act 2014 for instance in relation to aggressive begging and party houses but they need support from residents in the form of formal complaints and evidence gathering and there has been too little investment in improving or even publicising reporting systems. The use of any of these provisions requires close cooperation between various BANEs enforcement departments and the Police. However, we are now concerned that this may be undermined by manpower reductions in the policing of Bath and in particular the Anti Social Behaviour Unit. We now appear to be more reliant on BANES officers and the BID wardens in addressing anti-social behaviour than we are on the Police.

Sunday, 3 September 2017

The Poor Quality of BANES consultations

With a few notable exceptions BANES public consultations have been of very poor quality. Some of the recurrent problems are:
  1. Poorly designed questions
  2. Poorly structure questionnaires
  3. Poor presented background information and poorly researched information leading to poorly informed responses
  4. An over reliance on questionnaires
  5. A failure to use more deliberative processes
  6. A focus on consulting groups generating negative publicity
  7. A over reliance on self selecting respondents over more representative sampling
This has led to a whole series of confused, badly informed decisions and an over emphasis on vociferous minorities over wider public opinion.

We need our politicians to get a grip on this by:
  1. Getting better expert advice
  2. Learning from their own best practice
  3. Engaging with a broader range of organisation while designing consultations

Thursday, 31 August 2017

Pollution and political inertia

Politicians don’t like dealing with traffic management issues because they always find themselves between a rock and a hard place because they must try to balance the desire to reduce traffic with the fact that the economic vitality of their constituency is linked to people coming to the area. This is particularly true of Bath as a major tourism and shopping destination.

In practice, there are only really two strategies for reducing the number of vehicles coming to the area:
·         creating a barrier to entry either physical or economic and/or

·         creating a public transport system that people prefer to cars.
From a political perspective, the former is a problem because it creates howls of protest and threats from the business community and commuters and can rapidly create real economic harm if managed badly. The latter is difficult, expensive and takes a very long time to implement. Both these strategies, but particularly the public transport option, are hampered by considerable legislative confusion.
For these reasons politicians tend to do very little and as we have seen with the saga of the eastern park and ride even that can be derailed by the slightest resistance by special interest groups however small. We have also seen how local politicians of all colours use such situations to gain narrow political advantage.
TARA’s priority has always been the reduction of pollution not because we are entirely indifferent to congestion but because we are much more concerned about damage to peoples’ health.
Unfortunately, because their advisors have always had to tell them that the only way to reduce pollution is to reduce traffic politicians have been as reluctant to deal with pollution as they have with congestion.
Over the last few years this has begun to change. It is now possible, in policy terms, to see pollution and congestion as two separate problems. Euro emissions standards and the recognition of the disproportionate contribution of diesel engines means it is now possible to conceive of relatively low pollution levels from large numbers of vehicles in relatively short timescales. So, for instance, if you banned diesel cars from George Street and forced the bus companies to upgrade their fleet you would more than halve the pollution levels. Banning diesel cars would be relatively pain free politically, legislation is already been discussed, and BANEs are already moving to implement a CAZ which would force an upgrade in the bus fleet.
TARA is therefore focussing on getting BANES to do things to reduce pollution in the short term and are seeking to get the business lobby to support our campaign. This means that we are not pushing to arbitrarily ban traffic from the city but are pushing for measures which will encourage the adoption of new low pollution technologies and discourage older more polluting technologies.
There is one other area of vehicle generated pollution which needs to be addressed and minimised and that is braking. This is particularly important for the very dangerous 2.5 particulates. Clearly this can be addressed by reducing congestion but in lieu of any political enthusiasm for doing this the next best thing to do is manage the vehicles coming into the city to reduce the amount of driving and in particular stop-start driving they do in the city centre. We are therefore campaigning to have better coordinated and fewer traffic lights and better signposted off street car parking with a more realistic assessment of the amount of off street planning required.






Sunday, 27 August 2017

Failure to adequately control building development in the city centre

Recent problems with major  developments in the city centre highlight systemic problems in the way permission for significant development in the city centre is given and the way in which compliance is monitored and enforced.

In granting planning permission much more attention needs to be paid to the likely impact on the local community and conditions and guidelines put in place to minimise them.

BANEs needs to be much more proactive in monitoring and enforcing conditions and BANEs officers should be routinely talking to neighbours about their experiences and encouraging developers to do the same not just waiting for them to register complaints.

We are facing over the next few years unprecedented numbers of development projects in the city centre and it is vital that BANEs gets better and managing them in a way which minimises disruption to communities and ensures that they are fully informed about what is going on.

Thursday, 24 August 2017

The ongoing issue of Party Houses

We in the city centre have be grappling with the very many issues created by the operation of short term holiday lets and in particular "party house" for several years and TARA has been involved in a number of discussions and activities aimed at ameliorating this problem. Latterly various political interests and pressure groups have recognised the issue so it seems and appropriate moment summarise TARA's view of the current "state of play"

Two years ago, we successfully lobbied the council to review the legal advice to their planning officers in the light of Appeal Court Judgements which allow them to view this type of letting a “change of use” requiring planning permission and opening the owner to a more stringent set of regulations and potentially a requirement to pay business rates.

The appeal court said that whether the use of a dwelling for commercial holiday lettings amounts to a material change of use is a question of fact and degree in each case and the answer depends on the particular characteristics of their use as holiday accommodation. The courts have taken a very narrow view of what characteristics are relevant and have demanded a very high standard of proof.

In the intervening period BANEs have occasionally been able to make use of this judgement and enforce change of use but in most instances, the applicants have successfully argued that they fall outside the criteria required to enforce an application for change use.

The most recent use of this mechanism has received some publicity mainly because a number local politicians have raised objections to the change of use being granted. This represents a gamble on their part which might effectively block the use of this device in future because if change of use is refused the applicants have already indicated that they will appeal saying that change of use is not required  and this might well create an unhelpful precedent. However, if change of use is granted they will continue to trade but be subject to a more stringent regulatory regime.

What is really needed to address this problem is action by central government. However, this year the City Centre Action Group got our then MP to raise a question in the House of Commons about whether Minsters intended to do anything to improve or even clarify the law in this area and the answer was that they don’t.


Local authorities across the country have tried a number of approaches to this issue most of which have collapsed under legal challenge. BANE's have recently indicated that they are considering adopting procedures developed by Brighton involving mechanisms for promoting better cross agency collaboration and voluntary codes of conduct backed by the local hotelier's organisations. We will be interested in seeing BIGHA's response to this as the preponderance of Bath party houses appear to be operated by their members. 



We welcome the initiative taken by the Avon Fire Service to invite holiday property proprietors to voluntary training and awareness session about fire safety.



We are also asking the police and local authority rigorously apply the provisions of the Anti Social Behaviour, Crime and Police Act 2014.



There are a number of ways in which the police and environmental protection service can use the powers of the Anti Social Behaviour, Crime and Policing Act 2014 to make landlords more responsible for the behaviour of tenants and their property management practices but they need support from residents in the form of formal complaints and evidence gathering. 


The use of any of these provisions requires close cooperation between various BANEs enforcement departments and the Police. Some years ago, we used the Community Trigger Provisions of the Act to accelerate this. However, we are now concerned that this may be undermined by manpower reductions in the policing of Bath and in particular the Anti Social Behaviour Unit.

In the meantime we are urging affected residents’ to complain regularly to BANES Environmental Protection Team who can be reached via Council Connect. It is really important that there is a body of officially recorded complaints that can be referred to in any enforcement proceedings