Pedestrianisation may have a role but is not THE solution to the problems of the city centre

A number of politicians, pressure groups and officials have talked about pedestrianising all or part of the city centre. We have a number of concerns about this:

1. We doubt that BANES have well a founded traffic management scheme which can avoid considerable disruption and chaos if the is extensive experimentation with pedestrianisation. The traffic management in the city centre is poor even under normal circumstances and perioding closures of sides of Queen Square do not inspire confidence.

2. Any pedestrianisation scheme needs to be part of a carefully thought through traffic plan for the whole of the city centre to avoid unintended consequences elsewhere in the city. We have yet to see such a scheme. This traffic management plan needs to encompass more than just traditional traffic issues and in addition cover the range of things address by the late lamented Public Realm and Movement Strategy.

3. Pedestrianisation will create numerous problems for city centre residents ranging from loss of parking to problems with access. A large number of people live in the city and nobody seems to accord them and their needs any priority in pedestrianisation experiments or longer-term schemes.

4. Most importantly this whole debate seems to be starting from the wrong end. We should be talking about how to improve the city centre for all those who live, work and visit. Pedestrianisation may well have a role to play in these plans but it cannot and should not be seen as an end in itself.

It has been suggested that pedestrianisation is the magic bullet to improve air quality in the city centre. TARA has a long history of fighting to get improvements in air quality and this has shown us that the issue is much more complex than this and those advocating extensive pedestrianisation need to acknowledge this or we will fail to have the result that we would all wish to see. This is particularly true if we move from our current focus on NOX to the much more dangerous small particulate pollution.

We currently, for the first time, have a relative well funded project involving outside experts looking at pollution issues undertaking measurements and building models against which to evaluate potential approaches to improving air quality and we think the output of this work should be the starting point rather that simply espousing any particular solutions ahead of evaluating their data.

The need for national legislation

For a number of issues facing Bath residents, we are have reached the point where they can no longer be addressed entirely by local agencies and need action at national level.

Pavement Parking

Pavement parking is a big problem in the city centre causing considerable concern to people with mobility issues and causing considerable damage to paving stone which is unsightly, dangerous and expensive to put right and we need:

·         Legislation on pavement parking

Licensing

Licenced premises and their effective management are an important issue in Bath City centre, and indeed most urban centres in BANES. There are many problems with the current Licensing Acts which we outlined in our submission to the house of Lords Review and we need:

·         A review of the licencing law following up on the review by the House of Lords and in particular removing the artificial barriers between licensing and planning

Short term letting

Short term holiday and party lets can course major problems for neighbouring residents, are not subject to the same regulation or taxation regimes of other more conventional providers of holiday accommodation such as hotels and B&Bs.

Internet companies such as Air B&B are considerably increasing this type of letting and whole neighbourhood are being blighted by the worse tenants and most irresponsible landlords.

Local authorities are struggling to find legislation which allows them to manage this growing problem London Authorities have fallen back on some legislation from the 1970s which only applies within the boundaries of Greater London. However, even this rather inadequate legal provision was considerably weakened by the deregulations laws passed in 2015.

Outside London local government is struggling with case law which can only be applied in very limited circumstances.

We need legislation which unambiguously gives planning authorities powers to reclassify premises use for holiday letting as business use.

We need to give Local Authorities the option to bring short term letting within the sort of licensing regime which is available for HMOs

Housing Associations

Bath is unique in the number of people who choose to live in the city centre and in the social and economic diversity of those who live there.

This latter appears to be being changed by those entrusted with creating and managing social housing and other low-cost accommodation. We are increasingly seeing these organisation appearing to pursue policies which are displacing social housing tenants from the city centre and developing the resulting vacant properties for commercial gain by selling them, renting them out at commercial rents or even turning them into holiday accommodation.

These policies too often appear to be causing distress to tenants, threatening the nature of the city centre and displacing key city centre workers and turning them into commuters thus adding to their living costs and increasing the pressures on the city's fragile transport network.

·         We need changes to the regulatory framework to make Housing Associations as responsible for their social impact as they are for their financial management. They need to be made more accountable to local communities for what they do.

The Street Trading Policy Consultation

We have been actively participating in the Street Trading Consultation both in writing and through a series of consultation briefings and discussions and have been pleased to see many of the issues we have raised addressed in the latest proposals. Our remaining observations about the emerging policies are:

Part of the "vision" is to ensure "that public spaces become active spaces". Our view is that it is important that not all public spaces should or need to be "active" we also need spaces that are quiet and passive

There is a focus in the policy on the number of stalls that should be allowed in particular locations we think this is the wrong starting point. It’s not an issue about numbers it' s about the amount of space they take up, both their allocated space or the space they occupy in practice.

We support the idea of assessment criteria because it is important that Bath as a destination is managed with focused on high quality and diversity not just trading volume.

The council say they are exploring other ways of managing street trading on a day to day basis.  This could be by the Council as it is currently, or through a third party. Here, the key issue for residents is enforcement of the agreed policy's and rules and we will support whatever delivers this most effectively.

The policy proposals call for the creation of markets that "should be beneficial to the local area". We believe that this should mean that they should add to the local retail offer not merely compete with it. They should be managed to minimize disruption to local residents. They should where possible offer benefits to local residents such as discounts. special access or contributions to local community organisations and causes.

One group that is often negatively impacted by street traders are people with mobility issues and we believe much more thought needs to be given to their needs and issues in navigating the city centre.

Who should have a say in how CIL money is spent?

Clearly the Bath City Forum is not an ideal solution nor does it go very far in addressing the Bath governance issue.

However, creating a subcommittee of the Council made up of Councillors with Bath city constituencies to focus on Bath city issues and make authoritative proposals to full council about the how to address city problems and opportunities does make some sense.

To assist in this work, it might also have made sense to set up links between key organisations in the city, such as the BID, CCAG, BTP, Police etc., and forum members. This might, in part, have been achieved by inviting groups to nominate representatives to sit in on Forum discussions.

We are considerably less clear why the council has gone down the route of appointing self nominated individuals to sit as members the subcommittee. The pool created are self-selected and represent only themselves.

This is a situation which has always concerned us but a new development concerns us more. 

BANES are now using the forum to set priorities for spending the large amounts of money raised by the council through Community Infrastructure Levies.

How can this be justified?

Additional HMO Licensing consultation

HMO of any size create the same risk issues for both tenants, their neighbours and the wider community and should therefore be subject to the same regulatory framework.

We have seen an expansion of multiple occupancy properties of various sorts in the centre of Bath. This increase is both in terms of numbers of such properties and types of multiple occupation models ranging from large traditional HMO to holiday let party house models. We have also seen an erosion of traditional constraints and controls on this type of property both from legislative action and inaction and the ongoing attack on existing lease restrictions and covenants.

Two or more households in a building require as much external oversight as much as larger HMO both to protect tenants and their neighbours

Bath city centre is unique in the number and socio-economic diversity of its residents. This requires managing and protecting.

The nature of many of the buildings in Bath city centre presents particular challenges in terms of fire risk, noise pollution and waste management which require external oversight.

Fees proposed are designed to cover the administration cost not make a profit. HMO operators should be liable for the regulatory regime necessitated by their chosen business model.

The proposed conditions cover the basic risks and responsibilities that any responsible landlord should be held to

The current reactive response to complaints leaves landlords and tenants unsure of the rules. It also is a much more resource intensive approach and similar models of reactive response fail because of both resourcing issues and reporting issues as many tenants in this type of property feel vulnerable.

With the increased use of multiple occupancy models by landlords a lack of effective regulation will almost inevitably lead to abuses and increased nuisance and risk both for tenants and the community.

Letter to highways

We are writing in connection with the trade waste bins blocking the lower pavement at the end of George Street adjacent to Moles.

Have BANES, as Highway Authority authorised this obstruction of the highway. If so could you, please provide any documentation of such an authorisation and tell us what procedure was followed in granting this permission? Could you also advise what processes are available to challenge this decision?

If BANES have not authorised this obstruction we would like to formally request that action be taken to have it removed.

Ian Perkins – Chairman of TARA

Tom Maddicott – Managing Director Moles

Peter Turner – Ward Councillor

Major city centre development projects

For almost two years now we have been pointing out the fact that we are facing over the next few years unprecedented numbers of development projects in the city centre and saying how vital it is that BANES gets better at managing them in a way which minimises disruption to communities and ensures that they are fully informed about what is going on.

There has been little sign that our warning have been taken on board and we have already seen residents impacted by poorly managed projects. The Christmas Market is only just beginning to address the long foreseeable impact of the Footprint and Archway Projects and their progress in this has already been impacted by poor coordination with planned street maintenance activities.

We recently attended a meeting of independent traders who expressed concern about the impact of things like the positioning of hoardings around developments was having and bemoaned the general lack of engagement with businesses most likely to be affected by long term developments.

BANES needs to be much more proactive in coordinating, monitoring, controlling and anticipating the impact of major works in the city centre.

The Pedestrianisation of Milsom Street

A number of politicians, pressure groups and officials have talked about the current proposals for moving the footprint of the Christmas market as an opportunity to test the idea of pedestrianising Milsom Street long term. We have a number of concerns about this:

1. We doubt that BANES have well a founded traffic management scheme which can avoid considerable disruption and chaos if Milsom Street is closed for the Christmas Market. The traffic management in the area is poor even under normal circumstances.

2. Any pedestrianisation scheme needs to be part of a carefully thought through traffic plan for the whole of the city centre to avoid unintended consequences elsewhere in the city. We have yet to see such a scheme.

3. Pedestrianisation will lead to further loss of parking spaces for residents not just in Milsom Street but also in adjacent street which will become inaccessible

4. Many people live in Milsom Street and nobody seems to accord them and their needs any priority in pedestrianisation experiments or longer term schemes.

5. And most importantly this whole debate seems to be starting from the wrong end. We should be talking about how to improve the city centre for all those who live, work and visit. Within that we should be looking at how to make Milsom street a better place for all those who live, visit, work and do business there. Pedestrianisation may well have a role to play in either or both of these plans but it cannot and should not be seen as an end in itself.

Christmas Market Proposals

The start of both the Footprint and Archway projects this year means that the Christmas Market with have to move off its traditional footprint.

Their are two proposal on the table at the moment:

One is to move a sizable part of the market to Milsom Street which would be closed for the duration of the market and some days either side. This will:

• bring considerably more nuisance and inconvenience to town centre residents particularly those living on Milsom Street
• take out of operation a large number of city centre parking spaces several of which are residents only
• disrupt deliveries and collections from Broad Street and Milsom Street businesses
• create more traffic chaos in George Street and the rat runs north of George Street for the entire duration of the market

The other proposal is to move the entire market to the Royal Avenue and the area around the Bandstand. This would reduce the nuisance and disruption caused by squeezing the event into the restrictive and heavily used city centre spaces and put the event in a space where it can be redesigned as a 21st century event and where it will impact relatively few residents.

We just hope that this time BANES will put the best interests of city centre residents at the forefront of their decision making.

BANES consultations designed to disappoint?

We have commented before on the generally poor quality of BANES consultation processes.

Three recent examples have added to our concerns:

The Parking Strategy was based on what was finally a very good consultation process after a very poor initial effort and raised expectations that the parking strategy would be a comprehensive attempt to address the very many issues in this area. The outcome was disappointing as the resulting strategy largely ignored all the more difficult and contentious issues raised and focussed on a minor rearrangement of charging policy.

With the coach strategy there was a fair attempt at consulting although it seems to use a very limited sample of consultees but again the results are very disappointing and mainly focussed on issues raised by coach operators with little or no attempt to engage with more difficult issues such as pollution, enforcement and controlling coach cruising around key heritage sites that bring no economic benefit to the city or the relationship with other plans such as the destination strategy.

The library/one stop shop consultation which after a very poor start, which disappointed almost all stakeholder and led to some questionable decisions being made, now seems intent on setting the future project up to disappoint further. Consultees are being invited to make any proposal they like and being led to believe that all proposal have an equal chance of being considered for inclusion in the final project. This cannot be the case. Several proposals are not compatible and represent completely different vision of the role of libraries in the community. All proposal will have to fit in the existing space as the is little room for expansion at the Podium and the architects have already, in our view unwisely, committed to retain the same number of books available for browsing. It will also be the case that all proposals will have to fit within what is unlikely to be a generous budget.