Friday, 3 July 2020

Digital Exclusion

The Covid-19 crisis has pushed many people and organisations to make much greater use of digital systems and this is likely to continue into the post Covid world as organisations exploit their newly developed capability to deliver service via IT at a greatly reduced cost and newly skilled consumers become more and more comfortable with services delivered in this way.

More and more public bodies including BANES and the NHS are now planning to build on the on-line systems and processes they developed during the crisis. Residents have become much more comfortable with online service delivery which will, in turn, reduce the demand for traditional face-to-face services and make them less economically viable.

This will or should put the issue of digital exclusion front and centre for policymakers. Many of the most vulnerable and disadvantaged people in our community cannot afford to access IT and/or lack the ability to use it. This effect has been exacerbated by the closure of libraries and the underfunding of libraries. These have traditionally been where people in this position could be able to access both computers and help and training in using them.

The underfunding of libraries has been further impacted by vocal campaigns, usually led by the digitally included, to privilege book-based library services in the allocation of what limited funding does become available.

TARA is aking BANES what their plans are to address these issue as we enter the post-Covid world.

Tuesday, 26 May 2020


Despite the social isolation, the boredom and in some unfortunate cases, the loneliness of lockdown many city-centre residents will have had no difficulty in listing the benefits. Above all perhaps there is the kindness and good humour of strangers in the streets, the quietness, the cleanliness, the fresher air. Of course, much of this is due to the scarcity of people, both residents and visitors, and of traffic. For better or worse this will not last long. Without people and everything they bring, both good and bad, a city serves no purpose and will not long survive. But is there something we can learn from the benefits of lockdown? One undoubted benefit has been the marked decline this spring in the annual migration to the city of breeding gulls. Evidence is anecdotal in advance of the results of the council’s census of breeding pairs but many residents are noting that, compared with recent years, there are very few gulls about and with their absence has gone the raucous noise, the mess on our streets and the risk to health and safety. They seem to have left us in large numbers.


The annual migration of gulls to Bath is caused by the abundance, especially in the city centre, of nesting opportunities on inaccessible and undefended roofs and the generous food supply. There is no reason to think that nesting opportunities have declined but what happened to the food? This is largely provided deliberately by the thoughtless dumping on our streets of litter, particularly of fast food and the containers in which it is provided, and by the presence on our streets of residential and commercial rubbish waiting to be collected. Competing to find food waste, gulls attack the containers in which rubbish is left, scattering debris all over our streets which on windy days finds its way into every corner of the city centre. During the pandemic, residents have been in lockdown but many, including 90% of TARA members, live in apartment buildings where the rubbish collection is centralized. Businesses, on the other hand, have been mostly closed. It seems plausible to argue, therefore, that the retreat of the gulls has been due to the absence of pedestrian litterers on our streets and of the piles of commercial rubbish, particularly food waste from fast food businesses, pubs and restaurants, left on pavements for collection. If this is so, what can be done? Why are the problems of litter and commercial waste management so damaging to the appearance of our city-centre in normal times?

Collection and removal of commercial waste are the responsibility of the Council and the BID (Business Improvement District). The arrangements in place are complex and, in some respects, poorly conceived and ineffective. For example, although the Council and the BID, which regulate and partially provide collection, removal and disposal services, stipulate that both domestic and trade waste be left out for collection only at certain specified times, morning and evening shortly before collection, these stipulations are often ignored.  As a result, significant amounts of waste are left out overnight and attacked by gulls in the early hours of the morning. In addition to timing regulations both the Council and the BID require, and to some extent provide, supposedly suitable packaging in the form of bins and gull and rodent-proof bags.  These packaging rules are also routinely ignored.  Gull proof bags are easily opened.  Bins are overflowing and lids are not closed.  Extra, unapproved containers, bags and boxes including supermarket plastic bags are used widely and even the council and the BID appear to be issuing flimsy plastic bags.

The Council’s policy of refusing to collect waste that has not been correctly packaged, while well-intentioned, means that unless and until rubbish is returned to storage scavenging pests are free to attack and scatter it so that it becomes street litter. Both residents and businesses often lack the space to accommodate uncollected waste as well as the various re-cycling containers required. Finally, the many independent contractors used by businesses, so many that it has been difficult to obtain the exact number, often seem like a law unto themselves, frequently showing up too early, too late, or not at all. Litter, the collection of waste and the gull menace. All of these issues, and the links between them, have been exhaustively rehearsed in recent years, not least in the useful and thorough survey reported by the Chronicle in July 2019. As so often in Bath the problem seems to be not so much with the regulations as with enforcement. So far as waste management is concerned, in its survey last year the Chronicle reported ‘a significant fall in the number of offences by businesses,’ over the past three years. This turned out to refer to the number of fixed penalty notices issued and may reflect a reduced effort by the council rather than improved compliance by businesses. Given the limited resources available it is painful to watch the trouble that has to be taken before action is possible on a single infraction of the regulations for putting out commercial waste. Rubbish must be painstakingly gone through and photographed to identify the culprit. Standards for packaging and for the number and timing of collections need to be reviewed; two collections per week of food waste is inadequate in the commercial heart of the city. More effort is needed, not only to identify businesses flouting the rules and ensure they do not get away with it but also to monitoring and improving the performance of independent contractors. And why does the BID allow permanent waste dumps, in George Street for example, which are a magnet for scavengers both human and animal and remove any incentive for commercial premises to improve their management of trade waste?

As far as residential waste is concerned it makes no sense that the council allows this to be left out overnight where it is open to attack by gulls and rats. And then there is litter, an issue on which Bath is gaining an unfortunate reputation. Are we doing enough? In normal summers, having started at 6.00 am our heroic five-man city centre team is often still struggling to remove piles of overnight litter mid-morning by which time the streets are crowded with visitors and shoppers. The council should review the funding and organization of litter collection and removal in the city centre and replace the cancelled 3GS contract that brought in £200,000 in £150 fines in ten months with something more thought-through and less controversial.

The gulls seem to have arrived in their usual numbers in late March and gradually retreated as Covid19 indirectly eliminated most of their food supply. Is it possible that if we can at least reduce this food supply in future years we might have the makings of a solution to a problem which has been plaguing Bath for years and attracting critical comment in local and national media?

Friday, 8 May 2020

Pedestrianisation should not be taking place in a vacuum.

We have just seen yet another traffic scheme experiment in the City Centre this one apparently aimed at proving the viability of a scheme to pedestrianise Milsom Street. We are concerned at this further example of the council's apparent fixations with pedestrianisation as a magic bullet for solving the problems traffic and pedestrian movement. We are concerned because:
We have yet to see any evidence that BANES have well a founded traffic management scheme. One-off closures of Milsom Street and Queen square have shown our doubts are not without foundation. The latest experiment involving putting more traffic up one of the cities worse polluted streets with some of the narrowest pavements has not been reassuring. Any pedestrianisation scheme needs to be part of a carefully thought through a 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.
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. There are many residents and visitors with impaired/variable mobility and energy, who don’t meet Blue Badge criteria but would be adversely affected if the centre was pedestrianised. Accessibility for them appears to have been overlooked.
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 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. 

Perhaps Banes should be focussing in the immediate future on getting in place the CAZ and if they really want to reduce the number of polluting vehicles implement option D rather than the weaker option C.

Thursday, 7 May 2020

The management of tourism

  • In 2014 there were 969,900 overnight tourist visits to Bath & North East Somerset.
  • There were 4.8 million day visitors to B&NES in 2014.
  • In 2015 there were approximately 1 million visitors to the Roman Baths, 398,319 to the Abbey, 157,851 to the Victoria Art Gallery and 90,147 to the Fashion Museum.
  • Bath is a UNESCO World Heritage Site.
  • In 2015 the City of Bath ranked 12th in the VisitBritain ranking of top cities/towns for international staying visitors. 
  • There were 323,000 international visitors to Bath in 2015, a 36.8% increase compared to 2014 when there were 236,000.
  • £411 million was spent by tourists in B&NES in 2014.
  • It was estimated that in 2014 in B&NES 9,213 people were employed in tourism.
Coming out of the Covid-19 crisis the tourism industry will inevitably be facing grave difficulties. The statistics above show how critical this industry is in Bath.

There will be, and hopefully is, an ongoing discussion about how Bath will respond to this challenge. 

On a positive note many comparable cities around the world are using these discussions to address some of the more negative impacts of mass tourism and it is to be hoped Banes will follow this lead.

Any dialogue will inevitably need to involve numerous organisations such as Heritage Services, the National Trust, Bath Tourism, BIGHA, the BID, the World Heritage Steering Group and Bath Preservation Trust to mention but a few.

Historically, and it seems, currently one major group of stakeholders who will not be adequately represented will be Bath Residents and in particular Bath residents living in the historic city centre. And yet we are the ones who pay for the maintenance of the majority of the heritage assets that visitors come to see, we are the ones who create the social and cultural environment that visitors find so welcoming, we are the ones who volunteer as visitors guides and we are the ones whose amenities are impacted by decisions made about the use of public spaces.

We would like to see plans put in place to rectify this as a matter of urgency.

Thursday, 30 April 2020


The applicant seeks to vary some details of, and certain conditions attached to, an existing but un-realized, planning consent 18/04797/FUL which sought to convert the use of the premises from night club (sui generis) to pub (A4).  Among features that would be retained in the present application is a partially roofed outside drinking area at the rear of the property in what is presently the ‘garden’, the ‘Pergola,’ and an open area extending to the south boundary.  Due to noise nuisance from high volumes of traffic on the Paragon many Bladud Buildings residents have their bedrooms at the rear of the property.  In addition, the main Bath YMCA building is a short distance to the south-west.  Finally, numbers 45 and 47 Walcot Street, which incorporate existing and proposed residential accommodation on upper floors, occupy a position immediately to the south of the premises.  This is, therefore, a highly noise-sensitive location, particularly at night, and the introduction of an open, or partially open, drinking area at the rear of 7 Bladud Buildings is likely to have a severely adverse impact on the amenity of local residents contrary to Policy D6 of the council’s adopted Placemaking Plan.

It was for this reason that TARA posted an objection to the previous application and asked that, should consent be granted, certain conditions be attached which would have the effect of protecting local residents from unreasonable noise and disturbance, particularly from the rear of the property, during night time hours. 

The present applicant now seeks amendments to eight conditions attached to the original consent granted March 21st 2019.  

We request that where the applicant provides information in support of his request, and the LPA is minded to grant consent, those standards are met that would have applied had the applicant submitted material in an application to discharge the conditions, and that sufficient information is provided on plans and documents to enable compliance to be assessed.  This applies particularly to Condition 2 (materials to be used), Condition 3 (Noise from ventilation and extraction equipment), Condition 9 (Hard and soft landscaping), Condition 11 (Emergency exit) and Condition 13 (external lighting).  We also ask that Condition 12, which relates to the emergency exit at the rear of the property, remain unchanged with the exception of the drawing number revision.

The applicant also seeks removal of that part of Condition 5 which specifies that that use by the public of the unenclosed area at the rear of the premises will cease automatically after twelve months unless a further consent is granted. 

TARA asks that Condition 5 be retained as it stands.

The effect of Condition 5 with its reference to re-application after twelve months omitted, is that the alternative available to the LPA, should the applicant fail to comply with the time limits specified, would be enforcement action, a time-consuming and sometimes complex process which could subject local residents to a prolonged period of noise and disturbance at night.

The applicant has it in his power to ensure continued use of the rear of the property by complying with the requirements of Condition 5 while making a timely application for a further consent.

TARA further requests that any approved plans indicate clearly the area to which Condition 5 relates.  This should cover all un-roofed and unenclosed areas to which the public has access at the rear of the property including the ‘Pergola,’ which may be open or enclosed depending partly on weather conditions.  We also ask that the LPA satisfy itself that within the area to which Condition 5 applies roof and wall materials meet satisfactory standards of noise attenuation.

Tuesday, 7 April 2020

20/00127/FUL 75 ROSEWELL COURT - An Update

On March 16th, under delegated powers, our council granted consent for the conversion of a two-bedroom flat at Rosewell Court in the city centre to an HMO (Home of Multiple Occupation).  This approval was retroactive, in that the conversion had already taken place but the law required that planning permission should have been applied for and granted, had not been, and needed to be.
As is normal, the council based its approval on its policy decisions in relation to HMOs.  These include Policy H2 of the council’s Core Strategy and Placemaking Plan which, inter alia, is designed to ensure that an HMOs will be ‘compatible with the character of adjacent uses’, will not ‘significantly affect the amenity of adjoining residents’ or result in the ‘unacceptable loss of accommodation in a locality in terms of mix, size and type.’  In addition, the council’s Supplementary Planning Document, Homes in Multiple Occupation in Bath, adopted in November 2017, is intended to ensure that similar undesirable consequences are avoided by preventing the accumulation of HMOs beyond a specified limit in any particular residential area.
On the face of it, and in normal circumstances, the application of these laudable principles in combination should underline that the council has consistent objectives in relation to HMOs and that, provided that its policies are enforced, these objectives will be met.
But these are not normal circumstances.  Providing about two hundred and twenty homes, mostly two and three-bedroom flats in four to five-storey buildings with balcony access Rosewell Court makes an important contribution to the limited supply of affordable family accommodation in the city centre.  The conversion for which planning consent has been granted has transformed a typical two-bedroom flat into a three-bedroom unit with a single bathroom and no shared space of the type favoured by short term renters, holiday renters and students.
In approving this conversion, the council is in danger of bringing about the exact opposite of what its policies are designed to achieve.  Having set a precedent, the council will find it hard to resist pressure from other owners to follow suit.  Rosewell Court has a history of serious social problems including drug dealing and abuse, petty crime, noise and disturbance and other forms of anti-social behaviour resulting in police visits.  Any accumulation of HMOs in a development that lacks any shared external facilities other than a council car park will be likely to make all these problems worse.  In due course, if HMO conversions multiply, the council may feel justified in refusing further applications.
Unfortunately, none of these arguments appear to have been seen by the Development Management Committee (other than the Chair) despite a request for referral by a Ward Councillor, objections by TARA and local residents were ignored and, inexplicably, as principal landlords at Rosewell Court, neither Curo nor the council itself elected to comment.  
To TARA, this seems to amount to faulty administration.  There is no right of appeal in England to the granting of a planning consent except under Judicial Review.

Wednesday, 18 March 2020


This is a worrying time for all of us but especially for our older members.

With the potential plans for people over 70 to be asked to stay at home months whether they feel unwell or not, we think that it is important that we make plans now to reassure those affected, of the support of our community.

Please would you be particularly mindful of older people who have flats in the same house as you or neighbours either side.

If you are in the affected group and think that you will need help of any kind, please let friends and neighbours know.

If you know of someone whom you think will need help, please contact them and ask if you can help them in any way.

If you know of neighbours who need help, or you yourself need help, please do contact TARA and we will do what we can to assist either personally or put you in touch with people or organisations who can.

For those of you in a position to offer more help 3SG is registered charity working all year round for a more connected and resilient Bath & NE Somerset. During this difficult time, we want to make sure that our residents are looking out for one another to help everyone stay safe and healthy. Lot's of people are getting in touch to support others in their community which is great. If you're healthy and at low-risk, you can be a Compassionate Community Connector and help others across Banes. Sign up now, and pass the word on. Sign up here

Wednesday, 4 March 2020

The Min Development

We have seen the chaos surrounding the hotel development on South Parade which has massively overrun, causing unacceptable levels of nuisance and disruption to local residents, creating traffic disruption and creating an eyesore in a conservation area which is of often the first view visitors have of Georgian Bath.

We are now facing the prospect of another similar massive building project right in the heart of the world heritage site. If this development is anywhere near as big a shambles as the one on South Parade it could be a disaster for Bath as a World Heritage Site and tourist destination as well as having a potentially devastating impact on residents and traders in a huge and important area of our city.

What are BANES planning to do to avoid this potentially disastrous scenario unfolding? What lessons have been learned from the shambles on South Parade?

How will the traffic management plan for Bath be adapted to accommodate site traffic? Are the council still planning to exclude traffic from Kingsmead square and how will that work with the need to provide site access and serving of local businesses?

What noise standards will be imposed and who will monitor compliance?

What pollution standards will be imposed and who will monitor and enforce compliance?

How will residents' rights to privacy be safeguarded?

What standards will be set for keeping the site as visually unobtrusive as possible? This is a very important consideration in the heart of the World Heritage Site.

What support will be available to vulnerable residents living around the site?

What standards will be set for regular ongoing consultation with residents and traders? This latter was a major hole in the planning for the Footprint project

What framework of oversight will be put in place and will it include provision for officers visiting residents and traders to proactively identify issues which need to be resolved? Or will we again rely on a reactive strategy requiring formal complaints?

Will a proper mediation process be put in place to resolve conflicts of interests?

Monday, 3 February 2020

Planning application 20/00127/FUL 75 ROSEWELL COURT

Providing more than one hundred and twenty homes, mostly two-bedroom units in four to five storeys with balcony access, Rosewell Court makes an important contribution to the limited supply of affordable social housing in the city centre.  At number 75 the applicant seeks to provide three-bedroom accommodation with a single bathroom and no shared space of the type favoured by short lease renters, holiday renters and students, in our view an entirely inappropriate offer in this location.  If it set a precedent at Rosewell Court it would be likely to result in:
Loss of affordable single-family housing in a development that lacks any external shared facilities other than a public car park
Increased noise and disturbance 
Increased drug dealing and use, petty crime and anti-social behaviour in a location with a history of serious social problems
Increased fire risk
Increased pressure on local and emergency services

It was in order to avoid circumstances of this kind that, under Article 4 of the Town and Country Planning Act 1990, Local Planning Authorities were granted powers to require those seeking to transfer a property from C3 (dwelling house or flat) to C4 ( House in Multiple Occupation) which would previously have been designated as Permitted Development, to apply for planning consent, a requirement with which presumably the current applicant is now seeking to comply.

Under Policy H2 of its Core Strategy and Placemaking  Plan, the council confirms that the entire District is subject to Article 4 Directions and that as a result changes of use to HMO will not be supported if, among other factors

The HMO use is incompatible with the character and amenity of established adjacent uses
The HMO use significantly harms the amenity of adjoining residents through a loss of privacy, visual and noise intrusion
The HMO use results in the unacceptable loss of accommodation in a locality, in terms of mix, size and type
It is, therefore, both surprising and disappointing that, as principal landlords at Rosewell Court, neither Curo nor the Council has, so far as we are aware, elected to oppose the application.  It is therefore for TARA, in an attempt to defend the interests of existing residents at Rosewell Court, to oppose the granting of planning consent in this case.

We therefore ask for this application be REFUSED.

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
 ‘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.