Wednesday, 28 January 2015

TARA’s Response the BANE’S Place Making Plan


One of the things that make Bath special is the number and social diversity of people who choose to live in the historic heart of the City. They play an important role in creating the vibrant community and culture that attracts knowledge workers and industries to locate here and the maintain many of the Georgian buildings that draw tourists here in their millions.

We think it is important that this plan explains how residents will be supported, what sort of place BANES is aiming to create for city centre residents and how BANES plans to preserve and maintain the things that resident’s value.

We would like to see for all the key sites and areas a statement of what the impact on residents is likely to be both in the short and long term.


In general TARA supports both the analysis and the proposals that flow from it which are in line with recommendations made by us in September 2013.  We endorse, for example, the suggested mix of uses, the need to repair the ‘broken frontage’ on Walcot Street, preserve views across the site to the east and conserve and find a viable use for the Cornmarket building.  We support the emphasis on variety in the form, function and scale of buildings and the need to provide two east-west cross routes to improve vehicular access to the site.

However we notice some confusion and lack of clarity in suggestions for building height restrictions and the river corridor.  Limiting building height to that of local Georgian buildings is recommended but this is not typical of Walcot Street where buildings range in height from two to four storeys as well as in date of original construction.  Furthermore, because of the pronounced fall in the site from west to east higher buildings would presumably be acceptable on the east edge of the site.  We believe that higher buildings could also be acceptable on the west edge of the site if set back from the building line provided functional continuity is achieved.

The need to extend the riverside pedestrian route northwards from Pulteney Bridge is acknowledged but it is not clear whether continuing this route north of the Cattle Market site is envisaged. If not, then a publically accessible space should be provided as a destination on the river bank adjacent to the Cattle Market possibly incorporating a new pedestrian cross route linking Walcot Street with St John’s Road via a new pedestrian bridge across the river.  ‘Privatization’ of the river bank should be avoided at all costs.


In general TARA supports the analysis and the proposals but we suggest that the following points be taken into account as proposals are finalized.

The Colonnades

The council is currently seeking planning consent for enabling works in relation to the development of the vaults below Grand Parade for high end dining facilities (14/01772/REG03).  However, proposals included in the application documents (Design and Access Statement, page 13, Use of the Colonnades) envisage that the public would have no right of access to the south colonnade even during daylight hours when Parade Gardens are open to the public.  This effective privatization of part of the Colonnades would be in direct conflict with proposed Development and Design Principals 1 and 3 where the opening up of historic pedestrian routes in the area is rightly emphasised; it would be unacceptable to our members and we believe that, given the substantial expenditure of public funds on the development, the wider public would be likely to share this view.

Pedestrian river crossing

Given that Site SB2 occupies a strategic position between the recreation ground and the city centre we believe that cross-river links, particularly for pedestrians, are insufficiently emphasised.  A recent study of the traffic implications of the additional 4,300 supporters likely to converge on the new stadium on busy match days (assuming it is built) concluded that the main impact would be, not in enhanced congestion on city centre streets, but in a marked increase in pedestrian traffic in areas around the stadium.  Links to the stadium for pedestrians are currently poor, relying too heavily on flights of narrow, twisting, stone steps leading to the river bank from Argyle Street and North Parade.  A new foot and cycle bridge across the river linking the stadium and other recreation facilities with the commercial heart of the city to which many supporters are drawn during their stay should be given serious consideration.  This might be provided in conjunction with proposals to provide improved links between Terrace walk and Parade Gardens and between Parade Gardens and the river, or possibly as an extension eastwards from South Parade.

Radial Gate

Whether or not the radial gate is removed or renovated the potential of the island linking the radial gate with Pulteney Weir should have been explored.


We accept the analysis but with qualifications.  Proposals for the most part consist of options and qualified principles reflecting an inherent, and perhaps justifiable, confusion over the role of the site.  Where more definitive guidance is provided, for example over routes serving or crossing the site, there is sometimes confusion over purpose and Intentions.  For example

Roads and Access
A north-south extension of Duke Street ‘must be provided’.  This is to be designed as a ‘shared space that also potentially allows limited vehicular access to the rail station’.  It is not clear what this means.  Could a north-south traffic route serving the entire area be upgraded to relieve pressure on Manvers Street?  If so could this serve the site with a series of loops which might render the east-west route, which is also proposed, unnecessary?

A new pedestrian and cycle route across the river is proposed.  We support this but do not see why it should be ‘connected to the existing railway bridge’.  Could it not extend eastward from South Parade providing a more direct link between the rugby stadium/recreation facilities and the rail and bus stations which are used by large numbers of fans on busy match days.

Land Use

We agree that the site should be regarded as a ‘Gateway’, a new commercial quarter linked to Bath’s rail/bus hub and consisting of a complex of small industrial units, offices and workshops but we see no reason why other uses such as residential and local retail should be excluded.  Neither do we see why a hotel or major public institution such as an auditorium would be incompatible with this vision.

Public Spaces and Building Massing

A significant ‘public space’ is envisaged responding to South Parade, Duke Street and St John’s Church.  It is not clear what the function of this space would be and it is arguable that the space between buildings on this site could consist of a finer grained network of pedestrian and cycle routes providing a chain of more intimate spaces.  It is also envisaged that Zone 1 building height limits should be adhered to ‘subject to modification’ and that Bath stone should be used throughout.  We see no justification for imposing such disciplines.  The emphasis in our view should be on variety and flexibility in the form, function and scale of buildings as well as in the materials with which they are finished.  And we suggest that more attention could have been given to the river bank as a green edge and as part of the pedestrian/cycle network serving the wider area.

Monday, 19 January 2015


In a further review of documents which, as we understand it, are likely to be approved should this application be granted planning consent we have noted a reference in the Design and Access Statement (Page 13, Use of the Colonnade) to the possibility that the public would have no right of access to the south colonnade even when Parade Gardens is open to the public.  We recognise that there are legal constraints but given that the council is landowner, developer and planning authority in this case, considering also the substantial expenditure of public funds on the development and the expressed desire to open up historic riverside routes to public use we can confirm that this effective privatization of a part of the Colonnades would, if implemented,  be unacceptable to our members and we believe that the wider public would be likely to share this view.

We therefor ask that should the council be minded to grant consent for this proposal a condition be imposed providing that no development can take place until the applicant has submitted a statement to the satisfaction of the Local Planning Authority detailing who would have right of access to pedestrian routes throughout the development, at what times and under what circumstances.  This would provide an opportunity for much needed public debate of the issue.

Sunday, 11 January 2015

Regulation and enforcement

Without an effective enforcement regime in place all other regulations and regulatory actions become meaningless. For instance:

All licensed premises should be made to adhere strictly to their licence conditions. However licensing officers only inspect premises relatively infrequently and often not during the hours where breaches are most likely.

All licensed premises should comply with planning conditions but decisions of the planning authority are too often flouted for considerable time before effective enforcement action is taken.

Excessive noise from music, observable both on the street and in the nearest premises is routine in the City centre in the early hours of the morning. However, Environmental Protection Officers are not available at all at night when most noise nuisance happens. Environmental protection is not proactive in enforcement only acting on reported nuisance. Other enforcement agencies, such as the police, on the whole ignore noise as an issue

The Council’s Air Quality Management plan calls for improvements to the enforcement of the Traffic Regulation Orders designed to reduce pollution from heavy goods vehicles and with rising levels of pollution damaging both human health and the historic fabric of the city implementing these improvements is long overdue.

Parking on the pavement causes obstruction, particularly for people with disabilities and causes huge damage to pavements and other public infrastructure however nobody seems to take responsibility for stopping people doing it or penalising them when they do.

BANES spends large amounts of money clearing up litter but little resource stopping people dropping litter in the first place

Too often regulations are made with little or no planning of how they will be enforced - A Boards and 20 mph zone spring to mind. This does nothing for the credibility of the regulators or the regulations and leaves residents feeling short changed and abandoned.

Wednesday, 7 January 2015

Proposed Public Space Protection Order

Banes is currently running a public consultation on a proposal to ban on the use of amplifiers in the following locations: Abbey Church Yard, Kingston Parade and Abbey Green. This would be achieved by putting in place a Public Space Protection Order. You can access this consultation at and we would urge you to do so.

The criteria for issuing a Public Space Protection Order are:

  • That the activities i.e. the use of amplification have had a detrimental effect on the quality of life of those in the locality
  • The activities are persistent or continuing
  • The activities are unreasonable
We do support the introduction of a PSPO to control amplified busking around the Abbey but we are a little puzzled both by this proposal and the consultation.

We receive numerous complains about amplified music affecting peoples lives. We also know that BANES in its various manifestations receives large numbers of complaints about amplified music .

Only a relatively small proportion of these complains are about buskers or relate to the areas mention in this consultation.

Most relate to businesses, typically licensed premises, in areas like George Street, the Parades, Manvers Street, Bladud Buildings etc. Many of these complaints report that the use of amplified music particularly late at night is having a very detrimental on their quality of life, many complains have a history going back years and it seems to us unreasonable that any business should be using amplification at a level that impacts their neighbours.

Over the years Banes has done little to address many of these complains or tackle these problem areas. This is why we are puzzled that they are now proposing action in these limited circumstances and in these limited areas.

We do of course welcome the fact that they are at last starting to tackle the problem but hope that the action will not stop with this very limited first step.

Monday, 5 January 2015

The Public Realm and Movement Strategy

The Public Realm and Movement Strategy was created at considerable expense to improve  the quality of environmental design and management, particularly for pedestrians and cyclists, on city centre streets.

This strategy was generally well received and made a promising start but seems to have run out of money and political support.

In consequence our city centre still fails to meet standards which are commonplace among European peer cities and well short of what one would expect from one of the few cities in the world to have been awarded World Heritage Status.

Why has this been allowed to happen>