TARA comments on proposals for the World Heritage Centre and Roman Bath's Learning Centre

TARA is happy to lend its SUPPORT to proposals for the World Heritage Centre and Roman Bath Learning Centre at York Street.

It is true that visitor attractions in the city centre can cause problems for local residents including increased pressure on limited parking resources and the impact on air quality of slow moving tourist buses.  We recognize, however, that as a World Heritage City Bath has an obligation to protect and enhance its historic sites and make them available to public view.  In addition, tourists and visitors provide irreplaceable support to the local economy particularly to the hotel and retail sectors in the city centre from which local residents benefit.

TARA members have been fortunate in being able to follow the development of this scheme from its early stages.  We believe that the proposals represent an ingenious and well thought through response to a challenging brief and complex site which will provide a welcome addition to the city’s array of cultural and historic treasures without adding significantly to the city centre’s existing problems.

However, given access constraints and lack of obvious availability of areas for storage close to the site there will be concerns among residents over management of the construction stage We therefor endorse the request by the Highway Officer in comments posted July 18th 2016 for prior approval by the council of a comprehensive Construction Management Plan should it be minded to grant consent.

Comments on the proposed development of the Colonnades

The current application revises proposals previously submitted by the applicant in July 2014 on which TARA commented in July and October of that year. This application was refused in committee and there was no appeal. TARA has consistently supported the aim of bringing the Colonnades into public use and finding a suitable role for the vaults below Grand Parade. We welcome many of the changes now introduced including in particular the removal of the north and south kiosks on Grand Parade and the undertaking, in most though not all supporting documents, that access to the Colonnades will be available to the public at least during the hours that Parade Gardens are open. We have no objection to the changes of use proposed and applaud the inclusion of D1 (museum) as an adjunct or alternative to the original A3 proposal.

It is therefore with regret that we must ask that a decision on the application be DEFERRED until matters of concern to local residents, particularly those living at the Empire, an apartment complex on Grand Parade immediately above the Colonnades, are adequately dealt with. Notwithstanding comments made in the Statement on Community Involvement there has been very limited consultation on the current application and as things stand residents still have unresolved concerns about various detailed design issues as well as operational matters particularly in relation to service access and the role of Boat Stall Lane.

Issues of servicing and the use of Boat Stall Lane and the Guildhall car park illustrate a weakness of this as of many such ‘shell and core’ applications where crucial details of interest to the surrounding community are lacking. Servicing of the proposed restaurant and/or museum complex is to be via a single lift on the corner of Grand Parade which is also to accommodate such visitors and customers as choose to, or have to, use it. The contribution of Boat Stall Lane to this regime is, as it has always been, unclear. In documents supporting the application the Transport and Parking Statement claims that ‘no vehicular access to the undercroft area is proposed’ but also that ‘goods and items that are too large for the lift can be brought down Boat Stall Lane’, two statements that appear to be in conflict.

In the Statement of Community Involvement where issues arising from consultation on the 2014 application are discussed the following comment is made in relation to Deliveries and Waste Collection: ‘Particular concern was raised about using Boat Stall Lane and the impact this might have on the East Gate. In response to this consultation the (current) design includes a lift to service the restaurant and dedicated waste storage areas within the restaurant premises.’ We have taken this to mean that the use of Boat Stall Lane for servicing the complex is not intended. However, where consultation with stakeholders on the current application is described the statement is made that: ‘The use of Boat Stall Lane is undecided and will be a decision of the chosen operator.’

The Planning and Heritage Statement claims that: ‘Waste will be stored within dedicated waste and recycling spaces below ground and will be transported up to street level via the proposed lift or on rubber wheeled vehicles up Boat Stall Lane for collection in accordance with a Waste Management Plan.’

Regrettably, there is no Waste Management Plan in supporting documentation. Whatever is actually intended it is by no means clear that the use of Boat Stall Lane as a servicing route is practical at all. During the consultation phase following the 2014 application numerous objections to the use of Boat Stall Lane were put forward, some by local residents and ourselves and others by the design team itself

Width restrictions on the Brydon Archway and on the manoeuvring of large public service vehicles within the Guildhall car park

Conflicts over the use of the Courtyard as a public car park

Access to the Empire basement car park

The historic status, gradient and optimum surface for Boat Stall Lane and the way its use for refuse removal and major deliveries could impinge on the amenities of Empire residents

The lack of a turning and manoeuvring area at the foot of Boat Stall Lane

Lack of parking/storage area for the ‘rubber wheeled electric vehicles’ at various times proposed

In our view the current application, rather than leaving the matter unclear and unresolved or subject to ‘decisions by future applicants’ should state clearly and consistently how servicing of the complex will work under various alternative scenarios and the role envisaged for Boat Stall Lane. It is not acceptable that such fundamental issues of feasibility, practicality and potential impact on local residents should be addressed in conditions attached to the present application (on which the council has stated it will be unwilling to consult with third parties) or deferred until applications by future operators are under consideration. The planning and design team has commendably gone to considerable lengths to obtain specialist advice on such diverse matters as traffic and transport, drainage, ventilation and noise attenuation, bat welfare and flood risk. It ought to have been possible to obtain the services of a specialist consultant to advise whether servicing arrangements for the proposed complex are workable and the role, if any, of Boat Stall Lane in these arrangements.

The current ‘shell and core’ application has, by its nature, only limited relevance to other ‘downstream’ operational matters such as lighting, hours of operation, attenuation of noise and kitchen smells and management of the construction process and residents have no means of judging the extent to which any consent based on the current application will commit future applicants to acceptable standards. The officers’ report to committee on the 2014 application did recommend twenty five conditions covering these and other areas but it is no clearer now than it was then whether the local community will be consulted on the likely scope of such conditions, what standards will be mandated, if any, whether future applicants will be bound by them or whether residents views will be sought when applicants seek to have conditions discharged. It is for these reasons that we ask that a decision on the application be DEFERRED until these matters are clarified. However, should the council be minded to grant consent under the current circumstances we ask that conditions be imposed which will ensure that no development can take place until this applicant, and any subsequent applicants, are committed to workable and satisfactory proposals in at least the following areas and that residents have an opportunity to consult on such conditions

Waste management

Management of service access and storage

Hours of operation

Other management issues including noise attenuation and removal of kitchen smells

Buildability and management of the construction process.

Response to the PPC's YOUR POLICING PRIORITIES CONSULTATION

We broadly agree with the PCC’s vision and priorities.

However, we think her plan needs to be much clearer about what is meant by vulnerability and how competing vulnerabilities will be addressed.

We agree that strengthening and improving your local policing teams should be a priority but would observe that almost all the changes brought in by the PCC since the role was created have weakened local policing teams and connections between police and the communities they serve.

We agree 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 on the network.

We agree that working together effectively should be a priority but note that there is little coordination or pooling of funding over things like CCTV 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.

A reaction to planned changes to rubbish collection arrangements

The current proposals are in our view a "one size fits all approach" which completely ignores the practical realities of the situation in the city centre.

Gulls don't attack bags that have no food in them.

There is a real risk of gull proof bags being permanently left outside city centre houses particularly where there are several flats. They will then become outside rubbish bins with less incentive to separate food waste as gulls won't attack them.

Because residents work many gull proof bags will, as a matter of course, be left outside on pavements for many hours and in the city centre this means they will be moved or taken.

Given that, many city residents live in flats with very limited storage space the council’s ideas about recycling and storage are impractical, particularly if residents have to store two weeks’ worth.

Most of the rubbish and unsightly pavement blocking rubbish dumps, and in particular most of the food waste is created by businesses and not residents.

Commercial waste left overnight

seven days a week

We would suggest that instead of creating more problems for residents the council should focus on addressing the issues of rubbish created by businesses and street sleepers and drinkers.

Rather than exacerbating residents problems by moving to fortnightly collection we would suggest they talk to commercial waste contractors about creating a daily collection in the city centre.

A permenant commercial waste dump
showing detail

A permanent commercial waste dump 

City of Bath World Heritage Site Management Plan 2016-22 Consultation Draft A Response by TARA

There is much in this document which we would support but it is unclear how its conclusions and actions will be implemented.

Priorities

We would like to propose two additional priorities:

1.       Pollution and air quality – current levels of pollution exceed WHO guidelines in several areas. Pollution impacts the health, comfort of both residents and visitors and damages the history structures which caused the city to be selected as a WHS.

2.       Protecting communities - 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. Your own report talks about Bath as a thriving 21st-century community. Venice demonstrates what happens if a WHS loses its community structures.

Actions

Managing Development

It will be very important to have proper coordination of the many major, and some of the minor, development projects to avoid disruption and damage to the WHS in the short to medium time and to minimise costs.

Transport

The action “Monitor & engage with the delivery of the Transport Strategy (2014) objectives in so far as they relate to the WHS & seek to ensure that they have no unacceptable impact on the OUV of the WHS & its setting” begs the question who will decide on acceptability and what criteria will they use.

It is not clear why cycling has been pulled out of the Transport Strategies and accorded special consideration ahead of other issues such as parking. The assumption seems to be that cycling has an entirely positive impact on the city a contention that many residents would dispute.

Public Realm

There are a number of issues impacting the public realm which do not get mentioned here including street drinking, street living, busking, begging and litter.

In addition, the quality of public realm infrastructure, particularly in the city centre, continues to fall way below the standard achieved by many peer cities which do not have the benefit of World Heritage Site status.  Funding of the city’s own Public Realm and Movement Strategy, which would have remedied many of these deficiencies, has ceased after a promising start and should be restored.

Other observations

The stakeholders in the WHS referenced in this report and the list of those to be used in initiating actions seems to have been selected from a rather narrow pool which may well reflect the situation at the time the last plan was prepared.

There is a need to create an effective database both of the assets of the WHS in terms of historical and archaeological records and artefacts but also the key stakeholders and gatekeepers who need to be engaged if the objectives of this plan are to be realised.

Planned roadworks on North Parade Bridge

Residents, particularly those living in and around the Empire and the Abbey area, are very concerned about the planned roadworks on North Parade Bridge.

Under the current arrangements, Pierrepont/Manvers Street is often gridlocked and, with North Parade Bridge blocked, many residents will have no way in or out of the city.

One thing that BANEs could do to alleviate this problem would be to open up Pulteney Bridge to all traffic in both directions for the duration of the work.

If the volume of traffic on the bridge would be a concern perhaps the existing traffic control cameras could be used to restrict access to vehicles with appropriate permits.