Monday, 18 December 2017

The loss of Avon Street carpark

Air pollution in almost all the City Centre areas covered by TARA is above the safe health levels set by the world health organisation and adopted by the British Government.

We are pressing BANES implement its Air Quality Management Plan with much greater urgency.

The reduction of NOx and small particulates needs to be set as a key objective of any strategy. There needs to be more monitoring of small particulate pollution in the city centre canyons such as Broad Street where there is residential housing.

Any strategy needs to be based on realistic assumptions and well researched forecasting rather than wishful thinking about technological progress and radical changes in peoples’ behaviour.

For Bath to remain a vibrant and successful city we need people to come into the city centre and for the foreseeable future a large number of those journeys will be made by diesel and petrol driven vehicles. This is particularly true in the light of the failure to implement the previous transport strategy.

These vehicle journeys need to be managed better. People need to be encouraged to park out of town if possible and this requires the provision of good park and ride facilities near all the approach routes of the city. These need to be accessible to people when they need them so consideration needs to be given to extending the hours of operation.

Goods vehicles should wherever possible be incentivised to use out of city freight consolidation hubs.

Low emissions zoning can play a role in increasing the rate of uptake of both out of town parking and less polluting technology.

However, for the foreseeable future many people will, for a variety of reasons, continue to drive into the city centre and they need to be directed as efficiently as possible to adequate off street parking so that they do not circle the city’s streets adding to pollution by the sort of stop start driving this inevitably involves.

The loss of off street parking through the demolition of Avon Street multi-story will make together with the failure to provide proper park and ride provision to the east of Bath will make the situation considerably worse and is likely to substantially drive up pollution levels in the short term.

Urgent consideration needs to be given to replacing the Avon Street provision.

Sunday, 17 December 2017

The need for less planning and debating and more actions and results

The council recently published the final draft of the Bath Destination Plan. It contains the following paragraph.

"Bath and North East Somerset has built an enviable reputation for presenting major high profile events over the last 4 years, with a vision to be internationally renowned as a “beautifully inventive” entrepreneurial 21st century place with a strong social purpose and a spirit of well-being, where everyone is invited to think big – a ‘connected’ area ready to create an extraordinary legacy future generations"

This is a classic example of the sort of grandiose and almost meaningless goals which can be found in too many strategies produced by public agencies in Bath and being proposed by political parties and pressure groups.

It also contains numerous examples of the other kind of objective which is found all too frequently in Bath strategies, vision statements and plans. These are objectives for which there is no funding or resourcing and no realistic prospect of any funding or resourcing. Until recently the classic example of this was to be found in the air quality management plan.

We also have plans that will not survive the next round of elections because they are long-term in their nature but have no real cross-party by in the classic example being transport strategies, parking strategies and public realm management plans.

If we add to this the numerous forums, steering groups and scrutiny panels which produce  reports and analyses which will make little or no difference to the way in which plans are implemented in a world of shrinking government finance and will probably merely serve the political point scoring competitions which seem to be the preoccupation of many of our political representatives.

What all the above have in common is that they absorb huge amounts of officer time. This is officer time which could be spent addressing issues and practical problems raised on a daily basis by concerned residents or enforcing some of the existing rules and regulations or even trying to implement some of the old plans.

Friday, 8 December 2017

Community Safety

We recently attended the Communities Transport and Environment Panel scrutiny day looking  into community safety.

The day involved a variety of presentations which provided attendees with an opportunity to understand the national, regional and local perspective of community safety.

Speakers included; Cllr Anita Lower, Deputy Chair of the LGA’s Safer and Stronger Communities Board, the Police and Crime Commissioner Sue Mountstevens, the leader of Bath & North East Somerset’s Council Tim Warren, members of Youth Justice Service and Lucy Lord the Director, of Business Development & Communications of Women’s Aid who provided an insight into how Social Impact Bonds work.

Workshop sessions were held during the afternoon where and we chose to focus on the key city centre issue of Street Communities this was an opportunity to discuss some of the key concerns of residents with many of the key agencies involved.

Key topics addressed were:
  • Domestic Abuse
  • Prevent
  • Modern Slavery and People Trafficking, Facilitated by Jessica Wilde Anti-Slavery
  • Street Communities
  • The implications of mainstream funding for Community Safety has reduced by at least 60% since 2010.
  • The increase in complex crimes, such as child exploitation, and modern slavery, making multi agency work even more important.
  • The increasing need for agencies to shared priorities and responsibilities.
As a follow up to this meeting it has been agreed that the next meeting of the Responsible Authorities Group which coordinated the work of all agencies that have legal responsibility for these issues will include an agenda item where we can be updated on progress with creating better inter-agency working and provide an opportunity for us to explore residents community safety concerns in more detail.

Tuesday, 5 December 2017

Request for help cleaning

We have requested that BANES arrange a one-off clean up in the area between the river wall and the Waitrose service road in the city centre.  Local members have for many years done a weekly clean-up in this area which is used by the Genesis Trust's daily soup kitchen. 

The Trust does its best to keep things as tidy as possible but the accumulation of litter in recent weeks has exceeded our capacity to cope with it. 

This is mainly due to fly tipping of heavy objects and the use of the area as a litter dump and toilet by taxi drivers parked (illegally) on the road while awaiting fares.

If the council could arrange a one-off clean up in this relatively small area we could continue with our work.

Monday, 27 November 2017

Response to New Premises licence application at 66 WALCOT STREET

There are currently twenty three apartments at The Tramshed  immediately behind the above referenced premises.  They are occupied by households of all ages including children.  The building is currently under development to replace the former restaurant on the ground floor with a furniture store together with a further eighteen apartments on floors above.

Businesses operating at this address have previously held licenses as had the restaurant that preceded the furniture store referred to above.  We contend, however, that the hours requested by the applicant on this occasion which would extend the permitted sale of alcohol on and off the premises until 2.00 am Monday to Saturday and commencing at 7.00 am on Sunday are entirely inappropriate in a location of this sensitivity.  Compared with peer cities Bath has an unusually large proportion of its residents who have chosen to live in the city centre.  The existence of open drinking areas of the kind apparently proposed by the applicant and the noise emanating from the entrances and exits of licensed premises are among the commonest complaints that TARA receives from its members. The applicant has, moreover, apparently ignored Bath’s Cumulative Impact Policy which requires him to demonstrate that he is aware of the possible impact of his proposals on the surrounding area and that they will not adversely affect the city’s Licensing Objectives.  So far as we are aware no applicant has been granted hours this late since the Cumulative Impact Policy was introduced in 2007. 

We therefor request in accordance with the council’s Licensing Objectives 3, the Prevention of Public Nuisance, and 4, the Protection of Children from Harm, that the application as it stands be REFUSED. 

If, however, the council is minded to approve the application we ask that conditions be imposed as follows

·         That alcohol be sold solely in conjunction with menu-based food.

·         That no food or alcohol be sold for consumption off the premises.

·         That the sale and consumption of alcohol commence no earlier than 09.00 seven days a week and cease no later than 23.00 hours Monday to Saturday and 22.00 hours Sunday.

·         That the sale and consumption of alcohol and all licensable activities cease in the rear courtyard at 22.00 hours nightly rather than at 23.00 hours as we understand has been suggested by the applicant.

·         That customers enter and leave the premises only by the front (Walcot Street) entrance and that the rear entrance be used solely as a service entrance, staff entrance if necessary and fire exit.

·         That customers are prevented from gathering for drinking and smoking at the rear of the building.

Saturday, 11 November 2017

Walking and Cycling are not the same

Yet again in a BANES document, this time the consultation on the air quality plan, walking and cycling are treated as being the same with reference to walking and cycling strategies and routes as though the requirements were the same for both.

They are not.

Pedestrians need different provision and signage. They often need protection from irresponsible cyclists using, often illegally, the same space.

The impact on Bath of encouraging more cyclists in the city centre is different and we would argue worse, than encouraging more pedestrians.

Sunday, 8 October 2017

The poor state City Centre Public Realm

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?
What is the Council proposing to do to stop further deterioration? Is the plan to simply hope that developers and the BID's piecemeal efforts will fill the gap or will BANEs develop a proper strategy perhaps funded by a tourist tax?

Monday, 25 September 2017

Bath and Bath Politics a worrying picture

We now have a cabinet in which the representation of Bath is arguable reduced to one person and there is no representation from the core of the urban area or its unique problems.

For what look like political reasons politicians of all stripes  have chosen to  support a small number of well organised protestors over the interests and health of the majority of people and businesses in the City.

We have few, if any, neutral and well informed media outlets.

We have a new regional mayor whose views about Bath are yet to be clearly articulated but who has chosen to base his operations in Bristol.

We have a police and crime commissioner who was essentially elected by Bristol and has presided over a decline in community policing resources in Bath.

With less than two years to go to council elections we are seeing an increasing emphasis on political point scoring over debate aimed a resolving Baths issues.

The Bath City Forum has failed to deliver even the relatively modest things it was created for and is diverting resources from other arguable better forms of public engagement.

Friday, 22 September 2017

The Bath City Forum

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 effectively permanent members the subcommittee. The pool created are self-selected and represent only themselves.

Who made the selection from this rather narrow pool and what criteria did they use?

How can they be deselected?

To who, if anyone, will they feel answerable?

What are their priorities for and vision for Bath?

Some of those selected hold offices in organisations which have very clear and often controversial views on Bath City issues. Will they be acting independently or pursuing the agenda of these organisations?

What has the forum actually achieved? Many of their reported discussions appear to consist of political point scoring or grandstanding by individual members.

How much is the forum costing? Particular in the light of this already big committee spawning subcommittees. How much officer time is this absorbing?

Are councillors using referral of issues to  the forum as a way of avoiding confronting them?

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 many 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

Sunday, 13 August 2017

Trade waste

We are concerned about the permanent and semi permanent trade waste dumps which there are in the city centre. As far as we have been able to establish no one has authorised or licenced any of these dumps which are often positioned to block highways and pavements. Indeed highways officers have acknowledge that some are illegally blocking pavements but have taken no action.

Trade waste bins are large and invariably cause problems. They block highways and access to premises, they are often dirty and smelly and the attract litter and vermin. They also attract and encourage other forms of waste dumping and littering.

We are told bins have to be on the streets because businesses have no room to store them on site. This argument does not go down well with flat dwelling city centre residents who are expected to find space to store their rubbish within their homes for a week. It also allows business to ignore the consequence of their own poor waste management practices. If they had to store waste on their own premises and put it out for collection outside their own premises they would be much more careful about minimising dirt, smells and ensuring their waste did not attract vermin. It also offers them little incentive to invest in technologies that might minimise storage such as cardboard compactors and glass compactors.

In addition, we understand that some these businesses gave assurances to the planning authority about storing rubbish on site which they are now failing to deliver.

Many bins are located near listed buildings, in conservation areas and close to major tourist attractions.

 Although they often block pavements 24 hours a day seven days a week the highways authority do not take action. Why?

They are often a smelly health hazard but environmental protection takes no effective action. Why?

Waste dumped anywhere other than the perimeter of your premises constitutes fly tipping but waste enforcement takes no effective action. Why?

We have endeavoured on a number of occasions to engage officers in a discussion about these dumps we have also expressed our concern to the BID whose contractors collect from many of these dumps and who continue to give tacit support to these dumps in the teeth of complaint by both resident's and businesses.

Friday, 28 July 2017

The hotel development on South Parade

The beleaguered residents who are neighbours of the hotel development on South Parade have revived a suggestion they made a year ago that they should be allowed free Parking Spaces in the Manvers Street car park. To compensate for the loss of on street parking.

When they first raised it BANES rejected the idea. But they have now suffered another year of misery and disruption so feel their position should be reconsidered particularly as they have learned from the contractor’s staff that BANEs are being compensated for their loss of revenue.

This development continues to be a mess that reflects badly on BANES and highlights what we have been calling for some time, the need for a proper review of how BANES approves and monitors major construction projects in the city centre.

Wednesday, 12 July 2017

20 mph schemes in Bath £871,000 well spent?

Since 2011 BANES has spent £ 871,000 introducing 20 mph speed zones in Bath and wider BANES. There was no enforcement process built into any of these schemes, indeed the police complained at the time that they had not been consulted, and we expressed some doubts as whether without enforcement these zone would have any real effect.

Well the results are now available in a report to be considered on the 17th July by the Communities, Transport and Environment Policy Development Committee;

The study has found that,

a) Broadly speaking, speed reduction in line with national trends has been achieved, but in real terms the overall reduction in average speed is very small (1.3 mph) and thus is not persuasive in terms of the money spent on these schemes.

b) Some accident reduction has been observed in Bath, but accident increase, albeit slight, has been seen in outlying towns. Again, this mixed outcome seems to be reflected across the country.

c) Casualty severity has worsened marginally in Bath and more so in outlying towns. Again, this is reflective of the national situation for reasons which are not yet clear. A number of the schemes have not yet been in place for 3 years and thus the casualty picture might alter over the remaining months.

d) Overall, the speed limit programme in B&NES seems to have provided little in the way of persuasive argument for continuing the programme into the future.

e) Indeed, the rise in casualty numbers and severity as per the national trend (albeit with relatively small numbers in B&NES) would suggest against further expansion of area based schemes.

It seems our cynicism about likely value of these schemes was justified.

Tuesday, 11 July 2017

BANES U-Turn on Transport Plan

So yet another expensively created transport strategy for Bath is abandoned having been used as a political football by all our elected representatives for two years.

Two years on and millions of pounds later we are back to square one with another vague, largely unfunded strategy which will become a political football again  in two years time at the council elections.

Meanwhile, the health of thousands of city centre residents, not to mention workers and visitors, continues to be damaged.

It is also clear that by appearing to give in to the bullying tactics of minority, as shown in repeated surveys of public opinion, politicians of all stripes  have made a rod for there own backs. Any minority group will now think they can protect their narrow interests by bludgeoning the council in the same way.

Monday, 19 June 2017


We would appreciate it if action could be taken by officers on two related matters of concern to members in the Cattle Market area in the city centre.

Fly Tipping.  For as long as any of us can remember vacant land adjoining the river wall on the east side of the Waitrose service road has been used by local churches for their evening soup kitchen.  Local residents have always supported this charitable act; the organizers do their best to keep the area clean but local residents venture out on Sunday mornings to clear the area of accumulated litter and rubbish originating not only from the soup kitchen but also the Saturday Market which is held in the adjoining Cattle Market car park.

Lately however, two large crates and other sizable objects have been fly-tipped in this area; these have gradually filled with rubbish and litter and clearing the mess is now beyond the resources of local residents.  It would be appreciated by all of us if a crew from Environmental Services could clear the crates and associated mess from the area along the river wall, which they do not normally visit, so that we can continue with our work.

Illegal Stopping and Waiting.  We have noticed that the above referenced mess has been exacerbated by taxi drivers who have taken to stopping and waiting for indefinite periods on the double yellow lines on the east kerb of the road creating what amounts to an informal taxi rank.  This can happen at any time of the day or night but particularly during the evening hours when six or seven vehicles can sometimes be seen parking here.  The situation is made worse by the fact that they use the adjacent land as a toilet and contribute to the accumulation of rubbish and litter which local residents have to clean up.

Thursday, 8 June 2017

Objection to expansion of Sea Cadet's Building

17/01939/FUL  30 ST JOHNS ROAD
In summary we ask that this application be REFUSED.

Planning Policy.  Under a previous decision, 16/03359/FUL, permission was granted for improved facilities for the Bath Sea Cadets who have been based at this location for many years together with accommodation on two upper floors for university students comprising eighteen units in single and double occupancy.  This proposal is currently under construction.

While we accept that the placing of student accommodation on this site is consistent with national and local planning policy and guidelines the council nevertheless has various Retained Policies from the 2007 Local Plan under which it is obliged to consider any impact on the amenity of local residents when planning applications are being considered.  These include Policies S6, S7 and D2f which states: ‘Development will only be permitted if it will 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 or increased overlooking, noise, smell, traffic or other disturbances’. 

We contest that, while the term escapes precise definition, if the current application is granted and the building currently under construction enlarged accordingly the result will effectively be over development of the site to the disadvantage of existing residents.


We understand from local residents that for all practical purposes there has been no consultation whatsoever on this or on the previous proposal.  Attempts by residents to initiate  a dialogue with the Sea Cadets, the developer and the contractor have all failed.  It should be noted in this connection that the present applicant is not the Sea Cadets who applied for and received planning consent for the building currently under construction but an agent for an un-named third party.  Indeed we are informed by local residents that it is their understanding that the statement on the front of the Design and Access Statement that its contents are presented ‘On Behalf of the Sea Cadets and Rengen Ltd’ is false in that the application for the proposed extension was not initiated or asked for by Sea Cadets and was carried out without their prior knowledge.

Scale and Context.  Notwithstanding the policy context as well as efforts by the design team to modulate the roofline and the east elevation this project has always seemed to local residents as a bulky and unwelcome intrusion into the quiet residential street in which they live.  The addition now proposed in our view tips the balance and will result in an excessively overbearing presence in the traditionally domestic scale of the street.

It should be noted here that the Grade 2 listed former Bathwick Church of England School which was described in the Committee Statement relating to the previous application, 16/03359/FUL, as having ‘a strong presence in the street and…particularly important in its interpretation of Gothic Revival architecture’ lies immediately across the street from 30 St Johns Road.   The council is reminded that under Planning Policy Statement 5, DCLG March 2010, (Policy HE8.1) ‘The effect of an application on the significance of...a heritage asset, or it’s setting, is a material consideration in determining the application’, and that under Policy HE8.7 ‘local planning authorities should take into account the desirability of new development making a positive contribution to the character and local distinctiveness of the historic environment.  The consideration of design should include scale, height, massing, alignment, material and use.’

It would be one thing in this context for the proposed extension to be to be seen to be adding significantly to the community purpose for which it was primarily intended and  which was seen as a positive factor when the previous proposals were under consideration.  However not only do the benefits of the current proposals seem marginal to the point of insignificance but it is our contention that the resulting structure, already overbearing in relation to the varied and domestic scale of the streetscape surrounding it, by its additional bulk, risks compromising the setting of a valued heritage asset, something which in a World Heritage Site and Conservation Area should be firmly resisted.

Social Impact.  If the impact of the building in its completed form can be said to be overbearing in relation to its surroundings the same can be said of its social impact.  The provision of storage for rubbish bins for a resident population of 29 appears to be totally inadequate when the needs of the Sea Cadets themselves are taken into account.  This raises the likelihood that bins will be left on the street.  Provision of storage for nine cycles also appears to be too low.  In neither case do the current proposals provide additional storage space despite the increase in student numbers.

Car ownership and use by students is higher than is generally realized.  A 2010 UWE study showed that 87% of students surveyed had full driving licences and 57% of those living off campus arrived on campus by car as drivers or passengers.  No on-site parking space is provided in the proposals under consideration.  St John’s Road has about 80 numbered residential addresses, mainly one to three storey single household homes with a number of apartment complexes ranging from nine to twelve apartments and a care home.  There are roughly thirty on-street residents parking spaces.  Clearly the addition of 29 students in a single location will put pressure on this scarce resource.

Space and Light.  While we recognize that the council does not enforce standards for a minimum distance between buildings this proposal reduces the distance between its north wall and the south wall of No 31 St Johns Road from 3.0m to, by our measurement, about 800mm.  This is not in our view sufficient space to allow for the maintenance of the neighbouring property such as replacement or repair of the bathroom window.

In addition the proposed extension reduces light and direct sunlight available to the from and rear bedrooms of the neighbouring property to the north.

Conclusion.  We conclude that this application should be REFUSED on the grounds that it constitutes unnecessary over-development of a constricted site in a street of traditionally domestic and residential scale which will lead to a deterioration in the amenity of existing residents.

Monday, 29 May 2017

A Letter to the Leader of the Council

Dear Tim,

It seems to have become fashionable to send you letters critiquing the performance of the council. We have joined this trend because we think it is important that you get a wider and more represented set of views than those expressed by the rather narrow range of special interest groups who have written so far.

Looking at the correspondence that you have received we were surprised to see that their principal criticism seems to be you and your colleagues lack of willingness to meet and discuss issues with residents. We were surprised at this both because our experience has been entirely different and because we have seen and heard many of these groups at a number of discussion forums organised by BANES and attended by yourself and members of your cabinet.

On the substantive issues raised by groups like Bath Deserves Better:

As you know we strongly support the development of an eastern park and ride. We are primarily concerned with the real and serious health threat to city residents created by pollution. A key part of any pollution reduction strategy is implementing the Bath Transport Strategy. This strategy has taken many years to create, cost considerable amounts of money and been developed in conjunction with some of the county leading experts and has always included an eastern park and ride. While it was entirely appropriate to hold a detailed discussion on the choice of site the time has come to stop talking and put peoples' health first.

We are delighted that at a time when many councils are withdrawing from the provision of professionally managed libraries BANES are investing in the city centre library service and in particular its increasingly important and popular IT facilities. We are particularly pleased to see that you are merging the management of the two important historic archives and upgrading the facilities for accessing them. We understand that people have an emotional attachment to the old premises and that some user groups might have specific concerns which need to be addressed and look forward to participating in further discussions about how various needs can be and perhaps should be met.

As you are aware we are keen to speed up progress on a number of issues affecting city centre residents and in particular:

           Improving the quality of formal consultations

           Creating a more consistently customer focussed organisation

           Removing unauthorised trade waste dumps

           An improved dialogue with Universities about their impact on the city

           Stalled traffic management projects

           Reviving the vital but moribund Public realm and Movement Strategy

           More effective measurement of the most dangerous components of city pollution

           Short term pollution reduction strategies

           Addressing the challenge of rough sleeping and begging

           Improving policing and enforcement

           The problems created by various forms of short term letting

           The better management of building projects in the city centre

We look forward to a continuing constructive dialogue with you and your colleagues about how this can be achieved.

Tuesday, 23 May 2017


Notes on transport and access proposals


·        Bath is a regional transportation hub.  Would be impossible to locate a stadium in the city centre if this were not the case

·        Nearly half of fans travel by public transport (47%, about 30% by train) or by P and R.

·        No dedicated parking provided at the stadium

·        Almost all fans reach the stadium itself on foot


·        Nearly 40% (36.2%) of fans arrive as car drivers or passengers.  Need to get this number down.  This is about reducing both congestion and air quality

·        Cars circulate in search of parking adding to harmful emissions

·        Illegal parking rife in residential streets around the stadium and there is a lack of policing and enforcement

·        Serious pedestrian congestion in streets around the stadium.  Pedestrian links to city centre inadequate.  About a third of supporters spend about four hours in the city centre in addition to match time


·        Encourage greater use of public transport and P and R. 

·        Incentives: discounted tickets, beer vouchers, etc

·        Batheaston P and R essential to provide additional capacity

·        Following line upgrades new trains could enhance capacity

·        Incentives to increase use of buses.  No current changes to match day timetables

·        Improve pedestrian access to the stadium.  New foot/cycle bridge across the river linking stadium and sports centre to the city centre.

·        Extra parking enforcement on match days, tow trucks, enhanced penalties, etc.

·        Ban on coaches leaving engines running

·        More bike racks