Friday, 29 June 2018

Gambling Act 2005 Statement of Principles

We are broadly supportive of the proposed principles.

One specific issue which has been raised by residents which does not seem to be explicitly addressed is displays visible outside the premises which are not directly advertising gambling but are likely to attract young people to the premises an example being TV screens showing major sporting events.

We are also not clear how the enforcement regime will be modified to address the challenge of policing a casino operating over much longer hours than traditional Bath gambling establishments.

Tuesday, 19 June 2018

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

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

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

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

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

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

It has been suggested that pedestrianisation is the magic bullet to improve air quality in the city centre. TARA has a long history of fighting to get improvements in air quality and this has shown us that the issue is much more complex than this and those advocating extensive pedestrianisation need to acknowledge this or we will fail to have the result that we would all wish to see. This is particularly true if we move from our current focus on NOX to the much more dangerous small particulate pollution.
We currently, for the first time, have a relative well funded project involving outside experts looking at pollution issues undertaking measurements and building models against which to evaluate potential approaches to improving air quality and we think the output of this work should be the starting point rather than simply espousing any particular solutions ahead of evaluating their data.

Thursday, 14 June 2018

The need for national legislation

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

Pavement Parking

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

·         Legislation on pavement parking


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

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

Short term letting

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

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

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

Outside London local government is struggling with case law which can only be applied in very limited circumstances.
We need legislation which unambiguously gives planning authorities powers to reclassify premises use for holiday letting as business use.

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

Housing Associations

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

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

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

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

Sunday, 3 June 2018

The Street Trading Policy Consultation

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

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

There is a focus in the policy on the number of stalls that should be allowed in particular locations we think this is the wrong starting point. It’s not an issue about numbers it' s about the amount of space they take up, both their allocated space or the space they occupy in practice.
We support the idea of assessment criteria because it is important that Bath as a destination is managed with focused on high quality and diversity not just trading volume.

The council say they are exploring other ways of managing street trading on a day to day basis.  This could be by the Council as it is currently, or through a third party. Here, the key issue for residents is enforcement of the agreed policy's and rules and we will support whatever delivers this most effectively.
The policy proposals call for the creation of markets that "should be beneficial to the local area". We believe that this should mean that they should add to the local retail offer not merely compete with it. They should be managed to minimize disruption to local residents. They should where possible offer benefits to local residents such as discounts. special access or contributions to local community organisations and causes.

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