Thursday, 10 December 2020

Practical issues with deliveries in the proposed security zone

We are told that BANES are engaging with companies about how they will work with them and residents to ensure that residents can get goods and services delivered and we were asked to comment about which firms need to be included.

To start with we need to consider urgent situations which are likely to require heavy equipment either to undertake work or to replace failed equipment.

Clearly, leaks of water and gas require arrangements to be made quickly with Utility Companies but also emergency plumbers.

Breakdowns of critical equipment like cookers, fridges and heating system require prompt access by electricians, plumbers and white goods sellers.

The discovery of dangerous or worn installations requiring rewiring or the replacement of obsolete equipment requires access by plumbers, electrician and utility companies.

Loss of telephone and or internet connection requires access by Openreach and contractors of ISP’s many of which have tight rules about how far they will transport equipment by hand.

Many vulnerable people in the zone depend on carers and cleaners who often have equipment to carry and are operating to very tight schedules, often imposed by NHS subcontractors.

However, there are many non-urgent deliveries where the proposed arrangements, which seem to be based on commercial deliveries which can are easily scheduled, would create major issues in a residential context. Residential deliveries are not like commercial deliveries:

  • Suppliers and their sub-contractors often have inflexible delivery booking processes mediated by machines not people
  • Unlike shops, houses and flats are not permanently manned during working hours
  • Few suppliers offer to provide details of delivery staff or vehicle identity numbers or descriptions and we doubt if many would be able to do so.
  • Few suppliers can or are prepared to offer very tight delivery slots the best most offer is 4hr targets. 

We would reiterate that it is unfair to put residents, particularly elderly residents, between the rock of supplier inflexibility and the hard place of an opaque bureaucratic process particularly one that operates at the glacially slow pace BANES seems to be anticipating.

Monday, 30 November 2020

Bath City Centre Security Proposals

The council intends to create a security cordon excluding vehicles from the entire commercial core of the city between Southgate and Upper Borough Walls (Milson, Green and Broad Streets are excluded). This will be done using existing fixed bollards plus five new moveable bollards controlling entrances to York Street, Upper Borough Walls, Cheap Street and Lower Borough Walls.

Within this area, access will be controlled by CCTV twenty-four seven. There will be a daytime and night regime allowing access for emergency vehicles, waste collection, commercial deliveries, etc. All residential vehicles, all parking including Blue Badge parking, parcel and package deliveries and taxis are banned twenty-four hours a day. You can get special access permits but it will take twenty working days.

Anyone living in this area will be essentially trapped unless they are able to walk, cycle or use mobility vehicles to reach shops and other facilities including Blue Badge and general-purpose parking areas. It is admitted that there are as yet no detailed plans for how to deal with taxis and for mobility-impaired residents. Emergency vehicles have five entrances to the area controlled by CCTV and will radio ahead to ensure access. Residents will be expected to book any vehicular deliveries or access by tradesmen several days if not weeks in advance when after a complex bureaucratic review which will require information about things like the vehicle identification numbers and the name of the driver they may be issued with a tightly restricted pass. The area contains St Johns Hospital, Arlington House and the Min Building.

The will be no parking in this area at any time.

The justification for all these draconian restrictions is vague but appears to be that in the past terrorists have used vehicles as weapons in crowded areas. This begs several questions:

  • Why this crowed area? There are many other city centres which attract crowds is the intention to lock them all down? There are other areas of Bath and BANES which attract crowds can we expect these restrictions to spread?
  • Why focus on this particular type of attack? Recent attacks have, for instance, been carried our by pedestrians with knives and rucksacks full of explosives. Does this mean we can shortly anticipate metal detectors and baggage searches before you can enter this part of Bath?
However, even if we concede the justification for these restrictions the plans seem to be designed to bear down on residents far more that is justified or equitable to such an extent that it almost seems aimed at deterring people from living in this area altogether.

The council seems to have given no consideration to helping or compensating residents at all and have only recently started to look at ways of helping even severely disabled residents. The current proposal leave disabled visitors a long way from the most popular shops.

Some example of where we believe BANES should be looking to support residents include:

  • Turning the proposed system for booking deliveries and trade visits on its head. Rather than leaving residents between the rock of an opaque bureaucratic permit process and the notoriously inflexible booking processes of major companies and harrassed small traders, residents should be able to contact council officers explain what they need and why they need it and have the council contact the companies concerned gather the information they need and make the arrangements for access.
  • Given the consistent failure of both central government and BANES to provide adequate affordable public transport a car is still essential for many city centre residents. We have already seen a considerable reduction in parking provision and these proposals will add to that. It is time that BANES acknowledged this reality and allocated "residents only" all-day parking in city centre car parks for residents in the area covered by these and other proposals to remove parking spaces.
  • We are advised that these proposals are likely to have an impact on property values in this area and we think that resident thus affected are entitled to get compensated
However, we would propose that BANES scrap this scheme in its current form and rethink city centre security when they have:

1. Identified a way that taxis can operate freely in the security zone. Many residents, particularly the elderly, depend on taxis for hospital, care home and shopping visits. Hotels with no on-site parking cannot operate without a taxi service.

2. Identified a way of allowing small package and food deliveries without twenty-day advanced consent. Many residents, particularly the elderly, depend on deliveries for food and online purchases.

3. Agreed to allow residents who drive cars to freely enter and leave the security zone even if they have to park elsewhere. Many residents depend on their cars for non-local shopping for themselves and their friends and neighbours.

4. Agreed to allow Blue Badge holders to park within the security zone as they do at present.

5. Demonstrated that the proposals have been successfully implemented elsewhere under similar circumstances.

BANEs should recognise that the city centre is at risk from more than just terrorism. The economy of the area is under threat from online retailing combined with the effects of Covid19 and new planning regulations can be expected to erode the council's long-standing, and wise, policy of maintaining retail frontages. At present, a much higher proportion of Bath residents live in city centre wards than in comparable cities (6% as compared with 3-4%) and they do much to support commerce there. To make the city centre a considerably less attractive place to live can only add to the challenges.

Wednesday, 14 October 2020

The Government's White Paper on Planning Reform

There are many issues of concern in the Government's proposed reform of the planning system and many of its proposals will greatly reduce the ability of local residents to participate in decisions about developments in their area. For instance:

The approval of new development in growth zones will shift to the plan-making stage. The traditional process of politicians deciding planning applications with opportunities for the public to make representations is effectively at an end.

The White Paper suggests that people’s right to be heard in person will be changed. The paper states that inspectors will now have discretion as to what form an objector’s representations might take. Under paragraph 2.53 the paper goes even further and suggests any form of ‘right to be heard’ might be removed.  The right to be heard at Section 20 of the 2004 Planning Act is the only clear civil right that exists in the planning process for the individual citizen. The right includes the important phrase ‘in person’ in order to allow an individual to appear in front of an inspector and exercise other opportunities to cross-examine witnesses.  So, the opportunity to appear at a public inquiry has been replaced with the opportunity for an inspector to have a telephone conversation with you, or ask for further written comments if they choose to do so.

The White Paper does not provide a single new right for community participation or a single new opportunity for a democratic moment in the plan-making process but rather reduces both rights and opportunities to participate. The only potential additional opportunity comes from the White Paper’s belief that digitising information will encourage community participation.  Digital information can potentially lead to more openness and will hopefully make planning more accessible, but it does nothing on its own to give communities more control over their future

For Bath, there is an additional concern a little-noticed comment about "exploring whether suitably experience architectural specialists can have earned autonomy from routine listed building consents." This clearly opens the system to abuse as it leaves open such questions as:

What criteria will be used to decide if autonomy has been earned?

Who will judge whether these criteria have been met and continue to be met once autonomy has been "earned"?

What qualifies as "routine"?

TARA Response to the Liveable Neighbourhoods Consultation

As an organisation that has been in existence for 20 years, we approach the current liveable neighbourhoods consultation and debate with a degree of cynicism. In twenty years we have seen many proposals for improving traffic management and the quality of the public realm in Bath many of which have had the benefit of expert input, sometimes expensively bought, have been subject to extensive consultation and offered many benefits if their conclusions were implemented but to date none has. They have fallen foul of a lack of finance and often becoming part of a political football match as soon as trade-off needed to be made or elections loomed. Against this background, it is concerning to note that at a time when the council is facing a financial crisis the proposal for the livable neighbourhood are as far as we can tell largely unfunded.

In principle, we support the thinking behind liveable neighbourhoods. There is potentially much to be gained from fresh ideas about how street space in residential areas, too much of which is currently assigned to vehicles, could be used. The idea that extraneous traffic should be confined to perimeter roads has been in use in city centres for decades. Experience has shown, however, that caution is needed in transferring such ideas to residential neighbourhoods.

One of the key criteria for success is that there should be really effective consultation at all stages with residents who are likely to be impacted. This raises some concerns about the initial consultation process. The consultation is largely online thus making it difficult for the very many residents who suffer from digital exclusion to participate particularly at a time when IT facilities and support are not available at local libraries. COVID restriction means that there is little opportunity for residents to attend the sorts of educational events that were held as part of the CAZ to help people understand the research base of these proposals and decode the jargon. We are also concerned that this consultation is vulnerable to attempts by well-organised lobby groups to drown out the voices of local residents.

The council needs to ensure that where liveable streets are being considered residents are aware that trade-offs are inevitable. For example,

Access. While reducing rat running and parking by commuters is undoubtedly a gain there will always be an irreducible need for access for vehicles, not only to residential areas but even to individual homes, particularly for waste collection, for emergency vehicles, for taxi pickups, for local buses if car usage is to be discouraged, and for increasing numbers of delivery vehicles as on-line retailing takes hold. And there will those for whom the alternative modes available, walking, cycling, e-scooters, electric bikes, etc, are impractical.This implies a continuing need for car parking for residents, and for visitors, carers, etc, which, in the relatively high densities typical of Bath, is likely to be mostly on-street parking.

Displacement. The council will be well aware that reducing the amount of space on residential streets available to vehicles may cause some residents to use other means of travel but many others will simply transfer to alternative routes on the network thus leading to increased congestion on perimeter roads and in neighbouring residential areas where improvements have yet to be made.

Journey times. Residents need to be aware that any welcome improvement in environmental conditions may have to trade off against increased journey times as traffic circulation in their local streets is reorganized.

Maintenance. New planting, lighting, and seating is to be welcomed but who will maintain it? As things stand the council is barely able to keep residential streets free of litter.

The concept of "Liveable Neighbourhoods" needs better definition in relation to places like Bath too much of the current definition refers back to the Waltham Forest example. Waltham Forest and Bath have little in common for instance in London people have access to plentiful subsidised public transport. Experiences in London of trying to deploy schemes based on the Waltham Forest example have reinforced the need for high-quality public engagement programmes that clearly set out the likely trade-offs which are inevitable. We note that several London schemes have had to be abandoned.

One notable omission from the BANES consultation is any real proposals to reduce the overall amount of traffic coming into Bath either through disincentive scheme or diversions such as an A36-46 link or through improved access to public transport. Without this, the issues of access and displacement are likely to be magnified to an unacceptable degree.

Another mechanism for reducing traffic coming into the city which has been further highlighted during Covid is remote working which places an emphasis on the provision of high quality IT and communications infrastructure. This again does not seem to be addressed in the BANES documentation.

The mention of COVID raises another issue; these proposals are being put forward at a time of great potential change in the likely role of neighbourhoods. We are looking at much more home working with its attendant shift to neighbourhood shopping, we are seeing an acceleration in the decline of traditional shopping centres and potentially a comparable decline in the commercial property market and it is far from clear how BANES see these trends being factored into the debate.

In contrast to many of the other issues, the role of cycling seems to gain undue prominence in BANES proposals. As city centre residents we have some issues with this emphasis. Firstly many city-centre residents are elderly and cycling is not a viable option for them, particularly given Bath's topology, electric bikes are an expensive solution which only partially addresses this issue. Also, most city-centre residents live in flats and have limited storage capability, certainly for storing something as bulky as a bike, in addition to that many city-centre buildings are listed and have no lifts.

We are also concerned that too many BANES documents refer to facilities for cycling and walking as if those these two were equivalent activities. Many of our members find the increasing intrusion of high-speed bicycles into what should be pedestrian spaces unacceptable, and for those with mobility issues, frightening.

As we have said many city-centre residents live in flats and few have access to off-street parking all which calls into question strategies which feature plugin vehicles. Flat dwellers would be financially penalised as they would be forced to use expensive public charging provision.

We have considerable concerns about the council's proposed mechanism for identifying and adopting a liveable neighbourhood. Few residents have any training in traffic engineering or urban design nor do they have access to data and modelling software. The council's approach is already generating some rather questionable plans and is already creating conflict between groups of residents with competing ideas. We would have preferred the council to use its expertise to proposes viable schemes which formed part of a wider strategy and focussed residents efforts on evaluating this plan. From the council’s point of view this would also avoid the problem of raising un attainable expectations about what is achievable.

This issue is particularly acute in the city centre where there are numerous legitimate stakeholders whose competing needs need to be carefully balanced. We and many other of these stakeholders have been concerned at the lack of consultation over the emergency schemes which been put in place, the lack of feedback about the many experimental schemes and the prominence given to calls for pedestrianisation schemes in the absence of an overall plan for improving the city centre overall.

Tuesday, 29 September 2020

Residents' Parking

There has always been inadequate provision for residents parking in the centre of Bath and city centre residents do not enjoy the privilege accorded to other Bath residents of having visitors permits.

This already inadequate provision has been further eroded by the unjustifiable practice of selling quantities of on-street parking permits to hotels and B&Bs for onward sale, often at a substantial markup, to their guests.

Residents on-street parking spaces are regularly taken away from residents and allocated to film companies and developers, in the latter case sometimes for years. While BANES often receives substantial compensation for its loss of parking revenues little of no thought is ever given to compensating residents' for their loss of amenity. 

Motorcyclist are allowed to take up car parking spaces without charge and we have seen a recent example where the council has taken away parking spaces from car users and dedicated their use to motorbikes.

The fashion for pedestrianisation schemes has removed further parking without any consideration for residential amenity or access.

Traffic schemes, carried out under Covid emergency legislation, have further reduced residents' parking and the suspicion must be that some of these schemes will become permanent. When plans for electric charging points are rolled out it is not clear that the bays are taken out of commission for non-electric vehicle will reflect the reality that electric cars and plug-in hybrids will not be viable options for the majority of Bath residents for the foreseeable future.

Monday, 3 August 2020

Licensing Application Reference: 20/01103/PAVE

We are sympathetic to businesses struggling in the wake of Covid 19 and consequently have not objected to any similar applications. However, this application is taking advantage of the more relaxed procedures to move beyond what is reasonable even in these extreme times. The proposal to put tables in North Parade Passage leaving only 2 metres passing space in one of the narrowest and busiest pedestrian routes in Bath would be unacceptable even if people were not being told to socially distance. 

 It is, however, the large block of tables in North Parade Buildings which is most objectionable. This amounts to a proposal to create a new business by taking over what is currently a rare residential enclave in the city centre. The proposal places a large number of tables within 2 metres of the windows of listed Georgian buildings that have limited ability to introduce soundproofing measures, particularly in hot weather. The applicant offers no comment on noise nor do they suggest any noise management or mitigation measures. As well as generating considerable noise a large number of tables and chairs will effectively block residents and their support networks from easy movement to and from their homes. Many residents are elderly and have mobility issues. 

We note that disability groups have already highlighted the issues created for those they represent with the expansion of alfresco dining elsewhere in the city. This access issue would be unacceptable, even if the applicant has procedures in place to tightly control the behaviour of customers and keep them within the designated area. 

The applicant has not outlined any such procedures and observation of other similar alfresco dining areas, licensed by BANES, suggest such procedures do not exist. This is all bad enough, but to suggest that residents would have to put up with this noise and obstruction from 9 in the morning until 11 at night is completely unreasonable. Would the end time, in fact, be 11pm because the tables would have to be cleared and that is a noisy process in itself? 

 As we have said we are sympathetic to the plight of local eateries in these exceptional times and understand that BANES is prepared to relax its standards and procedures to help. However, there still have to be limits. BANES has a duty of care to its residents and council taxpayers and it is our contention that granting this license would breach that duty.

Friday, 31 July 2020

Sally Lunns

While we are sympathetic to businesses struggling in the wake of Covid some application for using the pavements for dining are taking advantage of the more relaxed procedures beyond what is reasonable. Sally Lunns are we believe are an example. 

They are effectively proposing to take over a residential area of the city centre to create a new business running till 23:00 hrs which will create noise and severely reduced space to walk safely. Many local residents are elderly and live in buildings vulnerable to noise. The application is as follows:
Every Day, 09:00 to 23:00
Dimensions of area
9m x 2.1m and 2.8m x 14m
25 tables, 50 chairs
In Northumberland Buildings

Saturday, 25 July 2020

Pedestrian spaces

Amid all the furore about pedestrianisation, low traffic neighbourhood and the health benefits of walking we have noticed that in reality space for walking is becoming harder to find.

Most highways plans, in fact, do not even refer to spaces for walking any more but spaces for walking and cycling. This probably reflects the success of a well-organised cycling lobby but fails to recognise the inherent conflict between pedestrians, particularly pedestrians with mobility issues, and cyclists in shared spaces.

Cyclists who claimed that they had to use pavements because of the amount of traffic continued to use pavements during the lockdown when there was little or no traffic on the roads. Officialdom still does nothing to stop or even impede cyclists travelling at speed and/or in large groups through the cities pedestrian routes and green spaces.

Some time ago when CART announced it intended to create a high spec metaled surface on the canal towpath local objectors warned that this would turn a much-used foot route into a cycling race track. At the time the cycling lobby mocked this suggestion but anyone using the towpath now will know the objectors were right.

The council has used its emergency powers to widen pavements to allow social distancing but still, nothing is being done about pavement parking which often undoes their efforts, as do restaurants which expand beyond their licenced outdoor table areas or shops who brake the a-board regulations.

Pavements broken up by cars and commercial vehicles remain unrepaired for long periods of time creating further hazards for walkers.

We see calls for more planters in pedestrian spaces in the city as well as calls to greatly expand alfresco dining on city centre pavements and pedestrianised areas. Neither, of these we object to in principle but they do not seem to be part of a well thought through plan and seem to ignore the needs of pedestrians.

Finally, we see calls to allow electric scooters and electric bikes to be added to the skateboards which already weave around startled walkers.

At one stage BANES paid for a well-research strategy for public realm spaces and movement through them but this was never implemented what now seems to be on offer is a smorgasbord of fashionable urban planning experiments often taken out of contexts quite unlike those that prevail in Bath.

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/café (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.