Thursday, 4 February 2021

TARA's Comment on the Local Plan Update JANUARY-FEBRUARY 2021.

In this submission TARA requests that the Council give serious consideration to a revision of its policies relating to HMOs. (Homes of Multiple Occupation).


On March 16th  2020, under delegated powers, The Council granted consent for the conversion of a two bedroom flat at 75 Rosewell Court in the city centre to an HMO (20/00127/FUL).  

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 policies 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.

But these were 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 was granted provides for the transformation of 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 under Policy H2, but by that time it will be too late.


The above case suggests an inherent potential conflict between Policy H2 and Supplementary Planning Document, Homes in Multiple Occupation in Bath.  TARA therefore requests that the Council consider adding to, or amending, its policies in relation to HMOs so that an application for an HMO will be refused where its presence would be in conflict with other Council policies such as Policy CP9, Affordable Housing, relating to the provision, or protection, of housing provided for, or occupied by, specific groups in need.


TARA has consistently supported the principle of development of a rugby stadium at the Rec and continues to do so subject to details and conditions.  We do not consider that any outstanding legal issues in connection with any specific proposal are planning matters.  We do have a number of specific concerns including building height and bulk, traffic, parking and pedestrian flows and the amenity of TARA members living at the Empire but these are detailed matters to be resolved if and when a planning application has been submitted.

We therefor conclude that the Council has no overt basis for altering existing policy and request that Policies B1 and SB2 should be retained in their existing form.

Friday, 8 January 2021

TARA's response to the One Shared Vision Consultation

BANES was, perhaps more than any other authority that emerged from the last boundary changes, an uncomfortable artificial construct. Bath itself is a unique city with its status as a major heritage destination and an unusually large and diverse number of people choosing to live in the heart of the city. Any vision which attempts to accommodate this diverse and eclectic area risks being anodyne, unambitious and a poor basis for inspiring or driving real change.

Bath as a city has probably had more effort and money spent on creating visions and strategies than any other city of comparable size in the world and its unique status has attracted the interest of some of the world’s leading experts. Unfortunately, none of these visions and strategies has been realised in practice and every new administration seems to feel the need to restart the processes from square one thus compounding the problem.

That having been said our comments on the individual visions are as follows:

15 Minute Neighbourhoods

One could argue that the city of Bath is already a 15 minute neighbourhood.  The main effort here needs to be the repair of the damage done by the combination of Covid and the long term effects of online trading and in the impact it has had on the availability sports, leisure and in particular cultural facilities and of course the impact on retail diversity.

There would seem to be four major omissions from the vision as presented:

  1. It seems to ignore the need to deal with the basic hygiene of repairing roads and pavements, clearing rubbish, managing trade waste properly etc. Currently few of these hygiene issues is well managed and this has a disproportionally negative impact.
  2. What will Bath look like in 2030? Will we have finally updated and implemented the Public Realm and Movement strategy and style guide?
  3. Most people in Bath live in flats. It would be nice if by 2030 BANES acknowledged this and all policies were tested for their impact on flat dwellers.
  4. The vision says nothing about Public Transport. If car use is to be reduced affordable public transport that has routes designed around need rather than profit will be crucial.

Heritage of the Future

The obvious omission from from this is the vital role played by residents. Residents live in and bear the cost of maintaining huge amounts of the built environment that attracts visitors. Residents fight to maintain the quality of city services. Residents put cash into businesses during low seasons. More importantly residents create the vibrant and welcoming city culture that so many visitors cite as a core part of their experience. If you want to see what happens to a heritage city that fails to acknowledge and support the contribution of residents we suggest a visit to Venice.

Hopefully, by 2030 BANES will have taken back the management of its tourism offer back from Bristol and will have a properly resourced destination management organisation.

Nature and Landscape

Much of this vision, at least as far as Bath is concerned, is being realised already. The countryside around Bath is well used and well loved. The main issues with this vision is highlighted by this popularity. We are  not creating anymore countryside and indeed some recent policy decisions look set to take some of it away and the more popular it becomes the more crowded it becomes. This vision rather ducks the issue of how this will be managed. One suggestion would be to take steps to ban all vehicles, including bicycles,  from footpaths and towpaths. Given the plans to reduce traffic on roads and create new dedicated cycle routes this would seem to be easily achievable.

Fairer Financing

We have no comment on this but would be interested to see the research on which it is based and hear some case studies from places where this has been successful.

Business and Innovation

One of the many trends accelerated by Covid is that knowledge workers are now able to, and choosing to, live in places that provide them with the best lifestyle. This further emphasises the need for BANES to be more proactive in understanding what residents are looking for and having processes and partnerships in place which are able to deliver. This implies a considerable change in the way BANES as an organisation is managed and in particular the way it manages its communication with residents and potential residents.