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Sunday, 22 August 2021

Motorcycle parking

One of the issue which the recent parking consultation seems to have failed to address is the anomalous position of motorcycles.

Despite their negative environmental impact motorcycles continue to be able to park in the city free of charge. This is a facility which they exploit to its fullest extent. We find motorcycles occupying car parking spaces and very dangerously cycle racks including cycle racks on pavements.

As well as occupying the cities limited parking spaces free of charge, irrespective of their emissions, many of them seem to have disabled or circumvented the sound control measures on their machines and create considerable noise nuisance.


Thursday, 1 July 2021

Security Zone Update

While it is clear that hardly anybody buys the justification for the security scheme proposed by the police which manages to be both objectively oppressive and inadequate when judged against recent attacks. It is also clear that the Council lack both the authority and political will to oppose it. So it is now time to focus on the issues of implementation.


Bath is very fortunate in having a wide variety of people that have chosen to live in the historic city centre. This is something that many cities have spent large sums of money trying to achieve and there are too many example of historic cities and tourist destinations that have lost their inner city residents and paid a heavy price.


Too often in Bath people who actually chose to live in the City come bottom of the list of stakeholders to be taken into consideration in creating and implementing policy. The city centre security proposals are yet another example of this. The original proposals were developed with minimal consultation with residents and the publicity sought to downplay negative impacts. As a consequence they largely failed to acknowledge issues for those with limited mobility and dumped almost all the responsibility for coping with the negative impact on residents. This dereliction of responsibility by BANES was most clearly manifest in the ludicrous proposed arrangement for deliveries and property maintenance.


While the access consultants did a good job of starting to identify problems their terms of reference constrained their conclusions to a focus on the most disadvantaged and then only a subset.


What is needed now is a proper consultation with all affected residents proactively working to identify problems that will be created and identifying ways in which the local authorities will seek to take responsibility for implement schemes to minimise those impacts and associated costs.

Monday, 14 June 2021

7 BLADUD BUILDINGS Planning Application ref: 21/02476/REM


The applicant seeks the removal of part of Condition 5 attached to an existing, but un-realized, planning consent 18/04797/FUL which would convert the use of the premises from night club (sui generis) to pub (A4).  Among features proposed 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.


The premises licence at 7 Bladud Buildings provides for closing times for the sale of alcohol of 02.00 Monday to Thursday, 03.00 Friday and Saturday and 22.30 on Sunday but makes no separate reference to the open area at the rear.  In considering application 21/04797/FUL the Council was therefor right to impose Condition 5 which specifies that ‘The external area at the rear of the premises hereby permitted shall be closed to the public and cleared by 23.00 hours from Sunday to Thursday and Bank Holidays and by 00.00 hours on Fridays and Saturdays and the use of this outside area shall cease twelve months from the date the approved use commences unless a further permission is granted’.  The effect of Condition 5 with its reference to re-application after twelve months omitted as requested by the applicant, 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 fully with the requirements of Condition 5 while making a timely application for a further consent.


TARA asks that Condition 5 be retained as it stands and that the above referenced application be REFUSED.


Sunday, 30 May 2021

TARAs response to the Atkins City Centre Security Access Report

Comments by TARA:

It seems to us that Atkins have done a reasonable job with the limited brief they were given and while we might quibble with the details and limitations of their recommendations the council has provided an inadequate forum for doing this.

We would however, like to highlight two observations they report:

1. "It seems like this is just tinkering with traffic management without any overall plans for the City Centre - What is the vision for what kind of City Centre we want?" 

This for us seems to be a key observation and should form a starting point for a new consultation.

2. The state of the pavements and the muddle of street furniture are a constraint on any access and mobile plans for the city centre. 

We note that there are large sums of proposed expenditure for "active" travel schemes most of which is planned to be spent of specialist cycling infra-structure. We would contend that much of this expenditure would be better directed at improving the ability of pedestrians and disabled people to move around the city.

Finally, reading officers analysis of the consultations responses make it clear that there is a bias in designing consultations to making them easy for officers to analyse at the expense of offering residents the widest range of options for participation. This is a bias which, in our view, should be corrected. 

Saturday, 22 May 2021

TARA’s Response to the Parking permits consultation

Parking is a considerable problem for people living in the city centre as many do not have access on-site parking.


Successive administrations have failed to provide spaces consistent with the number of permits issued. These spaces have been further eroded by “temporary” pedestrianisation, pavement widening and parklets as well as a policy which allows unfettered free use of on street parking by motorcycles. Proposed LTNs, the security zone and electric charging points etc will all potentially make the problem worse.


In the past handing out large numbers of permits to hotels, guest houses and holiday lets has eaten into the already inadequate provision in the city centre so we welcome the proposal to restrict the use of these to off street carparks.


We oppose the proposed emissions based charges for residents permits because it is inequitable to penalise residents when you allow private cars to drive into the CAZ without charge irrespective of their level of emissions.


Residents in the heart of the city have never had the benefit of visitors permits.


The arrangements for traders in the city are already a mess. Some companies will not service city centre addresses and the proposed security zones and LTN’s will make this worse. Charging traders more and continuing with the high level of bureaucracy will increase the number of these and increase the number of those who park in residential streets in outer zones to avoid charges.


Overall these proposal are likely to make very little difference they are just tinkering with the problem of parking in Bath. What is required is a root and branch reappraisal of parking policy supported by research and proper consultation.


This is yet another questionnaire, filled with leading questions masquerading as a consultation. It also discriminates against the digitally excluded. The inability to submit responses outside this online mechanism is unreasonable and unfair. The online mechanism itself barely acknowledges  the existence of representative organisations it has forced us for instance to declare whether TARA considers itself disabled.

Saturday, 8 May 2021

THE MINERAL HOSPITAL 21/01752/FUL

The applicant seeks consent for change of use from hospital (D1) to a 160 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.

We acknowledge that the applicant has made a serious attempt to address issues relating to the proposed extension to the south of the west block of the existing building which were the principal cause of the refusal of the previous application.  In broad terms these issues were consistent with matters raised by this association in its submission during the consultation stage.  These included concerns over the bulk and mass of the building in its context and the potential loss of amenity by local residents caused by overlooking and light deprivation and noise disturbance from south facing bedrooms.  We concede that the proposal to place the extension somewhat further north, the stepped profile, mansard roof and absence of south facing windows provide a reasonably convincing solution to these problems.

There are two outstanding matters, however, that in or view remain at issue

  1. Benefit to the community.  Although efforts have been made to make historical artefacts and references in the building accessible to the public the opportunity to incorporate a publicly accessible open space in development on the south side of the existing building has been missed.  The ‘glimpse’ of the proposed garden from Bridewell Lane and to a lesser extent from Parsonage Lane, is not good enough for Bath with its world-wide reputation for excellence in urban design.  There should be a small urban park for general use incorporating a pedestrian link between Parsonage Lane and Bridewell Lane with a new entrance from Bridewell Lane open to the public at least during daylight hours.  In addition, there should be increased emphasis on planting and bio diversity in this space and less on hard surfaces.


  1. Accessibility.  It is no fault of the applicant but in the context of the Council’s proposed city centre security zone whose detailed workings are, as we understand it, still unresolved proposed arrangements for access by guests and others to the building by car and taxi appear unworkable.  As things stand, access to the building from a dropping off point a minimum of 100 meters from the entrance or specific permission on a case-by -case basis seem unsustainable even as a temporary arrangement.

We therefor ask that a decision on the application be DELAYED until satisfactory arrangements are in place to create a publicly accessible space and pedestrian link at the rear of the existing building and there are workable arrangements for providing access to the hotel.


Sunday, 28 March 2021

Planning Application 21/00692/VAR. KING EDWARD SCHOOL

The applicant seeks modifications to proposals approved in 2013 (13/02136/REN), a renewal of 10/00041/FUL including the removal of Conditions 4,7,10,21 and 22.

This association has long sought the restoration of this important building. We have in the past had serious reservations about whether a large drinking establishment, even in the form of a boutique hotel, would be a suitable use for the building particularly in light of the challenge posed by the night time economy to city centre residents.  Cooperation between the public and private sectors combined with sustained public pressure and media coverage over the past decade have brought about much improved management of the night time economy.  We are also mindful of the pressing need for fresh investment in the city centre following the Covid 19 pandemic and the relatively high quality of the work done by the applicant in similar circumstances elsewhere.

We therefor have no objection to the modifications proposed or to the removal of conditions 4, 7, 10 and 22. 

We do, however, object to the removal in its entirety of Condition 21 relating to limits to the patronage of the rear courtyard area.  As we have stressed previously, the use of this large area by excessive numbers of drinkers could seriously harm the amenity of the occupants of the twenty to twenty five apartments in the immediate area.  This would risk setting an unwanted precedent in other parts of the city centre as well as being contrary to Policy D6b of the Council’s adopted Placemaking Plan which requires that development 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 disturbance’.   It has been for this reason that TARA has in the past pressed for limits to the number of patrons allowed to use this area at any one time and we believe that the Council was right to impose Condition 21 limiting numbers to 96, and to insist on its retention subsequently, and we ask that it continue to do so.

Wednesday, 24 March 2021

Further comments on the proposed development at Eveleigh House, Grove Street

Planning Application 20/01466/ODCOU


We have been taking a closer look, so far as has been possible, at the proposed development at Eveleigh House, Grove Street. Under 20/01466/ODCOU the applicant, Rengen-Longacre, was granted consent in June 2020 for a change of use from B1a (office) to C3 (housing) under the Town and Country Planning (General Permitted Development) Order 2015, Part 3 Class O. Little information was provided in the application and there was minimal consultation. Some existing office space is to be retained and around 48 'one bed studio apartments' are to be provided. The attached link from IESIS, a member of the development team, though not the applicant, describes the accommodation to be provided as 'student accommodation' and the number of units appears to have increased to 54. In addition, a full planning application (21/00636/FUL), discussed above and now under consideration, includes a new entrance on the north side of the building described as a ‘student entrance’.


Adjoining Eveleigh House to the north are two apartment buildings, Caxton Court and Northanger Court, containing some 53 apartments which are mainly occupied by elderly and retired people, most of whom are TARA members. There is a history of night time disturbances on Grove Street, reports of rat running and speeding traffic requiring traffic calming measures and substantial pressure on the limited on-street parking available. The designation of student housing as sui generis in land use terms was, of course, made for good reason. Student housing typically has a high population density and is associated with high levels of late night noise and disturbance. In addition, many students these days own and drive cars.


We recognize, of course, that the applicant in this case may be offering a product intended to attract a broad segment of the market including students. However student housing typically has certain specific characteristics which can include an emphasis on single bed spaces, showers rather than baths, durable finishes and equipment as well as shared facilities such as common rooms and laundry facilities. We believe it would be appropriate for the Council, as Local Planning Authority, to request more detailed information from the applicant to ensure that the Permitted Development consent which he has been granted is being implemented in accordance with the regulations, and to consider enforcement action if this proves not to be the case'.

Friday, 19 March 2021

Planning Application 20/01466/ODCOU the proposed development at Eveleigh House, Grove Street

Unfortunately it is not clear in plans submitted with the application exactly what is intended in relation to the 'student entrance' to the building. There is concern among our members at Caxton Court at the reference on Dwg 1080/171 to a first floor level door that is to be 're-hung and set into a handed frame'' and that this may indicate that this door, currently a fire exit door, may be used, also or instead, as an entrance to the building by students. The door affords a view directly into bedrooms a short distance away at Caxton Court through skylights and could offer a clear risk of overlooking.


We therefor ask that a decision on the application be DEFERRED until the applicant is able to clarify the intended means of access to and exit from the building by students.



The proposed development at Eveleigh House, Grove Street

Under 20/01466/ODCOU the applicant, Rengen-Longacre, was granted consent for a change of use from B1a (office) to C3 (housing) under the Town and Country Planning (General Permitted Development) Order 2015, Part 3 Class O. Little information was provided in the application and there was minimal consultation. Some existing office space is to be retained and around 48 'one bed studio apartments' are to be provided. The attached link from EISIS, a member of the development team, though not the applicant, describes the accommodation to be provided as 'student accommodation' and the number of units appears to have increased to 54.


Adjoining Eveleigh House to the north are two apartment buildings, Caxton Court and Northanger Court, containing some 55 apartments which are mainly occupied by elderly and retired people, all of whom are TARA members. There is a history of night time disturbances on Grove Street and substantial pressure on the limited on-street parking available. The designation of student housing as sui generis in land use terms was, of course, made for good reason. Student housing typically has a high population density and is associated with high levels of late night noise and disturbance. In addition, many students these days own and drive cars.


We recognize, of course, that the applicant in this case may be offering a product intended to attract a broad segment of the market including students. However student housing typically has certain specific characteristics which can include an emphasis on single bed spaces, showers rather then baths, durable finishes and equipment as well as shared facilities such as common rooms and laundry facilities. We believe it would be appropriate for the Council, as Local Planning Authority, to request more detailed information from the applicant to ensure that the Permitted Development consent which he has been granted is being implemented in accordance with the regulations, and to consider enforcement action if this proves not to be the case.'

Tuesday, 9 March 2021

Are pedestrians getting forgotten in transport plans?

The bulk of the money in BANES active travel proposals is being directed at expensive cycling infrastructure. This come on top of a considerable emphasis on bicycles in most other transport plans, visions and proposals. This emphasis seems to be at the expense of investment in public transport and in particularly investment in provision for walkers.

It is hard not to see this as, at least in part, as a  consequence of there being a very well organised cycling lobby with close links to BANES council.

We have seen a steady decline in the maintenance of city pavements which is both dangerous and unsightly. Where is the plan to address with the sort of funding being proposed for cycling routes?

We had a well research and widely consulted plan for improving the city centre, it was called the Public Realm and Movement Strategy and had pedestrians at its heart. It was not implemented, apparently because of a lack of funding. Where is the plan to update it and implement it or the commitment to produce and implement a public realm and movement plan of similar quality?

City centre residents complain about having to dodge cyclists, skateboarders and now electric scooters illegally using pavements and so called "pedestrianised" areas. Where are the plans to improve the enforcement of rules?

There are a number of dangerous and well used road crossing points in the city centre. Where are the plans to invest in properly designed crossing controls in these places?

Trade waste blocks pavements forcing pedestrians into roads. Where are the plans to address the storage of trade waste to avoid this?

Successive BANES administrations have talked about creating cafe culture in the city centre but where is the properly funded research into how to strike the right balance between this and the inevitable impact on pedestrians?


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).

BACKGROUND

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.


REQUEST

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.


BATH RUGBY AT THE REC

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.