8 October 2021
The Climate Emergency requires that the planning decisions we make today on this Local Planning Partial Update (LPPU) result in constructive action to reduce CO2 over the next 20 years. It is vital that B&NES Council undertakes a consultation process that is equitable to all sections of society.
The consultation on the LPPU and on the supplementary planning documents, running from 27th August to 8th October 2021, is impenetrable, unclear and apparently without easy and transparent access to all documents.
On the 27th September 2021, Bath and NE Somerset Green Party contacted a council officer with regard to the consultation section on transport and developments, as it had become increasingly clear that the consultation did not include the ‘Transport and Development’ supplementary consultation. The officer sent a link stating during the phone call that it had been decided to not include the actual 136 page document on the consultation. Links to further documents were also sent including ‘Houses in Multiple Occupation’
A local resident contacted BaNES Green Party stating: “My feeling is that the whole process is impenetrable, and really, the only people who have time to get to grips with the detail and complexity of the process are those on a full-time wage. Therefore, I think you are likely to get many more comments from developers, etc. than people who genuinely want to see B&NES meet its net-zero targets.I have no idea how the process could be more accessible, just that it ought to be, because it’s so important for residents to be engaged in decisions that will affect the future of our communities. I also feel that the update lacks urgency, and could be much more ambitious. I’m aware that it still has to go before the planning inspector, but even so, this is an emergency! Kindly feed these points into the consultation on my behalf.” BaNES Green Party called for an extension to this consultation of a further two weeks, and for the full documents on the three supplementary planning documents (SPDs): ‘Transport and Developments’, ‘Sustainable Construction’ and ‘Retrofitting, Houses in Multiple Occupation’, to be put at the beginning of the consultation so that members of the public can easily read what they are being consulted on.
BaNES Green Party is not satisfied that the consultation is set out to encourage residents to take part. Rather, we believe it is a consultation for developers and those with a high level of understanding on planning to set out their views. The multiple choice survey in the present consultation is very superficial and it is not made clear that residents could just email their own response to the documents.
It is also not clear how effective taking out the 3 supplementary planning documents (SPDs) from the LPPU will be? Will this then make them less robust because they will now not go through the scrutiny process of the LPPU and will this now mean that Developers can run roughshod over the SPDs, due to lack of due diligence by the Planning Inspector? “The LPPU as proposed is unsound due to the removal of policies relating to Sustainable Travel including Parking Standards from the Local Plan and placing them in a Transport Supplementary Planning Document. This will prejudice achieving the CE and carbon neutrality objectives due to the lesser authority of the SPD and the absence of rigorous examination thereof within the LPPU.”
Will all comments made at this consultation (27th August to 8th October 2021) be incorporated into the LPPU and the SPDs before being taken to the Planning Inspector? It is not clear if this consultation is valid and listening to the view of residents.
In general Bath and NE Somerset Green Party supports most changes to text, but have some concerns, especially about how strong the ambition really is to tackle the emergencies declared in 2019 and 2020 (please note throughout in various documents the Ecological Emergency is dated 2019, when it took place in 2020).
*583a on p74 - this is not ambitious enough. It says “if progress not great or fast enough” they will explore charging mechanisms like the workplace parking levy and road user charging. The most successful examples of modal change in transport all derive from these, and the seriousness of the emergencies mean that we should be exploring and then implementing them straight away, not just waiting to see how progress here goes. There should be an annual review of all polices to see if change is really taking place to reduce CO2 emissions. Mere preparedness to explore a workplace levy is insufficient and renders the LPPU unsound.
The update objectives on the Climate Emergency require the burden to be shared commensurately by workplaces and commuters, as well as residents. However, we see in paragraph 589: “Whilst the Council is committed to addressing the Climate and Ecological Emergency, we must achieve this equitably and inclusively.” A workplace parking levy needs to be the norm to reflect the impact of workplace parking on traffic and as an obstacle to the objectives of addressing the Climate Emergency and carbon neutrality by 2030.
*589b on p77 - sets targets that don't seem ambitious enough, including allowing for 10% petrol/diesel vehicles by 2030.
Para 589 is unsound. The statement in isolation that in Bath 42% of all journeys under 3km are taken by car is meaningless when compared with the 2030 target of “25% reduction in car and van mileage per person” which has previously been stated as a target for BaNES as a whole.
Data for overall mileage within B&NES shows this 25% reduction is not realistically achievable through reduced journeys within the 25% target journeys that are within Bath.
The policies on charging infrastructure are inadequate to achieve the electric vehicle objectives stated in para 589.
The LPPU should treat journeys from outside Bath in the same way as intra-city journeys – in particular it is completely inappropriate for developments in Bathampton or Batheaston (proposed to be designated as Zone C in the SPD) to be given more generous parking standards than locations in outer Bath (eg Upper Weston or Odd Down, to be designated as Zone B).
*ST3 Transport Infrastructure on p92 - points 4 and 5 still allow for increases in traffic capacity, which the Green Party opposes. The only way to reduce surface transport emissions is to cut private transport and enable active travel and public transport.
*215 on p145 The RUH parking plan seems very unambitious in light of the declared emergencies, and includes the potential for additional parking, which isn't compatible with the objectives.
*SB26 Park and Ride sites on p179 - this proposes changing them to transport interchanges and to do this, removing them from the green belt. 'The Green Party will need more information about what precisely the Transport Interchange would accommodate before giving our support to these proposals.'
*583a - yearly transport review needed
*Para 589f is unsound. It should be made clear that the legal air pollution limits are not a definition of “acceptability”. The legal pollution limits are not statements of “safe limits” but merely set upper legal thresholds, as it is widely accepted science that there is no safe level for emissions pollution – see the WHO Global Air Quality Guidelines issued 2021.
(i) It should be made clear in the LPPU that the legal air pollution limits are not a definition of “acceptability” and more challenging objectives for clean air included. Reference should be made to the WHO guideline levels of 2021 as "target" levels.
(ii) The references to "traffic management" arrangements in Queen Square should be removed from the proposed LPPU. If they are to be retained then they should be accompanied by explicit reference to the requirements to monitor the impacts of "Queen Square traffic management" with Class C CAZ as long as the "traffic management" arrangements in question are in place. See in particular the ‘Bath Clean Air Zone, Peer Review’ report dated 27 August 2019 2nd and 3rd paragraphs of Summary on pages 4 and 5 of 22: "It will be important that the traffic management approach implemented is able to respond and either restrict or relax the flow of general traffic as the real-world applications and impacts of the CAZ are monitored. Critical to the successful implementation of CAZ will be robust monitoring and evaluation of the performance of the scheme, alongside a willingness to review and alter the scheme should the real-world performance differ from significantly from the business case.”
The understanding of emissions pollution, the impacts on human health, and the levels that should be permitted are all areas of evolving policy, with the ongoing proceedings around the Prevention Of Future Deaths report in the case of Ella Kissi Debrah, the progress of the Environment Bill through Parliament and the recent issue of new WHO Air Quality Guidelines. It is important that the most up to date information on all of these matters should be taken into consideration during examination.
*593-599 The LPPU as proposed is unsound due to the removal of policies relating to sustainable travel including parking standards from the Local Plan and placing them in a transport supplementary planning document. This will prejudice achieving the Climate Emergency and carbon neutrality objectives due to the lesser authority of the SPD and the absence of rigorous examination thereof within the LPPU.
The parking provisions of the Transport SPD (even if strictly implemented) are insufficient to achieve the stated objectives, allowing excessively generous parking provision having regard to the urgent need to address CE and achieve carbon neutrality. Moreover, the Transport Plan provisions of the Transport SPD lack policy measures and leave far too much flexibility to enable achievement of the Update objectives.
*ST2A 602-605A The proposed update of ST2A is not sound and cannot achieve the aims and objectives of achieving modal shift or of contributing materially to aim of carbon neutrality by 2030 for the following reasons: (i) Inadequate policy provision for segregated cycle lanes on key connecting routes (main roads) thus inhibiting cycling journeys beyond immediate neighbourhood and substantially limiting options for younger, older or less experienced cyclists to cycle around the city. This is contrary
to the Update objectives.
(ii) Failure to provide distinct and relevant policies as between leisure routes and urban routes. Leisure routes (eg as proposed for eastern section of the Riverline route) are isolated and not suitable for bright lighting. This makes them unsuitable for evening or night-time use by most users, and they should be regarded as merely an optional extra to safe provision on well-lit, more direct main road connecting routes that are usable 24 hours a day.
*ST6 618- 618c, 619-21 Expansion of the policy to allow for transport interchange within urban areas, apparently potentially including residential areas, should only be permitted if successful mitigation of impact
on the neighbourhood in question and nearby residents and that the public benefit outweighs any detrimental impacts. Currently such mitigation and public benefit test only applies to heritage and designated environmental areas, and without extending this to residents the amended Policy would be unsound.
Further, interchanges which serve motor vehicles should not be permitted within residential areas since sites that serve to attract or provide incentive for motor vehicles into urban areas are contrary to the objectives of CE and carbon neutrality. Additionally they would counter- productively impair achievement of improved air quality.
*ST7 The requirements in Policy ST7 for car and cycling provision to “contribute to the aims of the Climate and Ecological Emergency” and “be appropriate to the context of the development” are vague and ambiguous, and Policy ST7 as proposed is rendered unsound due to the removal of policies relating to Sustainable Travel including Parking Standards and Travel Plans from the Local Plan and placing them in a Transport Supplementary Planning Document of lesser authority.
*B1 98 The Area and reference to Area of Search for East of Bath Park & Ride should not be removed unless or until there are policies in place providing for the essential access to the city from the east. Failure to provide such provision for access (whether as Park & Ride, Wiltshire Whippet, Park & Train or whatever) will be completely incongruous with the aims and objectives of the Update relating to Climate Emergency, carbon neutrality or modal shift, and render the LPPU unsound. The cumulative impact of Bath of not proceeding with any such interception of eastern traffic, not addressing through traffic in the WHS (para 582-3), and failing to include policy for safe segregated infrastructure for cyclists on main roads (see comments above on paras 602-605A) will be to severely hamper modal shift across a substantial part of Bath and thus raises serious doubts over the Council’s commitment to achieve the Update objectives.
* SB18 (RUH) and SB19 (University of Bath) The RUH and the University are very large generators of traffic within Bath and surrounding areas, the RUH generating much through traffic from Wiltshire and elsewhere through Bath, and the University generating much traffic throughout Bath especially in the east (about 40% of traffic on Cleveland Bridge at busy times according to contractor reports relating to the works on the bridge). Developments at these sites should be expected to be sustainable and to comply with the CE and carbon neutrality objectives of the Update. The LPPU proposed amendments currently fail to require the substantial reduction in parking space that would be required on these sites in order to support the level of reduction in car use required. The absence of robust requirements on Travel Plans also undermines any efforts to achieve sustainable travel to these sites.
SB1 Milsom Quarter – New area defined for specific development deliver proposals (Cattlemarket, Walcot Street, across Milsom Street to edge of Queen Square; and from Upper Borough Walls northward to beyond George Street. Potential for traffic impact.
SB8 Western Riverside, revised – Many substantive changes with some reading onto transport and potentially relevant to traffic generation.
SB22 New Policy for Locksbrook Creative Industry Hub added potential for traffic impacts unclear.
SB14 Twerton Park, revised – Potential for traffic impact
SB24 New Policy – Sion Hill – Provision of housing, illustrative of the illogicality of parking standards, with this site very close to city centre qualifying for more generous Zone B standards. Implications for local traffic.
SB25 New Allocation Policy – St Martin’s Hospital. Provision of dwellings, and some transport infrastructure proposals. Potential Implications for local traffic.
SB26 Park & Ride – substantive revision – removal from green belt, development to transport “interchanges”
SB23 New Policy for Weston Island added, employment uses? Potential for traffic impacts unclear.
SB18 RUH, revised – extensive revision with obvious potential impact for traffic generation. Inclusion of on-site accommodation (silent as to parking allowance but see rather unclear provisions on hospitals in Transport SPD). Little sign of requiring provisions to drive modal shift from a site that generates much traffic?
SB19 University of Bath at Claverton Down and Sulis Club. Extensively amended with radical development plans including new admin and research buildings, and reorganising car parking to include decked car park. Illuminating detail that the university employs 3500 people but has a huge current “operational” level of car parking of about 2,200 spaces. The option to retain such a large amount of parking (which is known to generate much traffic across the city – see eg Cleveland Bridge, where 40% of vehicles at busy times associated with the University) seems completely incongruous with the CE and carbon neutrality aims as well as all Liveable Neighbourhood and Active Travel policies.
How can both Universities be delivering on the CE with large car parks? Cars should be stopped from accessing these sites and should only be used for pick up and drop off, or using EV car clubs.
SB24 Sion Hill - How is Winifred’s Lane being used? Should this not be part of the Liveable Neighbourhood Policy work?
SB26 Park and Ride Sites: agree with change to Transport Interchanges - should there be a transport Interchange on the East of Bath? 28000 vehicles use the London Road each week day.
1.1.4 Better word than expectations “requirement”
1.2.2 Declared Ecological Emergency in 2020 not 2019
1.2.3 Use the term “requirement”
1.2.4 25% reduction on vehicle mileage - needs greater ambition
P5 Bath - "Excellent access to public transport". Is this true? If you live in Fairfield Park there is one bus every half hour with little or no service in the evening on and not on Sundays.
3.3.2 "In urban areas there tends to be well established networks for active travel" Where is this established network? There are no LTN 1/20 compliant cycle infrastructure in the city of Bath. Please amend.
3.7.4 Gear Change - One Year n to be included
3.7.9 Living Streets reference NICE Quality Standards to encourage physical activity in everyday life
4.5.1 Zone A should be bigger. Zone B should include Batheaston and Bathford. Zone D - Whitchurch should be part of Zone B due to its proximity to Bristol. East of Bath (Bathford and Batheaston) has poor public transport and little if any active travel routes (the river line along the canal can only be used in daylight hours and is not wide enough to allow for significant increase in cyclists and pedestrians), but is on the whole on the valley floor and flat and sustainable travel should be required in all developments.
4.12.16 Should all Car Clubs be EV car Clubs? There should be no fossil fuel based car clubs (in reference to all points throughout document on car clubs)
4.12.8 100 dwellings - this should be reduced to 50 dwellings. More ambition and promotion of EV car clubs are needed
4.12.10 only EV car clubs
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