Meeting documents

1.1.1 Bath and North East Somerset Council appointed WSP Environmental Ltd to undertake a Sustainability Appraisal (SA) of the emerging Supplementary Planning Document (SPD) for Bath Western Riverside (BWR). This is a summary of the draft results of the SA.

1.1.2 The purpose of the SA is to help ensure that the SPD is sound and that it contributes to a range of sustainable development objectives. It does this by assessing the extent to which the plan will help achieve a set of objectives that cover a range of issues, including air quality, townscape, landscape, health sustainable design and construction and economic performance.

1.1.3 Under the new planning system¹ SA is mandatory for Local Development Documents, including SPDs. The SA also needs to comply with the requirements of European Directive 2001/42/EC `on the assessment of the effects of certain plans and programmes on the environment' (the SEA Directive).

1.1.4 The appraisal team has carefully considered the content of the draft SPD. The perfomance of each of the key sections within the SPD has been considered against each of the SA objectives and the results recorded using a set of matrices.

1.1.5 Our overall conclusion is that the SPD performs well against the SA criteria. No instances were the SPD would definitely work against the achievement of one of the SA objectives were identified. We have however made a number of detailed recommendations that are intended to sharpen up the SPD and ensure that the aspirations set out in parts of the SPD are carried through to later stages in the development process. Key recommendations are summarised below.

1.1.6 We recommend that a clear distinction is made between background text, explanatory text and requirements/policies. This will aid the reader and help ensure that the objectives of the SPD are met.

1.1.7 Consideration of the vision and key principles against the appraisal objectives identified a number of potential gaps and uncertainties and these are shown on the appropriate matrix. If there is scope for amending the vision we feel that it should set out the aspiration for BWR to be an exemplar project, not just from an urban design perspective but in terms of wider sustainable development objectives, this aspiration is expressed elsewhere in the SPD. In addition the key principles should be extended to cover the following:

1.1.8 There may be scope for providing health facilities that meet the needs of the wider population. The SPD could be more explicit in setting out what the requirements might be, based on the anticipated scale of development and any needs in the community. The section on development requirements provides an opportunity to cover these points.

1.1.9 The SPD could reference the need for a Construction and Environmental Management Plan, incorporating waste minimisation and management programmes. The SPD identifies a range of renewable energy technologies but does not set a specific target for provision, nor does it prescribe a mix of technologies. There may be scope for district heating but the SPD does not carry this forward as a policy requirement.

1.1.10 The vision statement in Part 2 of the SPD is very urban design focussed. If that is the intention perhaps it should be reworded to make that clear. If the statement is intended to have a broader role it could embrace other aspects of sustainable development, such as the use of sustainable design and construction techniques, a commitment to enhancing biodiversity, whilst off-setting any negative environmental effects. The vision statement is also an opportunity to commit to a Carbon neutral scheme and a zero waste scheme.

1.1.11 The over-arching design principles has a section on sustainability. This could be expanded to spell out what a sustainable development at this location would entail, either that or the design principles should be narrowed down to cover issues relating to built form. There is no reference to achieving a mix of uses, securing the use of renewable energy, use of sustainable design and construction techniques etc.

1.1.12 The key organising principles make a contribution to the achievement of objectives relating to the built environment, e.g. objectives relating to townscape. We suggest that the principles are extended to include the opportunity for providing an ecological corridor along the river (which is identified elsewhere in the SPD) and also the need to consider micro-climate and opportunities for passive solar gain and the use of renewable energy.

1.1.13 The section on public realm should cover issues in relation to the provision of open space.

1.1.14 There is no reference to the promotion of cycling routes in the River Corridor section as well as the use of water taxis (if feasible). The issue of water safety is also not mentioned. It will also be important to ensure that a functional ecological corridor is provided along the entirety of the river bank.

1.1.15 Section 2.7.7 refers to the western neighbourhood as an exemplar of sustainable urban living. We wonder if this is the right section to make this statement. In any event the section does not discuss what this means.

1.1.16 The landscape strategy could reference the need to use species that reflect local character but also consider the long term implications of climate change and the impact this might have on the choice of species. There is no mention to the use of flora to reduce surface water run-off and therefore reduce flooding risk. The Landscape Strategy could also set out how applicants should demonstrate regard to landscape issues in applications and supporting information.

1.1.17 We suggest changing the title of the section on stakeholders to `Building Communities' the section seeks to identify key principles relating to community facilities and how BWR will relate to the wider area but at the moment it is not clearly expressed. This section presents an opportunity to set out a list of community facilities that will need to be provided on site. The section could highlight the need to `pepper-pot' affordable housing throughout residential elements. The section could also highlight the need for community participation in developing specific proposals, if that was considered to be beneficial.

1.1.18 Two options are presented in the SPD. Both options perform more or less the same against the objectives. The main difference between the options is that Option 2 provides more residential units (about 7% more than Option 1). Option 1 provides more employment space. It would be interesting to know how much additional employment Option 1 would provide because this would help differentiate between the two options and help illustrate the benefits associated with providing additional employment space versus residential units.

1.1.19 Both options seek to secure residential development on the site. The requirements should be expressed in terms of habitable rooms per hectare, in order to ensure that the anticipated capacity is delivered.

1.1.20 The SPD also contains a set of design codes that will guide the development of future proposals for the site. The codes support a number of the SA objectives, particularly those relating to townscape. The codes include a section on sustainability and we feel that this is an important opportunity to ensure that sustainability is embedded into the scheme. The use of design codes to secure such benefits is a fairly new concept and the appraisal team are currently looking to identify examples from elsewhere in the country. We feel there is scope for the codes to be more specific, e.g. by setting targets and to cover a broader range of issues than they do at present. We suggest the codes are extended to cover:

1.1.21 A key issue in relation to sustainability is: who will benefit from the development? We feel that the SPD could consider two factors, firstly the use of voluntary agreements to secure local recruitment and training so that local people have the opportunity for employment, both during construction and operation of the development and secondly to ensure that the development is accessible from areas of relative deprivation, so that people benefit from the provision of new facilities. The provision of public transport will be relevant here.

1.1.22 A further possible consideration is the use of planning obligations to achieve the provision of affordable houses (rather than flats) off site. This would have the benefit of helping to broaden the range of affordable accommodation provided but we acknowledge that this would be dependent on the availability of suitable sites.

1.1.23 The SA has considered the draft SPD against a range of objectives and arrived at a number of detailed recommendations. Overall the draft SPD performs well against the objectives. The SA will be published alongside the draft SPD and subjected to public consultation. A finalised version of the SA will then be prepared in light of those comments and a statement setting out how the SA has been taken into consideration will also need to be prepared.