Meeting documents

SPG Section

Key Issue

Officer Response

Change to Text

PART A

CONTEXT

1. INTRODUCTION

1.1 Western Riverside

Justification for the defined development area is questioned. The exclusion of some surrounding areas is questioned. However some questioning of the inclusion of the north bank area (with the Bath Conservation Area)

The regeneration area boundary was defined by the "Regeneration Framework Report" (2001) which was subject to public consultation.

The regeneration of WESTERN RIVERSIDE may also present opportunities to redevelop and improve adjoining or well related sites.

Proposals relating to these areas will need to be considered against a range of policies in the Local Plan

No change.

1.2 Purpose

Criticism that the SPG is unnecessary and should be withdrawn on grounds that it provides no material information additional to the policies in the Local Plan and the SPG fails to follow guidelines set down in PPG12.

The SPG provides the framework of principles to inform and guide the detailed development of the site.

The SPG:

· supplements a specific policy in a plan (GDS.1)

· is consistent with national and regional planning guidance

· is consistent with the adopted JRSP 2002 and with policies in the Bath Local Plan except for Policy E4 which is widely acknowledged to be out of date

· is cross-referenced to the relevant plan policy

· has been issued separately from the Plan

· has been made publicly available

· has been consulted upon and its status made clear

· will be reviewed on a regular basis.

No change to principle. Improvements/additions to text included to clarify purpose of SPG

1.4 Implementation

Land assembly - use of compulsory purchase powers would cause delay and should not be used to threaten responsible owners who's planning applications should be encouraged towards comprehensive regeneration.

Wherever possible, existing businesses within Western Riverside will be retained or, if appropriate, relocated (either within the area or elsewhere). This will be done through negotiation where possible with CPO as a last resort if necessary. The CPO process protects landowners and business interests to ensure reasonable compensation for disturbance or extinguishment.

No change to principle. Clarification needed including Council resolution of Feb 2000

2. POLICY CONTEXT

2.2

Strengthening of Bath & North East Somerset Local Plan policies

Key policies relating to regeneration of Bath Western Riverside in the Bath & North East Somerset Deposit Draft Local Plan should be strengthened to reinforce

GDS.1 (First Deposit) requires comprehensive mixed use scheme.

Masterplanning is a delivery process, not a policy but it is recommended to be referred to in the reasoned justification of the Plan.

The need for optimum use of land within Bath referred to in Regional Planning Guidance Note 10 and the reasoned justification of the Revised Deposit Draft Bath & North East Somerset Local Plan. However, the revised SPG refers to all three issues in considerable detail.

Amend the reasoned justification of the Bath & North East Somerset Revised Deposit Local Plan recommended.

Reinforced reference to comprehensive, masterplanned optimum development of the site included in SPG.

2.1.2

The Council's vision statement (2000) is weak and ambiguous. There needs to be a more challenging statement to ensure `exemplar' sustainable comprehensive regeneration of the site.

This issue refers to a previous decision of the Council to promote comprehensive regeneration of the site.

No change to SPG.

2.2.2 - 2.2.25

Need for greater explanation of related policy and guidance of National, Regional and Structure Plan level.

Inclusion of reference to PPG12, RPG10 and Joint Replacement Structure Plan policy to justify optimum, comprehensive regeneration

Agree

Text change as necessary to refer to related national, regional and Structure Plan guidance and policies.:

2.2.19

Need to refer to Bath Local Plan policy as the Adopted Local Plan for the site.

Need to justify move to mixed use redevelopment from employment based regeneration.

Disagree.

Key policies in the Bath Local Plan (1997) are now out of date. It does not contain policies which support the principle of mixed use regeneration of WR and is out of step with the adopted JRSP.

The Bath & North East Somerset Revised Deposit Draft Local Plan GDS.1 supports the principle of mixed use regeneration and is in conformity with the Structure Plan and national and regional planning guidance.

The SPG will remain supplementary to Policy GDS.1 of the Bath & North East Somerset (Deposit) Local Plan.

3. DEVELOPMENT CONTEXT

The SPG should make greater reference to the historic environment and the River Avon

Agreed

Archaeology merged with Historic Environment section (3.2) and expanded. River Avon referred to at para 3.8

PART B

4. DEVELOPMENT PRINCIPLES

4.1

Differing views of the interpretation and necessity of `comprehensive' regeneration of the site. These views are:

Comprehensive regeneration is a core Council and Bath & North East Somerset Local Plan objective for the redevelopment of the site.

Development of the core areas of the site in advance of masterplanning will be likely to compromise the optimum and viable regeneration of the whole area.

Comprehensive regeneration and delivery will be sought as a core principle.

The phasing of delivery will be the subject of masterplanning and the development process.

No change to core principles of SPG. Amendments to text needed to aid clarity.

5. COMPREHENSIVE REDEVELOPMENT

General

Justification for the principle of comprehensive redevelopment and delivery needs to be strengthened.

Agree - Reinforce this section to include Key issues of:

Add full justification for a comprehensive approach to SPG section 5.

Reinforce as key principle with summary reasons in section 1.

Add text to reasoned justification of Revised Deposit Draft Bath & North East Somerset Local Plan.

Amend text to refer to significance of delivery of comprehensive scheme.

Comprehensive development not a necessity. Regeneration of the site would be stimulated by early development of the core site which should be allowed to come forward in advance of a masterplan

Disagree. For reasons of delivering an holistic approach to secure the viable regeneration of the whole site as set out above.

No change.

A flexible approach to allow the regeneration to be implemented through more than a single developer should be allowed.

A single developer should be responsible for the whole site to avoid failure to develop part of the site.

This is a delivery issue. The principle of a masterplan led approach with delivery mechanisms to secure the integrated provision of viable regeneration, infrastructure and facilities is a core principle of the SPG and will be sought in any development scenario.

No change.

5.2

Residential

Density

High density residential development is supported. The SPG should specify the density requirement to be achieved.

High density mixed use development which includes a range of different types of dwelling will be sought in line with PPG3 guidelines and Local Plan policy.

Specification of a precise density target is considered unwise in advance of the masterplanning process which will be required to balance density with environmental, design and context issues.

No change

Doubt that the 900 dwelling completions on WR by 2011 is viable.

The figure of 900 is based on a start date of 2005/6 and delivery of about 150 units per annum which is considered to be realistic by a range of consultants and house builders.

No change.

5.2.3

30% Affordable Housing requirement is unjustified and does not take into account the viability issues of regenerating this contaminated site.

This should be considered in the context of regeneration viability

The SPG reflects Bath & North East Somerset Revised Deposit Local Plan Policy HG.8 and the forthcoming affordable homes SPG.

Reference to HG.8 of Bath & North East Somerset (Deposit) Local Plan and reference to differing types of affordable housing.

30% to remain as target minimum

5.2.3

There may be a need for a greater proportion of affordable housing.

The SPG reflects Bath & North East Somerset Deposit Local Plan Policy HG.8 and the forthcoming affordable homes SPG.

No change to 30% minimum target.

5.3

Commercial & Employment

Concern re viability and continuity of existing business uses.

The masterplan should identify existing business uses as retained in situ with their associated access and parking or relocated to suitable sites within the area.

This is a delivery issue. It needs to be addressed through the masterplanning process informed by necessary studies aimed at identifying the optimum viable use of the site. However relocations of existing uses to viable new locations may be considered in this process.

No change to SPG.

Enforced relocation and compulsory purchase should not be used in the development process. Existing uses including bulky goods retail should be retained on site.

Wherever possible, existing businesses within Western Riverside will be retained or, if appropriate, relocated (either within the area or elsewhere). This will be done through negotiation where possible with CPO as a last resort if necessary. The CPO process protects landowners and business interests to ensure reasonable compensation for disturbance or extinguishment.

No change to principle. Additional justification in text (1.4.4).

There is no justification or identified demand for the scale and types of employment space indicated in the SPG.

There could be serious implications on the viability of existing business space in Bath as a result of new space on WR.

The Council is seeking to achieve high quality employment generating development of sufficient critical mass to support Bath's regional economic role.

No change to principle of mixed use regeneration of the site as set out in Bath & North East Somerset (Deposit) Local Plan GDS.1.

The significant amounts of business/ office space provided on WR indicated in the draft SPG will threaten the viability of existing office space in Bath City centre. Much of this is located in historic/ listed buildings that contribute to the character and vitality of the World Heritage site.

Acknowledgement that increased supply has the potential to cause a loss of demand for office space in historic fabric.

However forecast demand for business space (Business Location Requirements Study) indicate demand for new space in addition to the existing, both in terms of overall space and different types of accommodation up until 2011.

The business space will be developed in phases. This will avoid the oversupply in any period that could result in localised relocation and effects upon Bath's existing historic offices.

No change to principle of mixed use development which reflects Bath & North East Somerset Deposit Local Plan Policy GDS.1.

There is insufficient evidence to justify the different types of employment space to be provided.

Large corporate headquarters buildings are incompatible with WR. They will increase demands for inward commuting and put additional pressure on local housing availability

Acknowledged that further studies will be required to specify the nature of employment floorspace to be provided. This will be done as part of the masterplan process.

Remove direct reference to particular types of employment space and refer to the need for further analysis as part of the masterplanning process.

5.4

Retail/Leisure

Bulky Goods Retail

Concern about the appropriateness of bulky goods retailing on WR. Incompatible built form and need for large on-site car parking provision not compatible with the objective of a high density, sustainable community development.

A fundamental principle underlying the regeneration of Western Riverside is that land uses/built form must ensure that travel by car in to and out from the site is minimised. Retail warehouses tend to be used predominantly by car borne customers. As such this form of retail development is incompatible with this underlying principle. However, the Local Plan recognises the need for bulky goods retail provision in Bath and a number of options require further investigation including potential for innovative solutions within the Western Riverside site.

No change.

Other leisure and cultural uses should be identified on WR.

The demand and suitability of cultural and leisure uses will be subject of masterplan and development process.

No change.

5.5

Community Facilities

Developer contributions to community facilities identified in the Draft SPG were considered unquantified and unjustified. There was insufficient evidence to support need.

Contributions to community facilities should also be related to existing provision.

Analysis of need should take into account existing local provision. Failure to do this may adversely affect its viability if overprovision achieved.

Agree that specific reference to types and levels of provision should be identified following detailed demand/need analysis. This would be part of the masterplanning process. However contributions towards identified need e.g. to create a sustainable community will be sought.

Agree that existing local provision needs to be considered in analysis and be eligible for investment should it be identified as related to WR community.

Remove direct references to specific types of community provision.

Commit masterplanning process to study of local community facility requirements.

Add item to 1.4.3 list of masterplan requirements.

5.5.2

There is insufficient justification for the requirement for a new school at WR which will be the subject of developer contributions.

The need for a new school as part of the development of the WR community has been identified in the School Organisation Plan 2003-2008 (Bath & North East Somerset 2003).

Retain the reference to the need for a new school in SPG. Delete specific details of associated ancillary provision subject to further study at masterplanning stage.

5.6

Recreation & Open Space

The River Avon should be identified as a focus of informal and water based recreation and leisure acting as the spine of the regeneration initiative.

Acknowledged. The River Avon has potential to become the focus of leisure and activity within WR linked to the rest of the city.

The significance of the river to be addressed in section 7 Design & Compatibility.

6. PROVIDING A SUSTAINABLE AND INTEGRATED TRANSPORT CHOICE

Need for more detailed transportation studies. The SPG should not be taken forward until sufficient transportation studies have been carried out to support the comprehensive development principle.

Disagree. The SPG is consistent with the policies of the Bath & North East Somerset Revised Deposit Plan sets out the principles for the development of the site to achieve low levels of car use and connection to an enhanced integrated transport network. This is to include links to a transport interchange, incorporating Park & Ride facilities at Newbridge. It is acknowledged the delivery of these principles will require detailed studies. These will be part of the forthcoming masterplan process.

No change.

6.4.3

0.7 car parking spaces per dwelling is not considered to allow viable residential development of the site and could have undesirable off site effects.

The Council has the objective of achieving minimum car use in residential environments. Significant progress towards this objective is achievable on Western Riverside. This is because Western Riverside is located within a mile of Bath City centre and will be connected to walking, cycling and public transport infrastructure. It will also offer opportunities for employment on site. It is considered that this target parking ratio is responsive to the ability to use alternative modes and the short distances to major amenities and employment. However, having regard to Policy T.26 of the emerging Local Plan and the assessment criteria to be established in the forthcoming SPG the 0.7 spaces per dwelling may be revised downwards.

It is also responsive to the need to create a high density sustainable community which is compatible with the neighbouring context.

No change to principle. Clarify text..

6.4.3

Commercial car parking ratio for the site should be set out in the SPG.

Policy T.26 in the Revised Deposit Draft Local Plan establishes a maximum commercial standards of 1 space per 40m². However, the Council is committed to achieving a new standard of sustainable development on WR which minimises the use of cars. WR's exceptional locational advantages, being within a mile of Bath city centre and adjacent to existing and new residential communities together with connections to an enhanced integrated transport network justify a much reduced parking ratio. In addition Bath World Heritage status requires a more sustainable approach to secure the preservation of the value of the city.

Additional guidance informing the assessment of an acceptable parking standard will be produced as SPG to the Revised Deposit Local Plan.

Redraft para 6.4.3 to bring it into line with Policy T.26 of Revised Deposit Draft Bath and North East Somerset Local Plan.

6.1.3

The River Avon should be acknowledged as part of the sustainable transport network.

The river has great potential to be focus for improved pedestrian and cycle routes. It also has the potential to accommodate greater recreational traffic. However it is considered that it would not form an effective element of any high capacity, rapid integrated transit system.

Acknowledge the River Avon has potential to be a focus for the regeneration.

Refer to recreational river transport.

6.3

The development will not generate sufficient demand to make an expanded Park & Ride viable.

The extent of expansion to Park & Ride will be the subject of further detailed study, linked to masterplanning.

No change.

New public transport services to the site may adversely affect the viability of existing services.

Any new provision will be planned in conjunction with the existing to avoid adverse effects on those services.

No change.

The transportation network should be implemented in full prior to any occupation of the site.

The level, location and delivery of the integrated transport infrastructure will be addressed as part of the masterplanning process.

Refer to transportation study in masterplanning requirement 1.4.3.

Concerns raised about Park & Ride expansion in the Green Belt

This issues is addressed through the Revised Deposit Draft Local Plan as changes to Green Belt cannot be properly addressed in an SPG.

No change.

7. DESIGN & COMPATIBILITY

The form of major headquarters buildings is likely to be inappropriate in the context of WR.

Issues relating to the effects of particular uses will need to be considered at masterplan stage.

Remove reference to particular types of business development.

7.2.3

High density development can be achieved without the need for tall buildings. The appropriate form of development needs to be informed by a thorough analysis of character of the surrounding area.

Agree:

The appropriate form of development will be considered at the masterplan stage where a character appraisal/analysis will be required (ref para 1.4.3)

State need for character analysis in masterplan requirements.

Brief for masterplan should be drawn up with the assistance of CABE. There should be a high profile design competition. The process should be overseen by a recognised "Design Champion".

Acknowledged. It is critical that the need for high quality design is incorporated into the masterplanning process from the outset. Consultation with key advisors will be critical in this process. A competition and appointment of a "design champion" will be considered.

No change.

Text should be amended to say that development of the area will reinforce locally distinctive patterns of development defined and informed by characterisation analysis.

Agreed. This will help to ensure that the pattern and grain of the development will be informed by and be compatible with its surroundings and preserves the value of the World Heritage Site.

Amend text in 1.4.3 and 7.2.3 to include issues which the masterplan must adhere to.

7.1.2

There should be a general requirement that the development demonstrates the highest design standards when measured against recognised extant published standards.

Agreed. Current standards may change or be replaced over the life of the development or masterplanning process. Best practice at any time should be maintained.

Amend text in 7.1.2.

7.2.3

Density envisaged by PPG3 is achievable without need for inordinately high buildings. Change "landmark taller buildings" to "landmark buildings".

Agreed. Landmark buildings do not by definition need to be tall.

Amend text in 7.2.3.

7.2.6

Specify use of Bath stone as principal building material.

Not agreed. This needs to be formulated at masterplanning and detailed planning stage having regard to design objectives etc.

No change.

7.4.1

Need for overall co-ordination of design of public realm.

Agreed. This needs to be properly orchestrated across and beyond the site through masterplan.

Amend text in 7.4.1 and 1.4.3 (masterplan requirements).

7.6.1

River in a natural orientation and legibility benchmark. Greater reference to the river is required throughout the document.

Agreed. River Avon is central feature ofregeneration area and should be a focus of attention.

Several additions to text to include reference to the river e.g. 7.6.1. In addition the masterplan should be informed by the Bath River Avon Waterspace Strategy now being produced by the Council.

7.2

None of the items listed under "character" are capable of any site specific interpretation and are of little value to landowners, developers and designers. Much of this part of the SPG is merely a reiteration of general principles.

Not agreed. The SPG clearly sets out relevant guidance for developers and for the masterplanning stage.

No change.

9. SUSTAINABLE USE OF RESOURCES

8.1 - 8.4

This section should be expanded and moved from section 9 to section 4.

Agreed that section should be expanded.

Amend text to incorporate suggested additions relating to land, river, buildings, energy, water, materials, waste, habitats.

Not agreed that section should be moved. The precise location/ order of topics in the document is largely stylistic and immaterial. The document must be read as a whole. The order in which topics are presented has no bearing on their relative importance.

No change to order of topics.