Meeting documents

Ref Plan Ref Comment Summary Last Modified/Officer

Clerk: L Holyoake

Our overall view is that there should be a presumption that this site should be used largely for housing, with a community infrastructure and some high

tech/science park employment. The riverside should become a linear park for the whole of Bath to enjoy.

shops and pubs should be made.

acceptable.

of the University's Campuses.

Clerk: Judith Plucknett

viewed overall as an admirable project but there are concerns that due consideration has not been given to the impact of this large development on the existing

businesses in Bath and the surrounding area. If this has been fully considered what were the results of the study? Bath & North East Somerset currently has

very low unemployment so where will the additional labour force be recruited? Is it likely to be from outside the area and will people require a financial

inducement to encourage them to move and work in an expensive, attractive area?

The transport plans appear to be very vague. Access for cars is apparently restricted but there is no proposal for a new bus station. Will there be taxi ranks and

city buses circling the area? An inadequate transport system would result in loss of trade and inaccesible 'no go areas'. Prospective residents require support

facilities i.e. health centres and schools to attract them into an area and these all need funding. The paramount concern is that of funding for the project and

cost control. What controls will be implemented to avoid a repetition of the financial shambles of the Spa project?

Clerk: M Townley

there is a significant lack of "access" and the various "link" proposals are indeed very tenuous.

Ref Plan Ref Comment Summary Last Modified/Officer

Employment in this new complex will surely be open to all in the surrounding and rural areas?

losses...

Clerk: M J Whittock

Director: Steve Bendle

whole site to a high standard, with the inclusion of integrated travel choice.

Quality Excellence and Innovation in Design

The development of a modern design which takes account of sustainable development principles depends on integrating the principles into the planning and

design rather than adding them later. The Environmental Impact Assessment for the Southgate development is an example: it is possible to argue that a

modern building, through basic regulation alone, is more energy and water efficient than existing ones and to avoid any deeper examination of sustainability

Employment - A centre for enteprise with serviced premises and support for start up businesses.

Cultural/Leisure - A centre for environmental information and equipment related to the development itself.

problems. Options might include some car free housing and automatic car club membership.

specific but "explore CHP..." is a weak recommendation which could be easily left out of account whereas this would seem a key oppurtunity for beginning to

establish a CHP network for Bath.

is very vague.

I would propose that it might be better to pick up on the "every stage" requirement in 9.1.1 and relate the following sections to those stages.

Ref Plan Ref Comment Summary Last Modified/Officer

Beth Brown

Personally, I would propose a centre for Healing and Reconciliation, to be integrated either into the community complex or the healthcare facilities. I assume

this to be sufficient detail for the S.P.G stage but am of course aware that the precise nature of such a project would need to be discussed/negotiated in great

Basil Greenwood

legislation and guidance.

Wendy Linham

exVenture liaison on this issue has been carried out with PC Saunders, the Architectural Liaison Office, Crime Reduction based at Bath & NE Somerset Police

District.

From my perspective, with involvement in Traffic Management and Road Safety, I would request that the chosen options for inclusion within this redevelopment

should achieve the aims on their own merits rather than reliance upon a third party i.e. the Police, in the form of enforcement. I look forward to having a closer

Rob Saunders

increase sustainable communities.

I would like to see community safety being represented at the pre planning meetings. To get completed plans just to consider a few houses going for SBD is

too late.

the people who can will move out and those that can't will be left behind and the area becomes run down. Sec 56 Designing For Quality Of PPG1 talks of new

housing development and the need to create places and spaces with needs of people in mind to promote layouts which are safe and take account of public

health, crime prevention and community safety considerations.

Sec 5 of the Crime & Disorder Act 1998 places a resposibility within each local authority area on the chief executive of the local authority and the chief police

officer to exercise their responsibilities and functions, to act in co-operation with other named bodies: Sec 3 states the responsible authorities shall in

accordance with the provisions of Para 5 formulate and implement strategies for the reduction of crime and disorder in their areas.

which also states that crime prevention is capable of being a material consideration in determining planning applications.

should: carefully consider security and personal safety, especially for children.

Ref Plan Ref Comment Summary Last Modified/Officer

other housing associations all will apply for secured by design status due to the large grants that are available for going down that route from government.

As the local architectural liasion officer the plans will fall to me. I will be unable to look at the social element in isolation as the units will more than likely be

pepper potted across the site, each element is effected by other factors.

Andrew Vines

documentary study of the historical development of the area over time, and an appraisal of the value or otherwise of the remaining structures on it (see 4.2).

The Master Plan should be informed by a detailed desk-based study of the historic development of the site by researching documentary information including

maps and other archival sources, to provide an informed view of the Western Riverside's changing function, character and appearance over time, and its place

in relation to the wider city. This process should inform not only future site planning but also an assessment in the Masterplan of the nature and significance of

the remaining structures on the site.

listed buildings. These remain the two statutory designations and indeed parts of the Western Riverside lie within the conservation area, as well as containing

listed buildings, with the potential for development to affect the setting of others. At present listed buildings and the conservation area appear to be only

mentioned in respect of the environmental appraisal at 4.2 and I think these aspects need greater emphasis in the document to reflect their statutory

the characterisation, or character-based analysis, of the site's wider context in the western part of the city (see 8.1). Characterisation is a developing approach

for managing change in historic urban areas with its roots in landscape character assessment. It is a methodology for mapping, describing and evaluating the

historic dimension of the urban landscape on a comprehensive area basis. It involves gathering data on the historic development and attributes of an area,

such as building age, building form, materials, functions, height, scale, and open spaces. By this means areas with common attributes can be grouped into

character types and value judgements applied to them.this helps to define the historic character and provides a positive approach to future change and a

framework for regeneration. In this case it should ensure that the western riverside redevelopment properly integrates into the historic character and grain of

Bath, and principles of the draft document. Such an approach would form an initial phase of the masterplanning work and should directly inform it. We would be

pleased to give further advice on characterisation and discuss with you how it can be integrated into this process.

Given the desire for the redevelopment to be compatible with Bath as a whole (4.1 and 5), I consider it an essential aspect of any Masterplan approach that it is

underpinned by the characterisation of its wider context, as described above. In this case the area appropriate for study should include at least the western side

of Bath and the city centre. I would recommend that the need for a character based assessment should be identified both in this section and in para. 4.2. you

may wish to use the general paragraph above as a basis for the text.

patterns of development which will be defined and informed by the characterisation process described above. However given the extensive new development in

the area it is likely to gain its own identity within the context of Bath's overall character.

patterns of development which will be defined and informed by the characterisation process described above. However given the extensive new development in

the area it is likely to gain its own identity within the context of Bath's overall character.

the city centre but also the site's immediate context in the western suburbs of Bath (where building heights are generally lower), together with the wider valley

setting. This should be clearly stated. The comparison of eaves heights with the city centre therefore appears somewhat arbitrary and is not in any case clearly

defined. I firmly believe that these issues of scale and building height are better resolved through the characterisation process mentioned above which should

give a clear steer to the Masterplan in this respect. I am aware that there may be considerable pressure to increase to increase building heights on the western

riverside above what may be generally considered appropriate. However I believe that the sort of density of residential development envisaged by PPG3 is easily

achievable here without the need to resort to inordinately high buildings, given the desire to follow the high density pattern and grain of the city's historic

housing.

Secondly I would recommend changing the phrase 'landmark taller buildings' to 'landmark buildings'. English Heritage agrees with the recent House of

Commons report that tall buildings are inappropriate in Bath and we would object to the suggestion that this is a suitable location, given the City's international

importance. We do however agree that landmarks within an overall appropriate scale of development are a sound principle for creating a good urban

environment, hence the suggested alteration above.

Ref Plan Ref Comment Summary Last Modified/Officer

to be the most appropriate, given the context. It could also imply encouraging the proliferation of poorer quality artifical alternatives, to the detriment of the

development as a whole, and I would therefore suggest deleting this point.

Transport & Highways Committee: Derek Walker

unsuitable. The Chamber takes a view that the absolute minimum parking provision should be one car per housing unit.

affordable homes that enables a judgement to be made on the practicalities of providing such homes.

unsuitable.

unsuitable.

John Webb

Western Riverside Development the text of the Draft SPG Document is notable for the lack of specific reference to the river and its frontages.

The river at present represents a squandered oppurtunity and as a consequence that part of it which comes within the boundaries of the Western Riverside

Development should be progressively redeveloped and managed so as to provide a benefit to the river's users who shall include but not necessarily be confined

to Boaters, Anglers, walkers and other river walkway users.

Such waterfront and adjoining development will reinstate what is currently missing from an otherwise much admired and beautiful city. It will serve to contribute

to and rectify what is currentlyone of the city's less attractive features. The upgrading and redevelopment of the water front should serve to improve Architectural

and Environmental aspects of the city. The fact that the development must also benefit the economy of the city by adding an area which will be attractive to

visitors and tourists must be taken into account.

The above would be driven from an agreed vision of what the waterfront should be like on the completion of the Western Riverside Development. This would

include clean water within a clear and dredged cruise way used by tripand hire boats as well as those belonging to private owners.

I addtion to this river traffic would be supplemented by the use of "water taxis" a river bus service and "park and glide", all of which will have to be considered as

part of the Local Integrated transport Plan.

To service such river traffic, which in itself will serve to bring the river to life, it will be necessary to provide perhaps marinas, visitor moorings, boat supply and

service points and possibly a designated "Bath Harbour"

Cafes, restaurants and public houses as well as hard and soft landscaped areas will be required so as to enhance the riverside setting and in so doing attract

people so as to make the new development area vibrant and successful. Such facilities will both compliment and be to the benefit of the adjoining buildings.

In setting the criteria for the newly created water front area regard must be had for accesibility which must as a minimum include continuous riverside walkways

on both banks.

paragraph 1.06 of our response.

A3o 2.2.2 We feel that the river is of sufficient importance that it must warrant a specific mention in your sub paragraph 2.2.2. 27-May-03 16:41

A4n GDS.1 23-May-03 15:42

A5n 3.1.1 Paragraph 3.1.1 should recognise the part played by the existing bridges in "linking" the north and south banks of the development. A future high quality 27-May-03 16:40

A6o 4.1.1 We are disappointed that under this heading and in paragraph 4.1.1 no mention is made of the river. The river frontage is in its present sorry state because in 27-May-03 16:40

A7n 4.2.1 It is considered that the "Riverscape" should be mentioned in paragraph 4.2.1. It is fundamental to the attractiveness of a city and whilst it may not as is the 27-May-03 16:22

A8n 4.9.1 We consider that the landscape proposals dealt with under paragraph 4.9.1 should be expanded to specifically refer to those which are to be provided so as to 27-May-03 16:19

A9s 5.1.1 Reference to the "New City Quarter" in paragraph 5.1.1 is to be commended. We would suggest that this statement could be expanded to state that its objective 27-May-03 14:23

A10o 5.1.2 Surely the presence and importance of the river warrants it being given "Key Principle" status under paragraph 5.1.2. 27-May-03 16:19

A11n 5.2.1 23-May-03 15:44

A12n 5.3.1 The words "socially inclusive" are mentioned at paragraph 5.3.1. such a stipulation would logically include access to both river banks by way of continuous 27-May-03 14:21

A13o 5.4.1 The words "employment and other accessible sevices" must not ignore the river and services to boaters should not be forgotten and should perhaps be 27-May-03 09:28

A14o 6.1.1 30-Apr-03 12:00

A15o 6.1.4 We are disappointed that the river and its frontage have not been listed in elements considered suitable for the development, this at paragraph 6.1.4. For 27-May-03 09:30

A16n 6.2.1 Paragraph 6.2.1 deals with accommodation and identifies the need for what are essentially high density dwellings. The Landscape Estates Scheme in its self 27-May-03 09:34

A17o 6.3.2 Under paragraph 6.3.2 the matter of employment accommodation is dealt with again unfortnately without any reference being made to the river. 27-May-03 09:35

A18s 6.4.1 Paragraph 6.4.1 deals with the need for Pubs, bars and restaurants which we applaud. 27-May-03 16:17

A19n 6.5.1 Pedestrian movement is addressed at paragraph 6.5.1. The continuous riverside walkways would fulfill this need and be less vulnerable to traffic 27-May-03 16:17

A20s 7.1.2 Whilst applauding the direction to provide provision for walkers and cyclists at paragraph 7.1.2, could not this be extended to cater for boat travel in the form of 27-May-03 16:16

A21n 7.1.3 At paragraph 7.1.3 it is perhaps logical to include the statement that a jetty is to be provided as a connection point to the inter city transport interchange at 27-May-03 09:48

A22o 7.2.1 Your paragraphs 7.2.1 and 7.3.1 deal with Integrated Transportation and Park and Ride expansion. Surely this should be expanded to consider river taxis/buses 27-May-03 16:16

A23o 7.3.1 Your paragraphs 7.2.1 and 7.3.1 deal with Integrated Transportation and Park and Ride expansion. Surely this should be expanded to consider river taxis/buses 27-May-03 16:15

A24s 7.5.1 Under the heading of access at paragraph 7.5.1 we would like to see added preferably as a principle means of transport but certainly as a secondary or 27-May-03 15:32

A26s 8.2.2 We are very pleased to note in paragraph 8.2.2 the comments concerning the river being the strongest landscape feature of the Western Riverside area with the 27-May-03 15:32

A27n 8.2.2 A further important point that requires inclusion is the need to bring the river to life. Your draft document tackles this to some extent by dealing with abutting 27-May-03 15:31

A28s 8.2.4 At paragraph 8.2.4 you deal with the requirement to maintain existing views. Whilst supporting this sentiment we would go further and state that the objective 27-May-03 15:24

A29n 8.2.6 Paragraph 8.2.6 covers materials and roofscapes. It is our view that good design, whether modern or intended to replicate a previous period, tends to stand out 27-May-03 15:23

A30n 8.3.1 Under paragraph 8.3.1 could a specific requirement be included covering the hard and soft landscaped areas bordering the river frontages. This would link with 27-May-03 14:13

A31n 8.4.1 Under paragraph 8.3.1 could a specific requirement be included covering the hard and soft landscaped areas bordering the river frontages. This would link with 27-May-03 15:22

A32o 8.5.1 In paragraph 8.5.1 river transport would sit with the objective expressed and should be stated. Well lit and secure access to the river will also meet the safety 27-May-03 15:22

A33o 8.6.1 A natural and obvious orientation benchmark is surely the river which bisects the site on an East to West axis. Perhaps this could be stated. 23-May-03 15:13

A34n 8.6.2 The river would also be an obvious focal point the requirement for which is dealt with at paragraph 8.6.2 Also in respect of this there is no better feature against 23-May-03 15:50

A35n 8.6.3 The display of public art dealt with by your paragraph 8.6.3 surely has a natural and obvious setting in the open spaces adjoining the river. 23-May-03 15:50

A36s 8.8.1 We concur with your stated objective set out at paragraph 8.8.1 to avoid a "honeypot" situation. For our part we would also favour spreading out the riverside 23-May-03 15:50

Ref Plan Ref Comment Summary Last Modified/Officer

would however advocate placing a requirement on the development to incorporate holding tanks for both systems so as to ensure that in periods of heavy rain

the risk of overloading the new Wessex Water CSO would be negated.

Philip Poulsom

comprehensive approach to the development of Western Riverside.

In the context of a £1 billion urban regeneration project that ranks among the largest in the South West of England, and that needs to complement and enhance

the City of Bath's status as a UNESCO World Heritage site, the requirement for a comprehensive framework for evaluating and determining planning

applications is overwhelming.

Given that the Supplementary Planning Guidance (SPG) document is primarily concerned with high level principles and policies, the Initiative welcomes

B&NES' intention to proceed by way of a Masterplan that will permit all interested parties to consider the project in overview as well as in detail.

One way in which this point is recognised is via the importance the SPG attaches to `connectivity'. In this way, an assurance is given that `connectivity' will be

thoroughly considered and incorporated in the Masterplan, not only in terms of how the new areas created within Western Riverside will connect with each

other, but also how Western Riverside itself will connect naturally and seamlessly into the areas that surround it.

The Initiative is strongly supportive of the emphasis the SPG places on the twin issues of sustainability and environmental soundness. Not only are these

important specifically for the regeneration of Western Riverside, they are also of material significance to the long term strategic direction of the B&NES

economy, being a prime example of how University research expertise can be linked to new business formation and the creation of new job opportunities.

The Initiative is supportive of the requirement to use local traditional building materials that are `all of a piece' with the heritage City area.

outputs that subsequently emerge. It is important that Western Riverside is accessible and convenient for residents, workers and visitors alike because, without

a superb transport solution, the wealth generating potential of Western Riverside cannot be optimised.

segments that Bath serves, including health tourism. While the SPG points to such facilities in general terms, the opportunity needs to be taken to consider

how Western Riverside can be used to promote the potential of, say, water-based sports and recreation, linked to the river, in order to create a major new

attraction. (In other words, Bath should use the opportunity of Western Riverside to reinforce its attractiveness as a world famous Spa health resort)

the provisions of the SPG should permit and encourage `thinking outside the box'. For example, complementary to its primary function, the Eden Project is

developing its site imaginatively to accommodate a successful range of cultural uses, combining education with creative arts and entertainment.

ranges are generally small/medium, not large. (For instance, Bath can comfortably accommodate conferences up to, say, 200 delegates, whereas it is clearly

not in the market for 1,000 delegates)

to bring together a comprehensive view of landscaping, vistas, views, river and bridges, roads and other key features. It is vitally important that magnificent

streetscapes and riverscapes are created that reinforce Bath's regional and international reputation, and that reflect well against the principles of `Civic Pride'.

efficient and cost effective way, by giving well prepared and documented guidance backed up by expert advice. It is of crucial importance that the adoption of

the SPG is used to deliver a planning process performance that helps developers mitigate the planning risks they take.

the buildings that are actually built and the micro economy of Western Riverside which, in the Initiative's view, should be distinctly knowledge based, and

innovative and creative in character.

Ref Plan Ref Comment Summary Last Modified/Officer

family groups, needs to be much better described. It must be more than providing a school with games and recreation space, because it is about creating

environments in which they can thrive and where their development can be nurtured. Building on this idea, perhaps a series of perspectives for all the various

age groups can usefully be devised?

facilities, are to be designed into the entire regeneration project. There is a design dimension to the provision of utility services that needs to be carefully

thought about so that it can be incorporated into design and planning guidance documents.

interaction with those spaces

Monira Ahmed Chowdhury

ensure that the needs of the wider community are met. Complement rather than compete with existing city-centre facilities; cultural/leisure - a concert

venue/conference centre; community - development of education, community and health facilities;

city in terms of those who live, work, study or visit. The present government is making extensive capital of embracing and valuing diversity and this is not really

reflected in the plans as presented.

Agency

England Regional Development gency (SWRDA) with regard to the publication of this important document. The SWDRA broadly supports its contents and

looks forward to continuing to work with the Council in order guide future development proposals.

Michael Briggs

objective of 30% (a higher target would be even better) will only be a reality if the council are determined in their lobbying of government to obtain a realistic

subsidy to match local authority/private subsidies to support the objective. We would wish to see affordable housing of a mixed type and spread throughout

develop a new city quarter on a brownfield site.

A4n 4.1.1 The SPG should acknowledge the objectives set out in the Draft World Heritage Site Management Plan, which will encompass Western Riverside, in particular 19-May-03 16:22

A5n 4.2.1 Every effort must be made to preserve the façade of the Bath Printing Press, Lower Bristol Road 19-May-03 16:21

A6n 4.3.1 For 'preliminary' should read 'preliminarily' (or delete) 19-May-03 16:21

A9o 5.4 Overall these principles are too vague and meaningless and need to be further developed or else deleted. How do these principles relate to the draft SPG 19-May-03 16:19

A10n 5.2.1 The architectural style should not be laid down in the SPG or Masterplan - whatever architects produce should be treated on its merits. As a World Heritage 19-May-03 16:19

A11o 5.3.1 'High density' - ratio must be specified in SPG. The Trust urges at least 50 dwellings per hectare. High density without high rise is imperative. 19-May-03 16:18

A12s 6.3 We agree with the general principles of commercial and employment oppurtunities at Western Riverside, especially if this is provided as a mixed, high density 19-May-03 16:18

A13o 6.4 'Bulky goods retail' requires access by car and we believe would be better located to the perimeter of the site. 19-May-03 16:18

A14n 6.5.2 The SPG must be consistent in use of terminology e.g. unit sizes. The 5,000 m2 school playing field should be referred to as 0.5 hectares, to put it in 19-May-03 16:17

A15o 7.2 'Integrated Transportation' should read 'Integrated Transport'. The guidance here must relate to the 'Transport Strategy' for Western Riverside, still to be 10-Jun-03 10:51

A16o 7.3 In the absence of a Transport Strategy for Western Riverside we reserve the right to comment further on the detailed proposals for the proposed extension of 19-May-03 16:16

A17o 7.4.3 In the absence of a Transport Strategy for Western Riverside we reserve the right to comment further on the detailed proposals for the proposed policy of 0.7 car 19-May-03 16:16

A18n 7.5.3 The guidance should include the provision of new bridges across the River Avon, and the potential 'Gateway' of Green Park station, linking Western Riverside to 19-May-03 16:15

A19n 8.1.1 Again, the guidance here should refer to the objectives of the Draft World Heritage Site Management Plan (Jan 2003), in particular Objective 11; 19-May-03 16:15

A20s 8.2.2 We fully support the orientation of buildings towards the river frontage and would like to see the innovative use of balconies to extend the architecture over the 19-May-03 16:14

A21o 8.2.3 We would like to see a dense urban development with real streets and small open spaces that reflect the pattern of historic Bath. The vital factors here are 19-May-03 16:14

A22o 8.2.5 'High density' - ratio must be specified in SPG. The Trust urges at least 50 dwellings per hectare. High density without high rise is imperative. 19-May-03 16:12

A23o 8.2.6 The guidance is too vague in determining the type of materials to be used on the site. For the Western Riverside to integrate with the World Heritage Site the 19-May-03 16:12

A24n 8.3.1 The SPG and Masterplan should adhere to a traditional pattern of streets, namely continuous street frontages, bordered by a natural stone pavement with a one 19-May-03 16:11

A25n 8.4.2 The SPG shuold stipulate the publication of detailed design statements, as well as management and maintenance agreements for the public realm, to 19-May-03 16:11

A26o 8.6 The SPG must include robust guidance on the lighting of Western Riverside. This is not addressed in the Draft SPG. It is vital the SPG acknowledges the 19-May-03 16:10

A27o 8.6.3 Do we need really extensive public art at Western Riverside. It is the design and function of the architecture which should create the principle 'striking and 19-May-03 16:10

A28n 9.1 It is imperative the development of Western Riverside takes into account the inevitable future impact of global warming. 19-May-03 16:09

A29o 9.2 Clarify the guidance on energy. Surely the assumption is not to only make use Renewable sources of energy on Western Riverside. What about National Grid 19-May-03 16:09

A30n A Add the Draft World Heritage Site Management Plan (January 2003) 19-May-03 16:09

A31o 1.3.1 We are concerned about the Council's percieved implementation of the redevelopment and in particlar the issue of land assembly (ref 1.3.1). It would appear 19-May-03 16:08

A32o 8.2.5 An objective of the Bath Preservation Trust is to encourage a high-density housing development on Western Riverside. Whilst the draft SPG (ref 8.2.5) 19-May-03 16:05

A33n SPG With regard to the draft SPG pursuit of 'excellence and quality of design, in the regeneration of Western Riverside as an enhancement of the World Heritage 19-May-03 15:55

Ref Plan Ref Comment Summary Last Modified/Officer

- The character of Bath is inextricably linked with the use of natural Bath stone for all street frontages.

- Streets of traditional pattern should be created, namely a carriageway with pavements raised by a one step of natural stone.

- Excessive amounts of glass should be avoided (except for special architectural effects). Too much glass is detrimental to both residential and office use and

can cause unfortunate light reflection.

- As in the Georgian City, heights of buildings should be fairly uniform and rooflines horizontal.

- Roofscapes will be conspicuous because of the valley bottom nature of the site. Traditional pitched roofs of natural slate should be encouraged, and flat

roofs must not be allowed.

Finally, we are disappointed the SPG makes no detailed reference to the integrated transport proposals, in particular the route of the proposed LRT. The SPG

must be assessed in conjunction with a comprehensive Transport Strategy for the Western Riverside, as yet unpublished by B&NES Council.

Barry Smith

The use of sustainable urban drainage systems where appropriate could also be promoted at this point.

these aspects will be a fundamental element of any planning consideration should help to focus developers thoughts along those lines.

land contamination will also be relevant considerations..."

physical boundary of the site. This will assist in providing a more complete picture on the biodiversity potentially impacted by the proposals.

environment' could replace 'resource'.

The words 'where-ever possible' could be deleted as they are superfluous. It should always be an objective to minimise resources even if this cannot be

be required for works in, under, over or within 8.0 metres of the bank-top of the River Avon.

working with the LPA, developers and others as appropriatein achieving this.

supports the desire for proposals to use sustainable drainage systems where-ever appropriate. The main thrust of such systems on this site will be from a

water quality viewpoint.

It should be noted that the word 'Urban' is no longer used when describing sustainable drainage systems. The accronym SuDs uses the 'u' from sustainable.

This is in recognition that such systems have a benefit in all locations not only urban areas.

Ref Plan Ref Comment Summary Last Modified/Officer

The intention that proposals should exploit the use of renewable energy including solar again is supported. The waste management sub-section is welcomed.

The proposals must seek to minimise waste where-ever possible. It should be noted that the second bulet point uses the word 'urban'. This should be deleted

in line with my comments above.

Managing Director: Brian Norton

Riverside as a significant area of under utilised/derelict land close to the historic heart of the City. In that closeness however, lies one of the principal

inclined to make use of public transport, even when it has been provided. That factor will unavoidably result in a reduction in the potential level of demand for

any operations which are provided. Equally, for many people, the location will be well beyond walking distance and there is therfore a need for public transport

demand (on which public transport is always very dependant) is inevitably reduced - a mix of residential and office development will never provide the same

level of public transport demand as a simple purely residential development, or a simple purely employment development.

Given the above, it is the view of First that a great deal of the way in which Western Riverside will be served by public transport, will depend on existing facilities

which are already in the area, which may or may not be diverted as necessary. Diversions which do not significantly add to the overall journey time of through

services would assist in providing the maximum frequency of public transport through the site which itself always has a generative effect on use. It is however,

equally important to avoid isolating existing users on sections of road which may no longer be used at that point. First would therefore like to work closely with

the authority and the developer to ensure that the maximum utilisation of existing facilities can be achieved with minimal adverse effects.

(Para 7, point 2.1) is not fully understood and could mean many different things to different people. It may very well be that there will be scope to provide a

transport corridor through Western Riverside from Newbridge but the extent to which that can be utilised by any existing facilities will depend on the level to

which existing demand to the Upper Bristol Road would be disrupted. Again, we are prepared to work closely with the authority and developer in order to come

the Park and Ride system, but that is something which, as the main Park and Ride contractor in the City, we would be prepared to consider closely with the

authority. It would again be important to ensure that any extension or diversion of the existing network was not to the detriment of the very high level of existing

users of the network - it could very well be that the proposals which integrate the Park and Ride services with the principal network of City operation through

integrated ticketing, could offer a far more cost effective and attractive solution for potential users.

G Creed

Rides, the railway station/bus station.

If the oppurtunity to include a tram system is lost at the planning stage it will be impossible to build it later.

Lisbon (Portugal) has all the problems usually associated with Bath, steep hills, narrow streets, old buildings, underground cellars, and still they have a superb

& expanding tram system, as do most major cities in Europe.

My objection would be withdrawn if the scheme included a definte plan for a tram system to link the new development with the places listed above.

Ref Plan Ref Comment Summary Last Modified/Officer

Sue Wilcox

development give due regard to, and do not adversely impact on the viability of existing commercial interests in the area. This includes the existing Sainsbury's

store and petrol filling station at Pines Way.

The Sainsbury's store is one of the major foodstores in Bath, and in particular has an important role in serving the main bulk food shopping need of south and

west Bath. The Sainsbury's store therefore provides a valuable community service, particularly as it has good accessibility by car and public transport.

alternative provision (Para 6.7.1). (particularly those providing a valuable community service) to remain in the area, and which therefore will need to be properly

integrated with new development.

Following the above, the guidance should also state that in cases where it is appropriate for existing uses to remain, they should not be commercially

disadvantaged by proposals for new development.

However, it is important that the council adopt a realistic approach when assessing the operational requirements of development proposals and those of

existing commercial uses in the Western Riverside area.

Furthermore, it is also important that the council adopt a realistic approach in their consideration of how, and to what extent, development proposals should

contribute to transport solutions and objectives for Western Riverside and the wider area. For example, the requirement to contribute towards off-site

infrastructure should be fairly and reasonably related to the transport effects of the proposed development.

the Sainsbury's can only provide this community service (and also remain commercially viable) by having a suitably sized customer car park and efficient means

of vehicular access. The comprehensive redevelopment of the area should not result in a reduction in existing parking facilities, inferior alternative parking

arrangements, or restricted access to the extent that sainsbury's are unable to meet customer requirements and viability is conseuently affected. This point may

be equally relevant to other commercial interests in the area.

need to be a range of densities across the area in order to reflect the operational requirements of existing and proposed uses. For example, the existing

Sainsbury's store requires adequate parking arrangements and comfortable shopping conditions in order to meet customer expectations and be commercially

viable.

The council will therefore need to be flexible in the application of density requirements across the Western Riverside area to reflect the operational

and Homebase sites, that serve a wider catchment area in the city of Bath and beyond, including the nearby residential and working population. Proposals for

new shopping need to make proper provision for this role to continue in order that the reasonable requirements of the shopping public are met.

Accordingly, with particular reference to Sainsbury's, any redevelopment proposals should make adequate provisions either for the retention of the existing

store, or for its relocation within Western Riverside to a site where it can properly serve the bulk food shopping needs of its catchment population.

Ref Plan Ref Comment Summary Last Modified/Officer

Andrew Philips

Wessex Water is responsible for drainage, sewage treatment and water supply facilities in this area. Due to the scale of the development and the impact on

this infrastructure, early discussions between potential developers and Wessex Water will be required.

Ref Plan Ref Comment Summary Last Modified/Officer

Paul Kemsley

this for two reasons.

Firstly the primary development plan (i.e. the B&NE Somerset Deposit Local Plan) that is intended to supplement is itself some way short of adoption.

Accordingly the draft SPG is attempting to second-guess a policy that may itself be subject to further and possibly fundamental change. There is in any event

no need for the Council to take this course of action since it has already adopted enough guidance material to provide a "Development Framework" for the area.

This provides landowners with a clear approach to the development of large sites within Western Riverside, providing they take a comprehensive view of the

area. This guidance includes, in particular, Bath Western Riverside Comprehensive Development Framework Report and Background Studies, 2001.

Secondly the content of the draft SPG is far too vague and general to offer any effective supplementary guidance, containing little that adds to the detail or

interpretation of Policies GDS.1 and IMP.1 of the draft Local Plan. It primarily contains a set of principles that need to be substantially expanded and made site

specific if they are to have any real value. These shortcomings are further compounded by the acknowledgement that more detailed advice will be contained in

the Master Plan that will follow the adoption of the current part of the SPG. Whilst it is also proposed to take the Master Plan through a period of public

consultation, it clearly will not be subject to such rigorous scrutiny as the SPG itself since it will rely on that document to provide the policy justification for its

contents.

The conclusion is that the draft SPG is premature and unnecessary, at least in its published form. It will only be meaningful when Master Plan proposals are

included as an integral part of it. The current phase of the SPG process should therefore be postponed until it can be married to the Master Plan process. This

will then produce a policy document that genuinely provides supplementary planning guidance rather than a vague set of development principles which do not

add to the already adopted framework documents.

Further, there is no need for there to be a single, overarching, Master Plan for the Western Riverside area since this could be dealt with by sub area Master

Plans for major sites within it. These can be prepared under the umbrella of the already adopted policy documents that provide an effective "Development

Framework". If such plans are compatible with the "Development Framework" and have been subject to public consultation there is no reason why they should

not be able to proceed in advance of the formal adoption of the SPG. The Master Plan that forms the basis of the current planning application made by

Landscape Estates in October 2002 and currently being considered by officers accords with that approach. One or more Master Plans, covering substantial

parts of the remaining Western Riverside Area, would better achieve regeneration of it and in a far quicker timescale, the site is derelict and should provide

certianty that we go ahead and have taken into account cumulative impact.

Paragraphs 3.15 to 3.18 of PPG12 Deveopment Plans set out the circumstances in which SPG may be prepared. In the view of Landscape Estates the draft

SPG (as published) fails adequately to meet these guidelines. While paragraph 3.15 states that SPG "can take the form of design guides or area development

briefs, or supplement other specific policies in plan" the Bath Western Riverside Draft SPG fails to offer enough specific advice to supplement anything in the

current development plan. Furthermore it cannot meet the test that it "derives out of and is consistent with the development plan" (paragraph 3.16) since the draft

local plan is still some way short of adoption. Similarly paragraph 42 of PPG1 makes clear that "supplementary planning guidance does nto have the same

status as an adopted development plan policy and should only be referred to in the reasoned justification for a policy". It is axiomatic that until the local plan

has been adopted, it will be impossible for the SPG to be referred to in the "reasoned justification".

This view is further reinforced by the advice contained in the DETR/CABE document 'By Design.' Here clear advice is given about the preparation of SPG in

general and major areas of change, urban regeneration and redevelopment in particular. None of the advice contained in 'By design' is contained in the Western

riverside SPG. 'By Design' refers to Urban design Frameworks - not a Master Plan and clearly specifies the topics that should be covered, such as building

heights, urban structure, massing and density. Particular reference is made to the sub-division of large sites into development blocks so as to encouragemixed

uses. None of these topics are dealt with in any meaningful way in the Western Riverside SPG. By contrast all of these matters are addressed in the

Landscape Estates planning application.

Individual parcels of development land may come forward without prejudicing the comprehensive approach and there should be an informal partnering

relationship between responsible planning authorities and responsible landowners and developers. There needs to be a degree of pragmatic realism injected

into the Council's approach. Promoting theoretical SPGs and Master Plans, where an affected landowner is already promoting a planning appication, are

unnecessary provided that application is not prejudicial to the already adopted regeneration framework. It is, in the view of Landscape Estates, incumbent upon

the local planning authority to do everything that it can to assist and promote an SPG that asssts in the regenration of a derelict site, not hinders it.

In any event it should be reiterated that the contents of the Landscape Estates Master Plan accord with the various planning guidance that the Council has

already adopted for the Western Riverside Area. It is also worth underlining that the Landscape Estates proposals would not prejudice the wider regeneration of

the Western Riverside. This point has particular force bearing in mind the Council's reliance on the need for the subsequent comprehensive Master Plan for

the entire regeneration area.

A2o 1.3.1 It is worth pointing out that compulsory purchase powers are unlikely to succeed if existing landowners are willing to carry out the same kind of development for 27-May-03 15:54

A3o 1.3.2 Reference to the content of the Master Plan is also unnecessary, particularly as the issues canvassed in the SPG are statements of general principle. Most are 23-May-03 11:32

A4o 1.3.3 Similary the attempt to link the SPG to Policy IMP.1 of the emerging LP is unnecessary since the policy is clearly capable of being applied to the Western 23-May-03 11:29

A5o 2 The section of the draft SPG dealing with Context adds nothing of substance that is not already contained in earlier adopted planning documents or the draft 23-May-03 11:28

A6o 3 The extent of the Western Riverside Development Area as defined in the draft SPG is generally acceptable and has been extensively canvassed in earlier 27-May-03 15:54

A7o 4 The section of the SPG dealing with the Development Context is of little or no value to the specific circumstances of the Western Riverside SPG. Firstly it sets 23-May-03 11:24

A8o 5 Whatever the shortcomings of section A, this section of the guidance should be clear and specific and above all of direct relevance to Western Riverside. The 23-May-03 11:20

A9o 6.3.2 Where this section of the SPG describes the possible development mix the resultant comments (paragraph 6.3.2) show little market awareness. For example 23-May-03 11:19

A10o 6.5.2 Other proposed land use allocations, such as the proposed school site, are unsupported by any need assessment and not directed towards any specific part of 23-May-03 11:16

A11o 7 Section 7 deals with Transportation issues and starts with the reasonable proposition that the transport implications should be assessed for the site as a 23-May-03 11:14

A12o 7.2 Similarly section 7.2 refers in very general terms to "Integrated Transportation" and the need to link the Newbridge Park and Ride site and "other related areas." 23-May-03 11:12

A13o 8 Section 8 of draft SPG purports to deal with "Quality, Excellence and Innovation in Design". It starts by referring to the DETR/CABE publication 'By Design' and 23-May-03 11:10

A14o 8.1 Weakness of the draft SPG. Instead of giving area or site specific guidance it refers to principles that will be applied in a later, and in Landscape Estates view, 27-May-03 15:54

Ref Plan Ref Comment Summary Last Modified/Officer

crossings, public access to the river and the value of the site to the World Heritage Site. None of these items however is capable of any site-specific

interpretation and is therefore of little real value to landowners, developers and designers. The final section of this part of the SPG, dealing with sustainability,

is even more reliant on a restatement of principles drawn from a variety of 'good practice' guides and contains even less guidance that relates directly to the

Regional Manager: Peter Bond

comprehensive and co-ordinated way.

through independent assessment and careful research which has been debated with the private sector to ensure it is robust. The inclusion of an

unsubstantiated fixed figure of 30% is contrary to those methods of good practice and current Planning Guidance Notes, so it should be deleted. The policy

imprecise leading to ambiguity and considerable scope for confusion. The reference and phrasing needs to be properly qualified and reflect direct relevance,

reasonableness and financial viability. An open ended requirement such as this could frustrate the development and sterilise the scheme so the requirement

needs to be much more measured. The need for financial viability is important reflecting and making the revised wording consistent with Vision Statement in

allow flexibility in individual circumstances while leaving a reasonable aspirational requirement. Our proposal is that "Building orientation should where

possible, pratical, feasible and viable endeavour to obtain optimum benefit from passive solar gain".

appropriateness and ensure the obligation is an endeavour.

refined.

recognise that the realistic aim is to "encourage the reduction of travel......"

"needs" should also be qualified and the "wider community" defined to avoid confusion and ambiguity.

research is relevant and appropriate to ensure robustness.

and alternative provisions if there are no suitable alternative relocation sites on or off site.

applied when there are effective alternative modes of public transport in place and these are fully operational. If alternatives are not available, it will deter

occupiers and damage viability frustrating development.

Ref Plan Ref Comment Summary Last Modified/Officer

qualification, such as to seek to or endeavour to where viable, feasible and practical.

suggest that these could form part of the guidance and include the following possible headings:

Phil Edwards

Riverside area.

SecondSite also supports the principle of mixed use development in the Western Riverside area and the provision for significant residential development, in

association with other commercial uses, in accordance with current national and regional government guidance.

SecondSite made representations on the Regeneration Framework Document Consultation Draft December 2001 (RFD) which is referred to in the Draft SPG.

2.1.3 in the Draft SPG indicates that the RFD has been adopted as the information base upon which the Draft SPG has been prepared.

It is not fully clear to what extent the issues raised in these representations have been incorporated into the Draft SPG. Certainly some of the key suggestions

made in SecondSites representations do not appear to have not been incorporated in the way in which B&NES's have sought to develop planning policy for the

site.

In particular paragraphs 7 to 8 of SecondSites representations on the RFD request that SPG is not adopted for the site until viability of the proposed

development can be assessed and assured. To do this it is necessary to understand both the proposed scale and mix of uses for the site and the nature (and

potential cost) of an "Integrated public transport system" for the site.

Specific to SecondSite, there are certain criteria which must be satisfied before SecondSite are able to justify to their shareholders that their site should be

brought forward for redevelopment:

(i) It must be financially viable for Transco to relocate the gas mains and decomission the holders from the site; and

(ii) There must be sufficient gas storage available elsewhere in the national network to accommodate the relocated facility.

When considering the site-specific characteristics of SecondSite's landholding, there are a number of factors that will impact on the viability of a

redevelopment proposal. Given the sites' operational nature, the land is contaminated and will require remediation.

Certain land-use proposals within the Draft SPG will also impact on the viability of the overall development.

the co-operation of the private and public sector if B&NES had consulted SecondSite and the Western Riverside Major Landowners Group (WRMLG) in the

process of developing planning policy for their sites. In addition, B&NES has selected a master developer without consultation or the involvement of

SecondSite or WRMLG. The need for a comprehensive and integrated approach to the development of the Western Riverside area is acknowledged. However, it

is not necessary to have a single developer and a single application in order to facilitate such development.

The complex nature of the Brief area should not be overlooked. A significant proportion of the land in question is currently in operational gas or water utility use.

There are no fixed timescales for the termination of either of these uses. It is unrealistic therefore to expect all of the land to come forward for redevelopment in

one tranche. In this way, it is important to ensure that any development within the SPG area does not prejudice the wider planning aims of the brief but this

does not require that the entirety of the Brief area should be developed at once.

Nothing within the SPG policy for the site should seek to restrict the various development procurement options available for Western Riverside.

A5o 6 With reference to Section 6 of the Draft SPG, as previously stated, SecondSite acknowledges the need for comprehensive mixed-use development in land use 27-May-03 16:41

A6n 6.1 SecondSite is of the view that the size and delineation of the development area is somewhat aspirational and includes limited consideration of the 27-May-03 16:40

A7s 6.2.1 As stated earlier, SecondSite are supportive of the aspiration for a predominantly residential scheme, however, given the size of the area of land identified for 27-May-03 16:38

A8o 6.2.3 30% Affordable Homes - Policy GDS.1 B3 re-iterates that B&NES Draft Local Plan Policy on affordable housing will apply to the site. In particular that 30% 27-May-03 16:32

A9o 6.3 Commercial development (Use Class B1) - SecondSite are concerned about the viability of "significant provision for business development (Use Class B1)" as 27-May-03 16:26

A10o 7 SecondSite is aware that WSP are carrying out an investigation and preparing a report on an "integrated public transport system". However, until this work has 27-May-03 16:24

A11n 7.2 When considering the issue of Public Transportation, SecondSite trust that B&NES and WSP are considering many different options/forms of transport system 27-May-03 16:22

A12o 7.2.1 Section 7.2 addresses Integrated Transportation. It is stated in paragraph 7.2.1 that "in order to maximise the development of the site it will be necessary that 27-May-03 16:22

Ref Plan Ref Comment Summary Last Modified/Officer

Park and Ride facility within the Western Riverside regeneration area.

If the section is referring to Park and Ride facilities outside Bath City Centre, SecondSite question the need for the development to pay for improvements to

facilities which are so far removed from the site.

commercial uses is not addressed.

SecondSite question the need for B&NES to be prescriptive on parking standards at this stage, especially a provision of less than 1 space per unit.

It has not been established how the development will be served in terms of transport infrastructure. The suggestion of a reduced parking provision implies that

a major public transport system will be implemented. In addition, until detailed scheme designs have been produced, it is not clear how much parking could be

accommodated in a viable configuration. SecondSite suggest either the SPG is not prescriptive, or that it provides for "up to 1 space per residential dwelling".

necessary to support the development of the Western Riverside. The Supplementary Planning Guidance does not state whether these improvements will be

required on the A4 (T) or not. However, we conclude that it would seem possible that the improvement programme will incorporate junctions on the A4(T).

Considering the scale of the proposed development, we believe the impact on the A4(T) is likely to be significant. Therefore we would wish to seek continued

consultation from B&NES at all stages of this proposal so that informed decisions can be made regarding the potential traffic generation, as the details

become apparent.

Rae Harris

oppurtunities and other commercial uses. The scope to improve accessibility to and through the site and to provide improved community facilities are

supported in principle, provided it is necessary, directly related to the development and reasonable in all other respects.

adopted development plan. PPG 12 confirms that only policies of the adopted developemnt plan will have the status that Section 54a of the 1990 Act provides

and the SPG will only be a material consideration. It is also clearly stated that SPG should not be used to avoid subjecting to public scrutiny, in accordance

with the statutory procedures, policies and proposals which should be included in the development plan. The development plan process would include full

public consultation and a local plan inquiry.

In this case, the draft SPG seeks to supplement a general/non-site specific policy of the adopted Joint Replacement Structure Plan (Policy 6) and Policy

GDS.1 of the emerging Bath and North East Somerset Local Plan is not expected to be placed on deposit until Autumn 2003 at the earliest and a local plan

inquiry would not take place before Summer 2004. We would expect formal adoption in Spring 2005.

The adoption of SPG for Western Riverside in advance of formal adoption of the Bath and North East Somerset Local Plan would be premature and fail to

satisfy the circumstances set out in PPG 12.

Furthermore, it is clear that fundamental issues which will determine the content and approach of the SPG have not been addressed at this stage. This

includes, for example, a Masterplan, transportation study, and environmental assessment. To progress SPG in advance of these studies reinforces the

prematurity of the SPG. The SPG would also form an inadequate basis for compulsory purchase having regards to Circular 02/03, Appendix A, paragraphs 15-

A3n 6 The extent of site specific requirements. The scope for and the level of contribution which the regeneration of Western Riverside can contribute to the delivery 20-May-03 16:58

A4s 6.1.1 The SPG considers that only a comprehensive approach in accordance with an overall master plan will secure the regeneration of Western Riverside. We 21-May-03 16:20

A5o 6.4.1 The Deposit Draft Local Plan confirms a need for circa 12,000 sqm of additional bulky goods retail floorspace in the period 2001-2006. It would not be 21-May-03 16:18

A6o 6.3 The range and scale of alternative uses identified for the site. For example, the viability and demand for a "significant provision for business development" is 21-May-03 09:44

A7o 6.7 Notwithstanding, BLCT (11680) Ltd considers that there are no grounds to justify the displacement of the Homebase store: 21-May-03 09:51

A8o 6.7.1 The oppurtunity to identify key uses and developments to be retained should be fully explored as part of the SPG process and not deferred to a later stage. It is 21-May-03 16:10

Ref Plan Ref Comment Summary Last Modified/Officer

Newbridge Road. That ought to help relieve pressure of demand for plots at lower common particularly.

My observations are as follows:

Presumably the Rapid Transport System will link up the proposed route to Bristol

blocks and with external vehicle access.

Principal vehicle routes could form vistas along the lines of Great Pultney Street with public buildings forming the end view.

blocks and with external vehicle access.

Principal vehicle routes could form vistas along the lines of Great Pultney Street with public buildings forming the end view.

clearly marked and shaded.

Ref Plan Ref Comment Summary Last Modified/Officer

linked to public transport well

the longest "brownfield" sites in B&NES there should be a much higher percentage of affordable housing in the development 'mix' A figure of at least 60%

affordable housing should be allocated.

meet all the criteria in Policy GDS A + B:

Public transport on Bath Road.

Safe access from Manor Road.

Pedestrian, cycle and vehicle routes all nearby + in a ? Environments.

Field surrounded on the sides by housing and golf course.

Schools within walking distance (both primary and secondary) - route to secondary used daily along lanes.

Play area opposite.

Community centre and sports field in village and within walking as are shops and small supermarket.

Apparently the site was ear-marked for the secondary school in the 1960s (later built in Keynsham) come on B&NES lets have some housing on an

enironmentally suitable site.

Please use our correct address which is:-

42 Courtenay Road,

Keynsham,

Bristol,

BS31 1XW

Babette Martini

of over 200 artists members from the area, working in a wide range of media. As the principal artists' network for the area, BANA would wish to stay actively

involved with the development of any Public Arts Projects that form part of the Western Riverside Regeneration Plans.

Adrian Tuddenham

the underlying transport infrastructure, those decisions become mere speculation.

The entire transport section (7) is vague, unfocussed and inconclusive. It gives no clear indication of what is proposed or how it will achieve the desiderata of

the rest of the SPG.

If there is an intention to install a tramway network in Bath, this SPG should have contained a clear statement of that fact - as it did not, we raise the following

Ref Plan Ref Comment Summary Last Modified/Officer

A corridor between Newbridge P+R and W Riverside will have no significant benefical effect on the development potential of the site because it does not

connect to the rest of Bath or beyond. This single dedicated corridor link will merely transfer the access and parking problems of W Riverside to Newbridge,

generating large traffic flows along and across already congested routes such as the Lower and Upper Bristol Roads. P+R sites should not be used as out-of-

town residential parking.

At all the public consultation meetings, a 'Rapid Transit' rooute running along the former Midland Railway alignment to Newbridge P+R was shown on the maps

prepared by B&NES council. Despite almost universal condemnation of this corridor alignment at consultation meetings and the clear identification of a need

for an integrated public transport network to serve the site from the whole of Bath, this single corridor alignment continued to appear on B&NES plans.

The single corridor continues to be referred to in Paragraph 7.2.1. The alignment for it appears on the western edge of the map on Page 10 of the SPG.

On 7th July 2001, B&NES funding was allocated for a Mass Transit/Tram Network Study, (Appendix A) specifically related to the development of the W

Riverside and Southgate, to be completed no later than January 2002. That study has not been undertaken and the SPG has failed to mention that the need for

it had been clearly identified at both council and public meetings.

is planned.

meaningfully considered. Transport was then removed from the agenda of all further public consultation meetings on the grounds that it was so important that it

needed separate discussion. No discussion or public consultations on transport were ever held.

it as clear as possible so that it can be relied upon to deliver a comprehensive, exemplar development on the BWR site.

the policy hierarchy, but we feel that the document does not adequately explain the full extent of the policy history and hierarchy from which the SPG has

emerged and its logical relationship with that policy framework

The SPG does not set out the justification for the Council's decision to apply emerging policy and issue the SPG at this stage. The inclusion of an outline of

the reasoning behind that decision will, in our view, help to ensure that there is no misunderstanding about the policy position and the relationship of the SPG

to that policy background.

That reasoning needs to explain that much of the BWR site is employment land and is protected for employment uses in the Adopted Local Plan and, subject

to qualifications, in the Adopted Structure Plan ("JRSP"). The JRSP and the emerging draft Local Plan now recognise the potential for a comprehensive mixed

use development of the whole area to achieve a wider range of employment opportunities and overall benefits for the community.The SPG should go on to

explain the need for high quality employment generating-development on BWR with good local facilities and the critical mass to make it viable. This can be

done appropriately with a wider mix of uses which would also contribute to quality and viability. The right balance in overall mix, location, quantum, proportions

relocation and supporting infrastructure demands a comprehensive approach to delivery.

This justification has its roots in JRSP policies 6 and 30, the accompanying JRSP explanatory text, especially paragraph 2.57, Regional Planning Guidance,

the emerging policy (particularly B1 of GDS.1 ©), together with the latest Government Guidance. In Section 2 of the SPG, the relationship of the SPG with that

policy and the Adopted Local Plan needs to be set out fully. Reference should be made to RPG (particularly paragraphs 3.25 and 3.26 which stresses the need

to optimise the opportunity), and specifically to SS9.

With regard to Local Plan policies, whilst the SPG clearly relates to the emerging policy, there is plenty of support for BWR objectives in the Adopted Local

Plan. See, for example, Policies C2 to C20 (listed buildings, conservation areas and the need for quality), policy T10 (riparian development), T1 (safeguards on

A3n 2.2.3 On the emerging policy GDS.1, the text used in the consultation document is confusing in terms of its source and status. We suggest that the latest wording is 16-May-03 15:35

A4n 6.2 At paragraph 6.2 of the SPG ("Accommodation") reference to JRSP policies 33 and 35 could be made. 16-May-03 15:33

A5n 1.1 As a general point, whilst some reference is made in the text to BWR in its context as a new part of the City, its key role in providing the opportunity for 16-May-03 15:32

A6n 1.3 The role of masterplanning should be explained by emphasising the essential need for a master planning process to be followed in preparing any development 14-May-03 17:01

A7n 1.3.2 In terms of the elements of the master planning process listed in paragraph 1.3.2 of SPG we would add the identification of the overall mix of uses within BWR 14-May-03 16:56

A8n 6.1 Whilst the SPG emphasises the need for comprehensive development, the justification for that approach is not made sufficiently clear. The SPG should 14-May-03 16:52

A9n 6.1.1 This justification should be set out in full in the introductory paragraphs to include the points made at 6.1.1 together with references to the following:- 14-May-03 16:47

A10n 5 In Section 5, the principles of comprehensive development which we suggest are included in the introductory paragraphs should be set out again and 14-May-03 16:22

A11n 6.3 The general points regarding the need to justify the move from Adopted Plan policy E4 to the emerging policy are emphasised in our section 2. This transition 14-May-03 16:16

A12n 8.1.1 At 8.1.1, the seven Core Objectives of Urban Design could usefully be set out in full. The Council should consider where the Design Guidelines would be part 14-May-03 15:54

A13n 8.2 At paragraph 8.2.3, 8.2.4, 8.2.6 and 8.6.2 of the SPG the references to eaves heights, existing vistas, appropriate allocation of high densities and landmark 14-May-03 15:53

A14n 4 We suggest the addition of a topic - "Transportation" - at the end of Section 4 of the SPG. This should address the need for public transport solutions and new 14-May-03 15:51

A15n 7.1 It is important that the SPG emphasises the need, as part of the master planning process, to fix the route and nature of the public transport provision through 14-May-03 15:48

A16n 7.3 At paragraph 7.3 of the SPG, the relationship of the park and ride expansion to provision of the Rapid Transport Link should be emphasised. The SPG should 14-May-03 15:47

A17n 7.4.3 In paragraph 7.4.3 of the SPG the reference to parking standards confuses standards for residential and commercial development. Parking standards for 14-May-03 15:47

A18n 7.5 In paragraph 7.5 of the SPG, the need for a master planning approach to the provision of linkages needs to be emphasised. Whilst public, pedestrian and 14-May-03 15:46

A19o 9 In our view, this topic as currently addressed in Section 9 is misplaced and does not deal fully with sustainability issues. It should be relocated to the end of 14-May-03 15:44

A20n 2.1 There is an opportunity in the SPG to stress the provenance of these proposals by setting out the history of their development, through the Comprehensive 14-May-03 15:42

A21n 5.4 At paragraph 5.4 reference should be made to the need for a consultation strategy to be part of the master planning process so that applicants can 14-May-03 15:41

A22n 6.4 In Section 6.4, reference should be made to the need for new hotel accommodation to meet both an existing Citywide need and those of the new employment 14-May-03 15:40

A23n 6.5 In Section 6.5, the full range of possible community facilities should be listed to include 14-May-03 15:39

Ref Plan Ref Comment Summary Last Modified/Officer

In paragraph 6.5.2, specific requirements, other than the need for a two-form entry school, should be avoided in the SPG. Instead the emphasis should be on

explaining the need for further analysis, with the Education Authority, of the school needs generated by any development within BWR and in relation to the

existing educational infrastructure and noting that in an urban location such as BWR the need for an innovative but appropriate solution to meeting these

educational needs will need to ensure that the most effective and efficient use of land is achieved.

urban scheme.

masterplanning, if the Figure is to be retained we suggest it moves to section 5.4 on Community Involvement.

In Section 3, the Council should consider describing the areas around BWR and the relationship between them, the need for linkages and the Council's views

on development control for those areas (notably in respect of Policies E1 and E4/JRSP 30).

of the development. Also, the SPG should state that the Council has already resolved to use compulsory purchase powers.

but not 3.

Simon Ridd

over and above the provision of public open space including playing pitches.

It is important that whatever sport and recreation facilities are to be provided by the developers, they are implemented alongside the housing development as

part of a legal agreement.

Sport and recreation facilities should be located in line with sustainable development principles including provision in accesible locations to serve all sectors

of the new community, workers and visitors.

Playing fields should be in the ownership of group or body that will guarantee community use in perpetuity. All the playing fields should be laid out for a number

of winter and summer sports, depending upon local demand, with suitable drainage systems and served by well-designed changing facilities.

provision may include a community hall that is suitable for indoor sport. A financial contribution should be sought for a sports hall and swimming pool provision

Ref Plan Ref Comment Summary Last Modified/Officer

Nigel Whitehead

justification is debatable and omits to acknowledge the outstanding land control issues associated with individual ownerships. Given that there are also

operational sites within the currently defined area, which have no alternative plans for relocation, these parties have understandably not expressed a

willingness to commit to the vision. More importantly in these circumstances the justification for the exclusion of surrounding areas appears to be unfounded.

specific areas from the WRA the importance of linkages between these areas is omitted. There is a requirement to consider the promotion of mixed use

development through complementary land allocations over a wider urban area. Current designation fails to acknowledge the oppurtunities for urban

consolidation in the immediate area with suitable scale and massing of buildings to create attractive setback frontages. These oppurtunities are paramount as

they include major oppurtunities for future employment development.

need to review the precise boundaries of the Western Riverside area. The SPG is formulated on the basis of a false distinction between the Western Riverside

Area and surrounding areas of existing or vacant employment sites.

Focus should be placed on the future oppurtunities for seeking to establish synergy between component land uses in line with the government's general thrust

toward sustainability. In this regard the wording of the SPG should better reflect the key themes which underpin the Governments approach to the planning

system - the creation and safeguarding of mixed use environments over a wider urban area. As stated in the supporting text to the emerging Plan, this is one of

the three Government themes (the others being sustainability and design) underpinning their approach to the planning system.

regard the provision of key community infrastructure on such an important area in Bath is an essential prerequisite.

the context of on-going employment studies. The current section does not provide a clear basis for decision making.

point to further studies. Proper consideration should be given to the consideration of retail demand, sequential alternatives and the potential impact upon the

centre and surrounding areas in the context of PPG6. The current section does not provide a clear basis for decision making.

land use policies would foster a more sustainable pattern of development to provide a clear basis for decision making. In doing so the SPG can be more

responsive and flexible to the changing needs and requirements of this area. This would be in more direct conformity with all tiers of planning policy including

PPG1, PPG3, PPG4, PPG6 and RPG10.

Western Riverside site are implemented. The words 'prior to' should appear at relevant points in the text of related sections. Without such sequencing the

proposals will have significant adverse effects upon the surrounding area.

on such a multi-million pound project should be directed at specific community vision for the core areas. Proper public consultation should occur to identify

and select preferred innovative approaches and techniques to achieve high-quality and imaginative planning solutions in this area. Without such an approach

the SPG inhibits the achievement of urban regeneration objectives and wider community benefits which in themselves would be discounted.

Additional emphasis needs to be placed on the achievement of specific urban design objectives for the area (character, connecivity, quality of the public realm,

adaptability and diversity etc...) This would in turn provide a clear basis for decision making..

Ref Plan Ref Comment Summary Last Modified/Officer

Chris Mackenzie

the likelihood that opportunities to fulfill these principles will be missed. This document represents a critical stage in enabling the objectives to be fulfilled.

The SPG contents will affect the "value" of the land and the level of quality and innovation in design.

We believe that the comments (changes) we have made reinforce the principles of the draft SPG, and that changes can be made to the sections that we have

highlighted in order to clarify these issues.

particularly ambitious by the developers. The Vision Statement refers to reinforcing the World Heritage Status of the City, but does not set a clear and

unambiguous challenge to the developers to, for example, ensure that this redevelopment will be in the future as important as the Georgian Centre of Bath from

the point of view of Urban Design and Architecture. We believe this is a realistic challenge, and, unless this ambition is made clear from the outset we know

that commercial pressures will conspire against this happening. The overwhelming concern of this generation is to do with sustainability, so we would

suggest that the Planning Guidance demands a development which demonstrates the latest and most advanced ideas in the field of sustainable design so

that Bath will become a model city for others to learn from around the world. This would indeed reinforce the World Heritage Status.

as something to be addressed after the other decisions are made. Section 8 of the document is in effect making innovation a requirement, but it does not have

the prominence in the document to make it happen at the stage where it will have the most influence. We would strongly recommend that this section is given

greater prominence in the document, either by putting it at the beginning and making clear that all other sections have to be read in the light of this section, or,

to put cross references in the other sections so that it's emphasis is properly reinforced.

We believe that the design quality and innovation has to begin with the masterplanning and land use allocation. Unless this is done the masterplanning (as

demonstrated by the "illustrative masterplan") will simply be an exercise in development plot packaging, with little or no real mixed use. It should be made clear

that "standardized" solutions ( EG bulk retailing sheds / HQ office buildings, car showrooms etc) will not be accepted as suitable solutions in this

development. Unless this is stated at this stage, then standard solutions will be adopted, due simply to the risk - averse nature of the development business.

This document provides the only opportunity that there is to influence the value of the land, which will in turn affect the willingness of the developer to innovate.

When it comes to actually delivering quality, it is a very difficult thing to achieve, unless there is a clear strategy from the start: The document does not define

a clear strategy, and would rely on the commercial judgement of the developers, followed by negotiations with Planning Officers. This could never be seen as

a process likely to achieve outstanding results. We would suggest that it should be stated that the design should come about as a result of a brief drawn up

with the assistance of CABE, and high profile design competition. Following that, the process should be repeated to arrive at the detailed designs for different

aspects of the development. The whole thing should be overseen by a recognized "Design Champion".

for example no mention is made of other relevant documents, such as CABE's "Better Places to Live" CABE / EH's "Building ion Historic Contexts" and

ODPM's "Sustainable Communities Plan". Other relevant standards include PPG 3 and building / construction standards like BRE's "Eco - home rating"

scheme.

This development will be active for a number of years, and undoubtedly these references will be updated and added to, reflecting new standards as they

emerge. We would suggest that a general requirement is made for the developments to demonstrate the highest standards when measured against the relevant

approach is that it gives the opportunity to achieve more in terms of the long term sustainability of the development and Bath as a whole than would be the case

if the site were developed piecemeal by various different landowners / developers. The mix and distribution of land uses on the site can achieve a better

overall balance, without simply letting the market decide the highest ( probably short term) return and lowest risk investment for each part of the site - this would

result in complete absence of innovation, with little cohesion or quality in the public realm. We believe that comprehensive development is also likely to

produce a better return for the developers, but they do need to have a long term commitment to the project.

building types within the development. EG cultural buildings, (a home for the Bath Festival / conference venue) sports buildings (Bath Rugby / swimming pool),

but there is no mention of these in the draft document, other than facilities related directly to the new Western Riverside Community. If there is an objective to

accommodate any of these in Bath, and this site offers a possibility of doing so, then they must be identified as a requirement at this stage. It will be too late if

this is left until the Environmental Appraisal stage as it will affect land values which otherwise will be assumed on the basis of the most commercially

attractive / lowest commercial risk building types. Other uses such as hotels and leisure uses etc are left entirely at the discretion of commercial decision

making. Surely research into Bath's needs and desires should be done at this stage and included as requirements, so that work can begin on identifying

funding opportunities and strategies. EG Planning Gain, Heritage Lottery, commercial etc.

Ref Plan Ref Comment Summary Last Modified/Officer

being decommissioned / removed) Paragraph 6.7.1 requires the Environmental Appraisal to address the displacement of this existing use. It is our view that

the assumption that this use will be removed cannot be made unless / until a better location is identified and has the necessary permissions to move. Clearly

the re - siting of this land use will be controversial, and as a principle of sustainable development, Waste Management is an essential component. There is,

we believe a possible opportunity being ignored, namely that, as a model of Sustainable Development, this land use could be incorporated within the

masterplan area. Undoubtedly it would be a design challenge, but it would not be impossible. It could be a feature of the design innovation that is called for in

section 8 of the draft SPG, and possibly incorporated with other innovative solutions to issues such as water management and energy efficiency. This issue

should be seen in the context of the Council's other policy commitments to recycling waste, and the "problem" of this land use should not be turned into a

needs to be more clearly defined - Paragraph 8.8.1 (Diversity) is fairly clear, but is undermined by Paragraph 6.3.2 which describes different types of

commercial employment accommodation: The description of "Premium Offices" and "Modern Offices" could lead the reader to believe that these were intended

to be single uses for particular plots. Section 8 of the SPG does contradict this possible interpretation, but we feel that P6.3.2 should be amended to include a

specific reference to section 8 so that there can be no misunderstanding. We believe that it is essential from the urban design point of view to include other

uses at ground (street) level in this type of building, and not just a token corner shop. This makes a fundamental difference between an "urban" scheme and a

"suburban" scheme which could potentially become an area of single land use within the masterplan ( as demonstrated by the "illustrative masterplan") which

would be extremely damaging to the overall principles. There is a clear opportunity to include, for example, bulky goods retail on the ground floor of buildings

facing busy traffic routes, with office ( or other) uses above. This is a common situation in densely built up areas). There are also many examples of premium

offices with high quality retail / leisure uses on the ground level facing into high quality public spaces or streets. Innovation in design should certainly start

with the principles of land use and mix of uses. The result of this type of "first principles" thinking should result in more flexible building types (more

sustainable in the long term) which is of course in the interests of a developer / landowner with a long term interest in the site. It could also result in higher

densities being achieved over some parts of the site, which will give more opportunity for public space, privacy for housing, ecological interests etc in other

parts of the site. There should be no opportunity in this development for single use corporate HQ sites, or single storey retail sheds.

Stuart Burroughs

Brian Thomas

major development zone close to the City Centre and it is therefore essential to integrate the City with urban development. We regard a mixed use including the

mix of employment, culture and leisure as of paramount importance providing the possibility of strategic partnership links particularly with a cultural focus.

The high cost of housing is of concern to the University with regard to attracting and retaining high quality staff, postgraduate and mature students. The

inclusion of a high number of smaller units would be of major benefit. The possibility of improving transport links into the City from Oldfield Park and the

refurbishment of the railway station would be particularly welcome.

Jon Mason

Ref Plan Ref Comment Summary Last Modified/Officer

Henrietta Sherwin

the people of B&NES to live work and play. The focus on tourism requires less resourceful imaginative thinking and is an easier option than planning for real

jobs for real people.

Similarly shopping. We believe that Bath has more shops per capita than comparable towns and cities. In recent years the individual nature of Bath shopping

has disappeared and has been replaced by the bland universal multi chains who will move at the drop of a hat should their returns decline by a fraction. (E.G.

John Lewis leaving the centre of Bristol for Cribbs Causeway). Western Riverside (WR) should have shopping but shopping which is varied, whose owners are

commited to Bath and it's people and so provide a wide spectrum of goods. Small shopkeepers who are close to their clientele best achieve this. Thus the

plan should limit the size of shop premises and ensure that living accomodation is provided with all if not most of these shops. We believe that such a varied

scenario will generate considerable volumes of business to the benefit of local residents. Examples of what can be achieved are Covent Garden and the

original redeveloped Lanes at Brighton.

It seems that the intention is to create large office areas for major companies. Such planning does, like tourism (above) seem to require less intellectual rigour

than more creative plans. Currently there are many vacant offices in Bath. Where is the reasoning to suggest that this small office market is likely to change? It

is our view that the plan could encourage and foster smaller employers because they are less likely to vacate sites and even if one did, only a small percentage

This is a worthy objective but the method of how this is achieved is unanswered. We strongly believe that such housing should not be segregated but

thoroughly mixed with other, more expensive properties. This is the traditional pattern of many towns and cities. As an example look at West Kensington where

£1,000,000 houses abut (literally) council houses and flats to everyone's benefit. Such a mixture creates a community. We take this oppurtunity to state that

what is required on WR is the generation of a community, not x units of housing, y square feet of retail and commercial property.

Again we see the stress upon business development without qualification. We suggest that such wording will enable a developer to erect office blocks, which

are out of character for Bath and would generate subsequent problems such as a significant increase in traffic. Surely the real solution is to foster employment

on the site for those that live on the site in a variety of employment creating a varied street scene for local pride.

We are concerned that no overall figure for housing density is given. Assuming a total area of 40 hectares the figure of 900 dwellings produces a density of only

22.5 dwellings per hectare which is below the norm as stated in the current draft local plan and below the government's guidelines and well under the

traditional density of Bath. The CABE document 'By Design - Bettter Places To Live - A companion guide to PPG3' includes developments such as Websters

Yard in Kendal where new build had a density of 177 dwellings per hectare. It is not suggested that WR should be at such a density but it is clear that a density

of 90/100 dwellings per hectare up to 4000 dwellings could be accomodated. (It should be noted that Landscape estates propose 900 dwellings on their one

third of the whole site. This proposal also includes extensive office and retail premises).

The figure of approx. 4000 houses which more in execution would probably be more like 3000 exceeds the entire housing provision contained in the current

draft local plan. Again we urge imagination in terms of housing, to create a real community that will have a significant impact upon the whole of BANES. If

2/3000 dwellings are built on WR not only are green fields saved but there is little or no increase in traffic because the residents would either walk to work or

travel on a mass transit system (trams) to the outer limits of Bath and as far as Bristol.

Why relocate the refuse site? In Wandsworth the recycling depot is adjacent to developments where apartments sell (rapidly) for about £1,000,000 plus. Why

should Bath be different? The refuse site is across the river away from the main area and moving it will generate more traffic and it will be either located within

the urban fabric or on green fields. Either option will most generate vigorous and determined protests, which could lead to a public inquiry delaying, the whole

process and increasing costs.

conservation significance thus must come from the vegetation that has grown on neglected sites. Much of this will go with the development. We are for

conservation but feel that measure such as creating grassy banks and vegetation leading down to the water will result in a greater chance of flooding and more

areas for rubbish and similar to accumulate.

A6o 6.2 Again only at least 900 dwellings are mentioned. The danger is that such suggestions become taken as actual. We strongly urge you to change this wording to 27-May-03 14:09

A7o 6.3 We have already commented upon the problems created and the undesirability of large office blocks. Corporate occupiers have an immediate attractiveness 27-May-03 14:08

A8o 6.4 We are encouraged by the first sentence of 6.4.1 but are alarmed by other parts of this sentence. Again the focus seems to be on expanding the already 27-May-03 14:04

A9o 7.1.2 No details are provided but reference to the plans that the council produced in late 2001/2002 clearly showed that the type of transport envisaged was bus. The 27-May-03 14:03

A10o 7.3 We are utterly against a significant investment in park and ride. Our objection is based upon two main criteria: 27-May-03 14:01

A11o 8 The oppurtunity is that WR becomes an examplar for the 21st century and we agree that it should be distinctive and coherant and not a mishmash of vogue 27-May-03 13:58

A12o 8.2.3 We are in broad agreement with Para 8.2.3 but reserve our judgement for to achieve this, will require a clear and strong stand on part of the council (officers and 27-May-03 13:57

A13o 8.2.5 From all of the above it is obvious that we are in agreement with the principles contained within Para 8.2.5 but we remind you that the devil is in the details. 27-May-03 13:56

A14o SPG Western Riverside is very important; it is an oppurtunity for Bath to show that it can produce worthy, exciting and lasting development which adds significantly to 27-May-03 13:56

Ref Plan Ref Comment Summary Last Modified/Officer

We trust that the final version of the SPG foster and encourage excellent and creative design and planning which will result in a thriving, happy community

which is an examplar of the 21st century in which the people of Bath can take great pride and not be another mediocre development.

Carenza Ellery

give more priority to PTWS. Please provide please provide secure parking for PTWS at strategic points in the plans. Ensure PTWS are allowed to share any

new bus lanes. They can contribute to better air quality as they generally use less petrol and do not spend so much time taking over in ? Please ensure any

parking areas for motorcycles are free of charge.

A iv - good!

give more priority to PTWS. Please provide secure parking for PTWS at strategic points in the plans. Ensure PTWS are allowed to share any new bus lanes.

They can contribute to better air quality as they generally use less petrol and do not spend so much time taking over in ? Please ensure any parking areas for

motorcycles are free of charge.

Michael Buxton

PPG3 and the sequential test by identifying brownfield land for redevelopment.

Since the deposit draft local plan, the council have increased the number of new dwellings allocated in the plan period from 620 to 900.

We are concerned of the deliverability of 900 new dwellings allocated for development during the local plan period. Western Riverside is predominantly

brownfield and is subject to a variety of planning and building constraints. These include ;

· There is a need to produce a comprehensive development for the area which is fully integrated into the existing urban fabric. The Western Riverside area

comprises of a mixture of vacant and occupied land, nearly all of which is in private ownership. The site consists of large areas of the land still in use which

would create timely delays in bringing the overall site forward for development.

· The proposal includes redevelopment within a Conservation Area together with Listed Buildings and Buildings of Local Historic Interest. This will require the

implementation of a Masterplan which must be approved before full planning permission is granted.

· The Western Riverside has a medium to high contamination risk and will require a Remediation Plan forming part on of Environmental Assessment (EA)

which must be approved before development can commence. The EA will also address other issues which are identified in the SPG as potential development

constraints. These include ; flooding, air quality, landscape, noise and vibration, ecology, archaeology, geotechincal and hydrogeology.

· The site is located within an area of flood risk / flood plain and will require additional flood risk measures to be implemented as part of the overall

development.

· An Integrated Transport Strategy (ITS) will also be required as part of the overall Masterplan which again has to be approved before development can

commence.

The above building and planning constraints are likely to seriously delay or possibly prevent development from taking place. All of the constraints must be fully

considered in the production of an Environmental Statement.

If construction is delayed to 2008 this would result in only 300 dwellings being provided over the plan period. If construction commenced in 2006 this would

only allow a five year period of development to the end of the plan period. At a build rate of 100 dwellings a year, as a result of the above building constraints,

Ref Plan Ref Comment Summary Last Modified/Officer

Matthew Smith

The needs for sport, recreation, green space, and children's play areas appear adequately catered for by various references to existing policies etc. we would,

however, wish the following points be taken into consideration:

1) The close proximity of the development to Royal Victoria Park (RVP) and the play area in particular will increase use of this area (with over 900 new

dwellings). It is suggested that we need to ensure that mechanisms are in place to ensure that off site contributions from developers go towards ongoing

refurbishment of this play area (and RVP generally) as well as providing and maintaining appropriate new ones within the development.

2) No mention is made of the provision of allotments, which a development of this size will undoubtedly produce a demand for. The SPG states "Sustainable

Development" as one it's three overarching principles and the provision of local allotments will go some way to meeting the definition set out in paragraph 5.3.1.

The nearest existing allotments are situated at Lower Common (below RVP) and although it might appear there are a number of unused plots, they are all

tenanted and we have a waiting list. The nearest site that we have vacancies on is at Monksdale Road which is not within walking distance of Western

Riverside. We would therefore ask that provision of further allotment gardens either within or near to the development be considered.

raises more questions than answers.

The draft SPG introduces new uncertainties which will have a negative effect on the local economy and deter future investment by other existing landowners

and businesses.

A comprehensive approach is supported in principle but this approach should be aimed at facilitating regeneration by current business. The effect of this draft

SPG is to introduce greater uncertainty and the suggestion that existing businesses will not be protected and indeed may be restricted in their ability to

respond to the need of business growth and market changes. This uncertainty is likely to lead to a reluctance to invest in the area and to a rapid decline in the

physical environment as illustrated by existing redundant uses and vacant sites.

Investment decisions have already been taken on the basis of the previous regeneration framework report and draft Local Plan in site acquisition and

remediation works to facilitate the expansion of existing car showroom facilities within the site.

infrastructure including rapid transit system linking the site to Park & Ride facilities at Newbridge and the City Centre." Whilst Section 7 of the SPG reconfirms

the need for an integrated transport strategy and expansion of Park & Ride facilities, etc the land use implications for such provision is not recognised in the

recognised as an existing use in paragraph 3.1.2, it is not a use which is included in the description of types of employment accomodation which would be

provided in paragraph 6.3. This appears to demonstrate a change in policy from the previous document "Bath Western Riverside Consultation Draft

Regeneration Framework" December 2001 which clearly identified car showrooms as being appropriate use for inclusion in the future of the site. It also

conflicts with draft Local Plan policy GDS1C Site Specific Allocations and Requirements: B1 Western Riverside. This policy identifies the development

requirements in relation to this site including the iv "relocation of other uses including civic amenity site/refuse transfer station, sewage pumping and storage

facility, gas storage facilities." Car showrooms are clearly a significant land use within the Lower Bristol Road area and there is no indication in this policy that

that the bus services are provided to the same or better frequency" and "in order to maximise the development potential of the site, it will be necessary that a

multi-modal integrated transportation system is developed and implemented to serve Bath Western Riverside, running between Newbury Park & Ride and other

related areas." The land use requirement of Park & Ride and the transport system are not reflected in this document.

Ref Plan Ref Comment Summary Last Modified/Officer

stadium, given appropriate design, could also provide a concert or conference venue, it is necessary to add it as a separate item to the list of examples of

components of the mix of uses. The potential of the stadium to keep the area alive at weekends is obvious; the impact of freeing-up the Recreation ground and

the City centre are beneficial knock-on effects which should be taken account of in the overall Planning context.

the city centre, and where flats are common. Amenity space, yes - gardens, no.

workforce. Such offices will be a magnet attracting workers from Bristol, Swindon and beyond. This is inconsistent with a stance minimising parking places.

walking distance of every new home. A better justification, however, would be one of social cohesion and mixing. There is no justification for special provision

of indoor sporting facilities - this would compete with the Sports Centre, which ought to remain in the Recreation ground unless, exceptionaly, it is combined

with what is much more needed - a stadium, on Western Riverside.

emerging Local Plan to provision of a stadium can only be met by building one at Western Riverside. Such a stadium should be explicitly included as an

element of the guidance. The excellent transport links at Western Riverside, combined with the pressing need to reduce the congestion in the City centre,

especially on Saturdays, make this possibilty almost a necessity.

there is a superfluity of free parking at those times. Re-use of office parking at those times must be encouraged within the Guidance. At the same time,

provision of only 0.7 spaces per dwelling is quite inadequate - even where there is good public transport, extensive employment and accessible park-and-ride

actually in the process of reducing stations and services.

can base its own plans for the future.

service businesses.

The company has occupied the premises on Lower Bristol Road in Bath for more than 100 years and has no immediate plans to relocate.

Whilst the SPG recognises the existence of this business, there is no guidance included as to what is intended for the property, the site or the business.

The lack of any clear proposals is particularly concerning as the preceding document, "Bath Western Riverside Consultation Draft Regeneration Framework

Report" published in December 2001, indicate that it was a site with potential for redevelopment for retail use. There was in that document specific reference to

its providing a site for relocation of Homebase, but even if this is no longer proposed, there may be other equally suitable retail needs (food and non-food)

which the site (a highly sustainable, ege-of-centre site on a main public transport route) would serve.

The company recognises that the current buildings do not provide the most efficient printing premises in which to meet future processing needs, but the

oppurtunities for relocation of this business as part of the regeneration of the Western Riverside, then it will be vital to ensure that it is secured by means of

generating sufficient value from its future use.

Ref Plan Ref Comment Summary Last Modified/Officer

may take. In the absence of any conclusions on this vital aspect of the plans for Western Riverside, the publication of the SPG is inevitably premature and its

contents therefore perhaps also inevitably vague.

Valerie Bearne

Ground Conditions: Self Builders are more adaptable to different forms of construction in order to accommodate ground conditions e.g. use of lightweight

construction techniques such as beco wallform, timber frames, use of mini piles.

recycling, using recycled materials, consideration of fuel miles in construction, low energy, non toxic paints etc.

purchasers who may never even speak to one another!

the aid of a Housing Association to fund the build costs whilst they learn new skills and achieve a good quality house which they will part own/part rent.

developer. Self builders with accumulated funds will be able to achieve a really exceptional quality of design and execution, and can be far more innovative

than any mass developer can afford to risk being.

P Burfoot

the school childrens' play areas and other community spaces be protected could these aspects be included please together with the principle of "designing out

PFG's it is felt that this is a subject of equal importance as noise and vibration/air quality etc.

Historic Buildings Team Manager: Jacky

or edge zone of influence. We should also then indicate the park and ride sites and the LRT routes as part of the wider "site" covered by the SPG. This gives us

a) flexibility to include/exclude sites around the site, and b) it gives a clear and honest picture of the implications at the edge of the city.

and b) could detract from the traditional role of the centre and clearly would not be serving just the local needs of the new population - sustainability???

I suggest that we don't say "city centre" as there are some unfortunate precedents in the centre. I suggest we say "eaves or parapet heights should be

compatible with the appropriate surrounding context which varies over the site".

Ref Plan Ref Comment Summary Last Modified/Officer

We also need to define somewhere in this chapter what we mean by Design Quality. How are we going to deal with the possibility that developers will want to

use historical styles for example?

Policy and Project Manager: Damien Wilson

owners of land adjacent to the site are looking to offload industrial land for mixed use residential and office. The most recent example being Herman Miller site

where we are aware that the owners are now touting this as an office/residential site, despite having 2 industrial users interested in the site. This kind of

speculation, if not restricted, could result in the loss of yet more industrial space, which will not be replaced by the developments on Western Riverside.

contained within. These will not create local employment, will not add any value to the economic base of the area and as history will show, will eventually just

become part of the house. Very difficult to monitor, enforce.

a less than significant development. It would be beneficial to have a hectareage or floorspace figure to work to.

Chairman: Peter Witty

bounded by the Newton Brook-Stony Lane and the railtrack?

B) This site was in the Green Belt but has been under threat of development since 1995 when a Rail Park and Ride arrangement was proposed. The Stohert

Sports Club still uses and maintains the facilities but now we are unsure of our future and would like to know if any of the land will be required due to the

Western Riverside development?

C) As the draft local plan has not yet been approved, uncertainty remains as this Supplementary Planning Guidance does not address the traffic (road)

arrangements for the additional Park and Ride requirement or the layout of the interchange of the new road and the A36/A4 junction.

Nicholas Stubbs

SPG (i.e decontamination, community facilities - especially a new primary school and playing field, flood control measures, re-siting of the gas and water

utilities) will require a high level of return on the income generating uses to make redevelopment viable.

New commercial space will be more attractive than the existing stock housed as it is within the Georgian heart of the city. Relocation of businesses to Western

Riverside will deprive the World Heritage Site of rents and repairs and will precipitate some areas into decline.

Ref Plan Ref Comment Summary Last Modified/Officer

The Strategic Joint Replacement Structure Plan Adopted 2002 Policy 6 states that provision will be made for employment was to meet local requirements. It is

not envisaged the Bath will attract inbound business or the infrastructure would require another level of investment.

This is a fine balance and I would not wish to oppose development per se.

Studies commissioned by the council have repeatedly demonstrated that high levels of public subsidy are necessary to construct and operate these facilities.

Bath already has a number of concert and conference venues - The Guildhall, The Assembly Rooms, The Forum and the loss of revenue would damage their

viability and vitality.

The investment would be better placed in supporting and enhancing these venues.

period.

It seems unnecessary to burden the Western Riverside development with this cost when there are sufficient local primary schools to meet the demand of 200

new houses.

The Bath Western Riverside Consultation Draft Regeneration Framework December 2001 indicated a possible route for a Light Rapid Transit System, Figure

7.7 et seq.

As owners of site 9 Riverside Business Park Bath we objected to that draft on the 28 February 2002, on the grounds that we have a valid planning context for

office s reference 00/01001/FUL granted 8 November 2000, and that site 9 is not available for use as a transport corridor.

For the Western Riverside development to be acceptable, as stated in the SPG Draft for consultation it will be necessary that a multi modal integrated

transportation system is developed and implemented to serve the development under PPG13 this system must connect the development with the City Centre.

document refers to providing a sustainable and integrated transport choice and Paragraph 7.2.1 indicates the necessity for a multi-modal integrated

transportation system running between Newbridge Park & Ride and "other related areas." If this transportation system involves a new rail or road link to the city

centre and if the route were to affect the currently vacant former petrol filling station on Midland Bridge Road then we would object to any consequent loss of

raises more questions than answers.

The draft SPG introduces new uncertainties which will have a negative effect on the local economy and deter future investment by other existing landowners

and businesses.

that the bus services are provided to the same or better frequency" and "in order to maximise the development potential of the site, it will be necessary that a

multi-modal integrated transportation system is developed and implemented to serve Bath Western Riverside, running between Newbury Park & Ride and other

related areas." The land use requirement of Park & Ride and the transport system are not reflected in this document.

Ref Plan Ref Comment Summary Last Modified/Officer

recognised as an existing use in paragraph 3.1.2, it is not a use which is included in the description of types of employment accomodation which would be

provided in paragraph 6.3. This appears to demonstrate a change in policy from the previous document "Bath Western Riverside Consultation Draft

Regeneration Framework" December 2001 which clearly identified car showrooms as being appropriate use for inclusion in the future of the site. It also

conflicts with draft Local Plan policy GDS1C Site Specific Allocations and Requirements: B1 Western Riverside. This policy identifies the development

requirements in relation to this site including the iv "relocation of other uses including civic amenity site/refuse transfer station, sewage pumping and storage

facility, gas storage facilities." Car showrooms are clearly a significant land use within the Lower Bristol Road area and there is no indication in this policy that

infrastructure including rapid transit system linking the site to Park & Ride facilities at Newbridge and the City Centre." Whilst Section 7 of the SPG reconfirms

the need for an integrated transport strategy and expansion of Park & Ride facilities, etc the land use implications for such provision is not recognised in the

Regeneration Officer: John Young

guidance such as the Local Plan and the Affordable Housing SPG and will depend on the latest Housing Needs Assessment.

"Detailed requirements for Affordable Housing can be found in the latest version of the Affordable Housing Supplementary Planning Guidance which should

also be referred to"

a unique strategic site such as this may be required to satisfy more than just local need and may also be subject to regional strategies.

Second sentence is too prescriptive on the type of affordable housing and "general needs" is not a good term for describing the residential units that are for

sale as it is used as a specific term by the Housing Corporation.

against certain types of resident such as tenants of affordable housing as the market housing will probably not sell without some parking. The other result may

be a spill over of parking into adjoining areas. Also the only figure quoted is a ratio of the residential element.This gives no guidance on the commercial

Ref Plan Ref Comment Summary Last Modified/Officer

General Manager and Secetary to the Trustees: Joy

following grounds:

a. Reference is made in the planning guidance to Bath as a World Heritage Site and the need for Western Riverside development to be built in sympathy with

this status (4.1.1, 5.2.1). Bath already has several conference/concert venues in listed buildings of great architectural importance, including the Guildhall,

Assembely Rooms and the Forum. The provision of a new conference facility would lead to a loss of revenue to these current facilities thus threatening their

viability.

B. The Forum has spare capacity above the existing needs of Bath City Church who use it as a meeting place.

C. The article about the proposed conference centre in the Bath Chronicle on Wed 7th May talked of an operational deficit of £1.7 million pounds. The

economic argument for the success of such a conference centre is unconvincing and the Council need to show that they have thoroughly tested the market for

a new conference venue. It would be better to use the money to develop a partnership between the existing conference/concert venues in the city to improve

provision of the necessary facilities, and to improve the lack of bed space by building a large hotel on the Western Riverside site.

D. Section 7 talks of sustainable and integrated transport. Whilst it is recognised that this is fundamental to the viability of Western Riverside it has to be

pointed out that the ease of accessibility of the city centre venues (Guildhall, Assembly Rooms and the Forum) means that people can walk to them from the

train and bus stations. The Avon Street and Ham Gardens car parks are particularly close to the Forum, which is also within walking distance of all the Park and

Ride stops - the Odd Down one being opposite the building. This would make the existing facilities sequentially preferable to a conference centre outside the

city centre.

E. The existing conference venues are in the historic heart of the city and thus draw more trade to existing businesses.

F. Bath City Church also have reservations about the Council being willing to stand such a large operational loss while managing shortages of finanace for

education and social services. There is also concern that this deficit wouold be raised from local council taxpayers, many of whom would see little or no

raises more questions than answers.

Investment decisions have already been taken on the basis of the previous regeneration framework report and draft Local Plan in site acquisition and

remediation works to facilitate the expansion of existing car showroom facilities within the site.

The draft SPG introduces new uncertainties which will have a negative effect on the local economy and deter future investment by other existing landowners

and businesses.

infrastructure including rapid transit system linking the site to Park & Ride facilities at Newbridge and the City Centre." Whilst Section 7 of the SPG reconfirms

the need for an integrated transport strategy and expansion of Park & Ride facilities, etc the land use implications for such provision is not recognised in the

recognised as an existing use in paragraph 3.1.2, it is not a use which is included in the description of types of employment accomodation which would be

provided in paragraph 6.3. This appears to demonstrate a change in policy from the previous document "Bath Western Riverside Consultation Draft

Regeneration Framework" December 2001 which clearly identified car showrooms as being appropriate use for inclusion in the future of the site. It also

conflicts with draft Local Plan policy GDS1C Site Specific Allocations and Requirements: B1 Western Riverside. This policy identifies the development

requirements in relation to this site including the iv "relocation of other uses including civic amenity site/refuse transfer station, sewage pumping and storage

facility, gas storage facilities." Car showrooms are clearly a significant land use within the Lower Bristol Road area and there is no indication in this policy that

that the bus services are provided to the same or better frequency" and "in order to maximise the development potential of the site, it will be necessary that a

multi-modal integrated transportation system is developed and implemented to serve Bath Western Riverside, running between Newbury Park & Ride and other

related areas." The land use requirement of Park & Ride and the transport system are not reflected in this document.

Ref Plan Ref Comment Summary Last Modified/Officer

the depth of the site is likely to render the businesses unviable. We would therefore wish to sustain objections previously made to plans which indicated a

potential rapid transport route running to the rear of the premises along the riveside.

This site is outside the defined area of the Supplementary Planning Guidance and therefore is not directly affected by these proposals. However Section 7 of

the document refers to providing a sustainable and integrated transport choice and Paragraph 7.2.1 indicates the necessity for a multi-modal integrated

transportation system running between Newbridge Park & Ride and "other related areas." If this transportation system involves a new rail or road link to the city

centre and if the route were to affect these properties then we would object to the consequent impact and seek compensation for loss of the businesses as

Chair of Governers: John Gamlin

and the proposed building of the new St John's 420 place primary school close by.

Failure to do this will add to the current over capacity at primary level in Bath, which is a new drain on the educational budget, and may jeopardise the future of

existing schools.

Perhaps the rationale would be to ear mark this new school in Western Riverside for St John's, giving them their new school, and reducing surplus places at

the same time.

Arthur Morris

encourage developers.

Ref Plan Ref Comment Summary Last Modified/Officer

development process.

David Moynihan

convenience goods).

It is important to ensure that both the emerging local plan and any SPG for the Western Riverside area conform with the sequential approach with regard to town

centre uses, particularly retail and leisure facilities, and that government policy is taken into account regarding both location and form of such developments.

Sites within the City Centre should be considered for all retail and leisure facilities before such development takes place at Western Riverside.

The role of retail warehouses is not as clear-cut as is suggested in both the Local Plan and the draft SPG. A significant amount of expenditure has been

identified as being available to support new retail warehouse development. There is clear potential for at least part of this expenditure to be accomodated in

shops in the City Centre able to sell a range of electricals, furnishings, recreational and other "bulky" goods. In short, BANES should encourage City Centre

developments to accommodate the expenditure that has traditionally been isolated for retail warehouses as far as is possible. This would add to the mix and

attraction of shopping in the City Centre. This approach must be taken in order to accord with the most recent Government guidance. (Lord Rooker Parliamentary

Answer 28 April 2003 - text appended hereto)

Any retail or leisure development must be required to demonstrate a specific need, including specific advantages to the public, of locating on a non-City Centre

site.

It is equally important to ensure that the vitality of Bath City Centre and its role within the heirarchy of centres in this area is maintained and enhanced.

Inclusion of retial and leisure attrations in the Western Riverside area could have a negative impact on Bath City Centre, the image of the City Centre and any

future development oppurtunities in the area.

The strategy for shopping and leisure in the Western Riverside area should attach greater weight to the need to sustain and enhance the City centre's regional

role.

Ref Plan Ref Comment Summary Last Modified/Officer

Paul Aldridge

bullet point three which concerns retail uses. As drafted the SPG refers to "local convinience and other retail". It is unclear what is meant by "other retail". This

should be clarified in the SPG. In particular, paragraph 6.4.1 makes reference to the emerging Local Plan and the need to provide for bulky goods retailing

within the City. However like paragraph 6.1.4 the SPG is unclear regarding the acceptability of the Western Riverside site to make provision for bulky goods retail

floorspace. The Bath and North East Somerset City and Town Centres Study prepared on behalf of the Council by Nathaniel Lichfield and Partners in July

2000 points to a strong quantitative need for bulky goods floorspace. That Study identified the Western Riverside area as the only potential site capable of

accommodating significant bulky goods floorspace. In particular that study identifies leakage of expenditure from the local area and a specific need for Western

Riverside to provide up to 12,000 m2 of bulky goods retail warehousing by 2006. Paragraph 12.28 of that Study states that "The failure to secure bulky goods

retail warehousing at Western Riverside within a reasonable timeframe will result in increased pressure for other out-of-centre retail development proposals on

windfall sites in Bath. It will also result in a continuation and possible increase in the level of expenditure leakage to retail warehouses in Bristol and western

Wiltshire." Naturally, we can understand that the Council is keen to exploit the site for high density uses and uses that make the best use of the riverside setting

however, equally there are other parts of the site that are better suited to other commercial uses for example bulky goods retailing particularly where the

provision of such uses are consistent with the aims and objectives of the policies of the emerging Local Plan. In this respect the site should provide some

retial warehouse floorspace. This is clearly more suited to locations away from the riverside for example along the Lower Bristol Road. In particular, we

consider that the Bath Press site, should it become available for redevelopment, would be entirely appropriate for a retail use. The site is self-contained and is

uniquely seperated from the main Western Riverside area by Lower Bristol Road. The use of this part of the site for retail could make a significant contribution,

say by providing in order of 8,000m2 of bulky goods floorspace, to meet a qualitative and growing quantitative need over the emerging Plan period.

bullet point three which concerns retail uses. As drafted the SPG refers to "local convenience and other retail". It is unclear what is meant by "other retail". This

should be clarified in the SPG. In particular, paragraph 6.4.1 makes reference to the emerging Local Plan and the need to provide for bulky goods retailing

within the City. However like paragraph 6.1.4 the SPG is unclear regarding the acceptability of the Western Riverside site to make provision for bulky goods retail

floorspace. The Bath and North East Somerset City and Town Centres Study prepared on behalf of the Council by Nathaniel Lichfield and Partners in July

2000 points to a strong quantitative need for bulky goods floorspace. That Study identified the Western Riverside area as the only potential site capable of

accommodating significant bulky goods floorspace. In particular that study identifies leakage of expenditure from the local area and a specific need for Western

Riverside to provide up to 12,000 m2 of bulky goods retail warehousing by 2006. Paragraph 12.28 of that Study states that "The failure to secure bulky goods

retail warehousing at Western Riverside within a reasonable timeframe will result in increased pressure for other out-of-centre retail development proposals on

windfall sites in Bath. It will also result in a continuation and possible increase in the level of expenditure leakage to retail warehouses in Bristol and western

Wiltshire." Naturally, we can understand that the Council is keen to exploit the site for high density uses and uses that make the best use of the riverside setting

however, equally there are other parts of the site that are better suited to other commercial uses for example bulky goods retailing particularly where the

provision of such uses are consistent with the aims and objectives of the policies of the emerging Local Plan. In this respect the site should provide some

retial warehouse floorspace. This is clearly more suited to locations away from the riverside for example along the Lower Bristol Road. In particular, we

consider that the Bath Press site, should it become available for redevelopment, would be entirely appropriate for a retail use. The site is self-contained and is

uniquely seperated from the main Western Riverside area by Lower Bristol Road. The use of this part of the site for retail could make a significant contribution,

say by providing in order of 8,000m2 of bulky goods floorspace, to meet a qualitative and growing quantitative need over the emerging Plan period.

Ref Plan Ref Comment Summary Last Modified/Officer

Management

taken into account as follows:

A) It is assumed that this level of parking will include any possible provision on the public maintainable access roads. To avoid obstruction problems will

these have 24 hour parking restrictions? If not, how will the public realm be designed to ensure that parking does not take place?

B) To prevent off site parking it is suggested that residents parking is introduced in adjoining areas. This will be the same scheme operated in other parts of

Bath and will involve payments by residents for permits. Are members happy to go wih a scheme that will result in adjoining residents paying for a permit or not

having the parking they now enjoy? Evidence from out previous work on these schemes suggest that this wil be a difficult process to manage and resolve.

C) Will all the site be carefully controlled to ensure that areas due to be developed later in the programme do not become temporary car parks.

D) The figure of 0.7 is leading to a very low traffic generation figure from the site. It will not be possible to change this figure in the future if the properties are

uncommercial due to lack of parking.

Transport

The development must demonstrate through assessments and monitoring that traffic generation is minimised. The provision of walking, cycling, public

transport and green travel plans to utilise them is critical.

The development will be required to show that there is not adverse affect on the network throughout the construction period.

"Providing a sustainable and integrate transport choice"

amend to

"Restricting car based infrastructure and providing a sustainable and integrated transport system".

And are not comprimised by the development

Has this been thought through from a transport side. If not it should be omitted.

Bullet point 7

Must ensure that a Riverside Boulevard is not the responsibility of this authority in the future. The costs associated with maintaining a river bank can be

A10o 6.4.1 Mix of pubs, bars and restaurants will be a traffic attractor - Is this desired? 19-May-03 16:50

A11n 6.5.2 Large school for site - refer here to green travel plan for school (children and staff and visitors). 19-May-03 16:50

A12o 6.6.1 Sounds very expensive. If the authority is not prepared to provide a significant revenue budget for this it has to be removed from the guidance. 19-May-03 16:50

A13o 7.2.1 Rewrite: 19-May-03 16:49

A14o 7.3.1 Is this site meant to expand and develop Odd Down, Lansdown and Lambridge. Rather than say same or better frequency say "increased capacity to 19-May-03 16:49

A15n 7.4.2 Add following commercial "residential and school" 19-May-03 16:48

A16n 7.4.3 Add resulting is no provision for residents to park cars within the site. 19-May-03 16:48

A17n 7.5 Access "and Egress" 19-May-03 16:48

A18o 7.5.1 First line after "to" insert "and from" 19-May-03 16:48

A19n 7.5.3 No objection to moorings and jetties subject to 19-May-03 16:48

A20n 7.5.2 Access during dark evenings needs to be covered. 19-May-03 16:47

A21o 8.2.2 Care needs to be taken to only include issues which the Council are committed to maintain. 19-May-03 16:47

A22n 8.5.1 Fifth line remove "not just". 19-May-03 16:47

A23s 8.7.1 Agree in principle but perhaps need to ensure that the lifetime changes will not act against the sustainable transport aspects of the development 19-May-03 16:46

A24n 8.8 24 hour usage - assume 24 hour public transport or greater parking provision. 19-May-03 16:46

A25o 9.2.1 This seems totally inappropriate for this site. It would be more appropriate to indicate that the site will require a comprehensive drainage system working in 19-May-03 16:46

A26o 9.3.1 Again appears inappropriate for this site. 19-May-03 16:45

A32o 5.3.1 Last sentence refers to the need to reduce travel by car, but does not continue to say and encourage other modes of travel to deliver the modal shift they are 19-May-03 16:41

Ref Plan Ref Comment Summary Last Modified/Officer

(this may be inappropriate for SPG) I suppose what I am getting at is that the development should be phased in such a way that the less attractive development

oppurtunities are not left to last and to deliver important aspects of the package, which may then never materialise.

on this issue. I.e. in order developers, business operators and the public who purchase dwellings are aware that they will have little opportunity to park vehicles

within the development. I am still concerned about the parking provision and the ability for problems to spread into other locations, no mechanism for non car

ownership is promoted.

consideration. I understand that the route is protected within the Draft Local Plan however this document is not adopted for Development Control purposes. The

SPG does not make reference to the route (as it will appear on the ground) it does however refer to a master plan to follow. I realise that the recently produced

WSP Draft Report on this particular issue has only just been submitted but it seems to me that the route ought to be included in the SPG in order to add some

clarity to the current unsatisfactory situation. This may help to add weight to the protection of the route while the local plan progresses towards adoption.

There needs to be another bullet point here which deals with egress as well as access and also nightime acitivities vis a vis lighting and timing of public

transport provision.

accommodate the run off from adoptable roads. Pleased to see recognition of poor soil conditions and the need for environmental appraisal of these issues.

emergency vehicles will all need to be accommodated within the development. Perhaps he means that it will be imperative that the roads giving acess in and

around the site are not capable of being cluttered by vehicles and that the emphasis for transport to and from the site should be an integrated one rather than a

relying on.

(possible implications re residents parking zones, nuisance etc)

(this may be inappropriate for SPG) I suppose what I am getting at is that the development should be phased in such a way that the less attractive development

oppurtunities are not left to last and to deliver important aspects of the package, which may then never materialise.

plan identify which uses are to go where, or this considered too prescriptive for SPG?

A14o 6.5.1 Accompany with, or be an integral part of the master plan, a pedestrian desire line plan (including cyclists) not confined to north and south either all origins and 22-May-03 11:16

A15o 6.5.2 School will need to be promoted with a Travel Plan and a co-ordinator (nominated officer) Need to build in from day one a culture which knows you should not 22-May-03 11:15

A16o 6.6.1 Implications for safety and future maintenance need to be considered. 22-May-03 11:15

A17o 6.7.1 The impact of the new uses in their respective locations will all need to be considered on their merits. 22-May-03 11:15

A18o 7.1.3 Can't we be a bit more specific here, or have we not got this far, it's loose but it doesn't rule anything out. 22-May-03 11:14

A19o 7.2.1 This section seems to concentrate on Newbridge but forgets about all of the other areas which may need consideration. Where are people coming from and 22-May-03 11:14

A20o 7.3.1 May need to identify new sites, increased frequency of services may be needed too. 22-May-03 11:14

A21o 7.4.3 Back to my first paragraph, be very very clear about this issue from the outset. Need clarity in what the SPG means when it says operational only. 22-May-03 11:13

A22o 7.5.1 Which junctions? What does it mean when it says main means of access will be via public transport if Rapid Transit say so, if referring to other services as 22-May-03 11:13

A23o 7.5.3 Recreational access only? 22-May-03 11:13

A24o 7.5.4 Does anyone know about any long term plans for the Rail Station? 20-May-03 10:29

A25n 8.2.2 Plural please routes not route 22-May-03 11:12

A26o 8.3.1 Add, but which also accomodates modern needs emergency and service access whilst not comprimising pedestrians and cyclists. 22-May-03 11:12

A27o 8.4.1 SLOAP is the subject of a forthcoming meeting between various parties "eventful experience" for peds and cyclists, I'm more concerned with secure, safe, and 20-May-03 10:32

A28o 8.5.1 Peter (Brook) has picked up on this already "not just traffic" this is JUST not necessary. 20-May-03 10:33

A29o 8.7.1 The implications of changing things later may have the ability to impact in traffic terms. 21-May-03 12:48

A30o 8.8.1 Public transport provision nees to reflect 24 hour usage i.e. 24 hour operation. 21-May-03 12:47

A31o GDS.1-C-vii Cars alongside the river not desirable but peds and cyclists might benefit from access depending on how desire lines pan out. 21-May-03 12:47

Ref Plan Ref Comment Summary Last Modified/Officer

and ped routes, existing as well as new are taken into account.

TAWM. Site may not be suitable in any event.

Homebase Group Ltd.

1) The approach the Council has adopted to progress SPG

2) The need to fully evaluate the deliverability of the proposals

3) The identified requirement for additional non food bulky goods retail development.

4) The need to set the development proposals for the site within national planning policy guidance, particularly PPG6 "Town Centres and Retail Development".

adopted development plan. PPG 12 confirms that only policies of the adopted development plan will have the status that Section 54a of the 1990 Act provides

and SPG will only be material consideration. It is also clearly stated that SPG should not be used to avoid subjecting to public scrutiny, in accordance with the

statutory procedures, policies and proposals which whould be included in the development plan. The plan process would include full public consultation and a

local plan inquiry.

In this case, the draft SPG seeks to supplement a general/non-site specific policy of the adopted Joint Replacement Structure Plan (Policy 6) and Policy

GDS.1 of the emerging Bath and North East Somerset Local Plan. The Revised Deposit Draft Local Plan is not expected to be placed on deposit until Autumn

2003 at the earliest and a local plan inquiry would not take place before Summer 2004. We would expect formal adoption in Spring 2005.

The adoption of SPG for Western Riverside in advance of formal adoption of the Bath and North East Somerset Local Plan would be premature and fail to

satisfy the circumstances set out in PPG 12.

Furthermore, it is clear that fundamental issues which will determine the content and approach of the SPG have not been addressed at this stage. This

includes, for example, a Masterplan, transportation study, and environmental assessment. To progress SPG in advance of these studies reinforces the

prematurity of the SPG. The SPG would also form as inadequate basis for compulsory purchase having regard to Circular 02/03, Appendix A, Paragraph 15-18.

of site specific requirements such as affordable housing, community facilities, an integrated transport system, park and ride, etc has not been fully assessed.

However, it is expected to deliver improvements/measures which are not necessary, relevant to planning, directly related to the proposed development and

reasonable in all other respects.

questioned. Conversely, the council has identified a need for significant additional bulky goods retial development within Bath over the Plan period, for which

there is likely to be strong occupier and investor interest. However, the SPG does not address the scope to accommodate bulky goods retail development in

unreasonable to assume a greater need over the whole Plan period (i.e. up to 2011). The emerging Local Plan acknowledges that there is limited choice of

bulky goods shopping in the District and no sites are identified for new development. The emerging Local Plan states that an option may be to identify land

within Western Riverside. This is noted in the draft SPG (para 6.4.1), but no provision is made for bulky goods retail, either the existing Homebase or additional

floorspace, within the Western Riverside area.

The Homebase store is the only large scale DIY/home improvement centre in Bath. The store meets an identified need for bulky goods retail and trades

successfully. Indeed, in performance terms the store sits within the upper quartile of the Homebase portfolio. The loss of the store or its relocation to a site or

development which fails to meet its operational standards will exacerbate the limited choice of bulky goods shopping in the District leading to significant trade

diversion and travel out of the District to Bristol and Wiltshire. This would not be sustainable and would not comply with national policy objectives (i.e. PPG 6

and PPG 13). Furthermore, it would increase the quantitative and qualitative need for bulky goods retail floorspace in the area, for which the Council accept

there is limited oppurtunity to meet.

Government policy adopts a sequential approach to retail development with first preference to town centres, followed by edge of centre and then out of centre

locations (i.e. PPG 6 and 13). It is accepted by the Council that given the restricted oppurtunities within the central shopping area, bulky goods provision would

best be made in an edge of centre or if no suitable sites are available an out of centre location (see para B5.39 of the Deposit Draft Local Plan).

Ref Plan Ref Comment Summary Last Modified/Officer

It is considered that the existing Homebase store occupies a location which meets the locational requirements set out in PPG 6. It would be an appropriate

location for new retail development, including for bulky goods.

the case where the existing developments are established operations which satisfy an identified need, are well related to government policy objectives (see

below) and where their displacement would potentially add significantly to the cost of delivery. This consideration is particularly relevant to the Homebase Store.

Mining Engineer: John Stothard

contained within PPG13: Transport and PPG1: General Policy and Principles. Government advice clearly seeks to locate development to locations acceessible

by a choice of transport modes and reduce reliance on the private car.

site stretching across the river adjacent to land in Network Rail's ownership. We would suggest that this land would be suitable for a public transport link into

the site from the west, utilising the Network Rail land. This would offer a sustainable transport reuse of former railway land. We would be pleased to discuss

any such possibility with the Council. The contacts within Network Rail for this are either myself or my colleague Andrew Dobson, Sales Surveyor. We can be

contacted at the address at the foot of the page.

identifies former railway land as being contaminated. Planning applications for the redevelopment of the area will need to be supported by an Environmental

Appraisal that outlines proposals for the investigation and remediation of contamination.

Town Planner: Tom Lambshead

would support any such station improvements provided they were operationally, commercially and technically viable and have the support of the relevant Train

Operating Company(ies).

WRMLG is firmly of the view that B&NES should not establish SPG for the site until it has demonstrated that the nature of development envisaged and any

community provision or transport infrastructure associated with the project can be funded on a sustainable basis. Given the long term nature of the project it is

essential that such viability can be demonstrated to exist in current and potentially less buoyant market conditions over the medium term.

To date WRMLG has not been involved by B&NES in the development of planning policy for the Western Riverside - other that through the general public

consultation process. Likewise none of its members been involved in the selection of the appointed masterplan developer for the site.

This is surprising given that WRMLG members own or occupy the vast majority of the Western Riverside development area. WRMLG suggests that B&NES

reviews it policy of excluding the major landowners at Western Riverside from the process of developing and establishing planning and development

procurement policy for the site and establishes some form of meaningful partnership for decision making in respect of such issues.

Riverside area. However the members of WRMLG are generally in operational uses and as such support for any form of redevelopment at Western Riverside is

wholly conditional upon satisfactory operational solutions and relocations being achievable.

minded about the development procurement strategy for the site at this stage (i.e. delivery through one of a number of developers) it does believe that it is

premature to stipulate that development should be co-ordinated by a single developer through a single planning application.

A4o 3 RMLG is of the view that the size and delineation of the development area is somewhat aspirational and includes limited consideration of the practicalities of 20-May-03 14:51

A5n 6.2.1 Residential Density - WRMLG is supportive of the aspiration for a predominantly residential scheme, however, given the size of the area of land identified for 20-May-03 14:52

A6n 6.2.3 30% Affordable Homes - (Policy GDS.1 B3) re-iterates that B&NES Draft Local Plan Policy on affordable housing will apply to the site. In particular that 30% 20-May-03 14:54

A7o 6.4.1 With regard to para 1.1 above and the provision of retail uses, WRMLG believes that SPG policy for Western Riverside should take account of the need to 20-May-03 14:09

A8o 6.7 Given the scale and quality of the existing retrial uses on the site WRMLG also believes that SPG for the site should acknowledge the reality that it may not be 20-May-03 14:10

A9o 7 When considering the issue of Public Transportation, SecondSite trust that B&NES and WSP are considering many different options/forms of transport system 20-May-03 14:10

A10o 7.2.1 Section 7.2 of the Draft SPG addresses Integrated Transportation. It is stated in paragraph 7.2.1 that "in order to maximise the development potential of the site 20-May-03 14:11

Ref Plan Ref Comment Summary Last Modified/Officer

there are two issues that I believe a fully worked up SPG for this site should address. One relates to how the site may be approached by any prospective

developer in terms of what is and isn't acceptable in relation to overall site morphology and I believe that the base line position that the guidance could usefully

take should relate directly to the site's historic grain. Rather than implying as I believe the document does, that Western Riverside is a largely blank canvass

we should be guiding developers to respect and enhance the historic grain. Within the site and apart from visible and obscured road systems, bridges and

early field boundaries, there are four significant surviving elements of the historic uses of the site. The most obvious are the gas holders and whilst their

continuing survival may not be appropriate they nevertheless represent a key aspect of the site dating back to the 1880's. and their presence could usefully be

incorporated into new designs. The railway embankment is another historic feature that also incorporates a significant biodiversity issue which should be

retained. A possible use for this feature could be the provision of a pedestrian and cycle link across the river to the Bath and Bristol Railway path. The third

element is the Printing works on Lower Bristol Road. This building is quite monumental in style and size and again represents a key historic aspect of the

area. In terms of landmark buildings within the development area, the conversion and reuse of this structure should be highlighted. Another group of

buildings deserving of special attention within any future development are the Wessex Water pumping station buildings off Midland Road. For any

redevelopment of this site to work well as part of the setting of the World Heritage City I believe that paying significant regard to enhancing existing and historic

morphology will be crucial.

that this should be rewritten to refer to existing and historic site morphology. The streetscape of Georgian and Medieval Bath is surely inappropriate here.