Meeting documents

Cabinet
Wednesday, 11th October, 2006

Responses to the BWR SPD

Support

Paragraph/Plan No/Proposal	Support/Object	Company	Comments	Council Comments
General support	support	International Council on Monuments & Sites UK	Welcomes in principle the document as an essential prerequisite for this development.	Support noted.
General support	support	Mrs J Bird	Support all documents	Support noted.
General support	support	South West Regional Development Agency	We are happy with the proposed distribution of land uses, and the connections that have been made to the surrounding areas.	Support noted.
General support	support	St John's Hospital & Bellots Hospital	Welcome the overall content of the SPD so far as it affects their land.	Support noted
General support	support	The Environment Agency	The Environment Agency supports the approach adopted by Bath and North East Somerset Council, and particularly welcomes the continuing strong emphasis on, and promotion of sustainability and related environmental issues, which is evident throughout the SPD.	Support noted
General support 1.1.4	support	National Grid Properties Ltd	National Grid Property supports the principle of the Council's vision for BWR.	Support noted
General support	support	Sainsbury's Supermarkets Ltd	General support for the comprehensive redevelopment of BWR.	Support noted
General support	support	National Grid Properties Ltd	Overall support for the Bath Western Riverside project and for Council's initiative to put in place a detailed "master plan" framework to guide the regeneration of this important site on a comprehensive basis.	Support noted
General support	support	Deeley Freed Estates Ltd	DFE is generally supportive of the principle of development outlined for the Western Riverside in the draft SPD, and the principle of new residential development in some areas along the north bank of the River Avon.	Support noted
General support	support	South West of England Regional Development Agency	We are happy with the proposed distribution of land uses, and the connections that have been made to the surrounding areas. We understand that negotiations in relation to the delivery of the scheme, including the financial aspects of this (such as developer contributions) will evolve as the strategy to develop this area of Bath progresses.	Support noted
General support	support	English Heritage	We welcome the creation of the SPD for the area and appreciate the time, effort and resources which have been invested in its production by the Council and its partners. We strongly support the emphasis that has been given to the public realm and landscaping element of the SPD. It represents the defining factor in Bath's character and quality and will be key to the delivery of a successful redevelopment of the site overall.	Support noted
General support (Provision of leisure facilities)	support	Lesley Metcalf	The infrastructure in central Bath will be over-loaded otherwise.	Support noted.
(General support) Shopping	support	Mr M Ware	The shops and concert halls cafes etc are to be welcomed, which could bring Bath to life again; for too long it has been a museum, and together with the Odeon cinema complex could make for a good night out.
General support (1.1.5, 1.5.2, 1.5.8, 1.5.25, 1.5.44, 1.1.45, 1.5.49, 2.2.9, 2.5.13, 2.6.1, 2.6.2 & 2.6.4)	support	The Inland Waterways Association	We support much of what has been written and in particular the content of these paragraphs.	Support noted
1.1.4 Vision	support	Crest Nicholson	Crest Nicholson supports the principle of the Council's vision for BWR. Welcomes the council's proposal to allow flexibility to developers to bring forward alternatives to the spatial master plan where they are supported by a clear design justification and where the quality of the development as a whole would be maintained or enhanced as a result.	Support noted
1.1.1-6 Vision	support	Westmark	We welcome the SPD; clarification will help to bring certainty to those bringing forward the regeneration of this important area of Bath. We support the Vision for BWR and its key principles	Support noted
Development Requirements 1.5.40	support	The Environment Agency	Supports the stated Environment Assessment Standards Energy Targets for BWR.	Support noted
Affordable Housing 1.5.16	support	Lesley Metcalf	There should be genuine provision of housing which can be afforded for renting or buying by people on average or below average income already working in Bath	The affordable housing strategy set out in the SPD proposes to achieve this.
Sustainable design 1.5.38 & 1.5.48	support	The Environment Agency	Particularly welcomes the stated aim that all buildings on the BWR site should be assessed at the design stage against the BREEAM or EcoHomes standards and should achieve an Excellent rating.	Support noted
Zero waste policy 1.5.46	support	The Environment Agency	Supports this text which is in accordance with the Council's Zero Waste Strategy.	Support noted
Affordable Housing (key workers) 1.5.16-1.5.21	support	Royal United Hospital	We would welcome the provision of some key worker accommodation in the Bath WRD development as part of the overall affordable housing requirement.	Support noted
1.5.26 - 1.5.29 Embedded Sustainability	support	Highways Agency	Support the concept of BWR being a sustainable community with aspirations for `zero carbon' and `zero waste' and welcome the encouragement of alternative modes of travel to the private car.	Support noted
Embedded Sustainability' 1.5.26 - 48	support	Envolve	This statement contained in the strategic framework must however be imbedded and monitored in all of the applications that will form part of the whole Western Riverside Development over the entire development period. The council must ensure that there are suitable resources (both financial and human) available for ensuring that this takes place. In addition there must be a stated mechanism in place for ensuring that the targets set for such things as on site energy production can be revisited and upgraded as technology advances over the life of the development. We would like to see a proposal for a sliding increasing target for this and for the initial on site energy production target to start at 15% rather than the stated cautious 10% Envolve feel it is critical that an opportunity is not missed to ensure that as much of the development as possible should be carbon neutral. This should not be optional and the SPD needs to set clear targets on this. The council should consider financial incentives for occupiers such as lower council tax bands for properties that are carbon neutral. Overall we welcome this clear and positive statement on sustainability, this is the only chance to be bold and brave and we would urge the Council to be ambitious and increase some of its targets for these critical issues effecting climate change. There is a huge opportunity for the development, within the context of a World Heritage City, to show the way forward for innovative sustainable urban development both in the UK and on the global stage	It is likely that a Sustainable Development Review Panel will be set up to look at detailed proposals, carry out post-construction reviews, and to review Sustainability Statements, taking into account changing standards. The 10% target is the one set out in the draft RSS. At para. 1.5.40 the SPD states that energy targets will be subject to review. The SPD can be reviewed alongside the LDF regarding this issue. The Panel referred to above can also review targets as applied to individual developments. It is considered that the SPD goes as far on this subject as is currently reasonable, in requiring one carbon neutral building. The SPD itself cannot commit financial incentives. Support noted. It is considered that the SPD goes as far on this subject as is currently reasonable.
Sustainability Open Space	Support	Friends of the Earth	The emphasis on imbedded sustainability and the attempt to achieve Eco homes `excellent' are both significant steps towards turning our culture away from out dependence on fossil fuels. We support the quantity standard, as a minimum, for each type of green space, as outlines in Appendix C. We also support paragraph 4.6.4 of the draft Sustainability report that the open space requirements will be significant and that the overall amount should be indicated. We would like to see greater detail about the anticipated bio-diversity enhancement. Crest's Outline Application pictures a kingfisher: what habitat and where, is being provided or enhanced, to encourage this bird? How will the existing `Brownfield' species continue to be accommodated? There is a golden opportunity for directly linking the pedestrian/cycle route known as the Linear Park, and the up-and-coming Western Riverside development area.	Support noted. Support noted. This appears to be a comment related to the planning application submitted by Crest. This linkage is recognised in the movement and access strategy diagram (plan 2.11) and will be facilitated by the improved crossing facilities required for the Lower Bristol Road / Windsor Bridge Road junction listed in Appendix C on page 1. Plan 2.11 to be amended to show the linkage as being a cycle link, as well as a pedestrian link.
1.5.44 Embedded Sustainability (transport)	support	Highways Agency	The promotion of walking and cycling is supported by the agency.	Support noted
2.11.11 - 2.11.13 Movement & Access: Parking	support	Highways Agency	The Agency supports the concept that large surface areas of parking area are not acceptable within the development.	Support noted
2.2.1 Vision Statement for BWR	support	Southgate Limited Partnership & Morely Fund Management	Fully support the redevelopment of the BWR area to provide `a sustainable mixed use city quarter' (para 2.2.1) for Bath.	Support noted
2.2Vision Statement	Support	Somer Housing Group	Pleased with the BWR SPD and support its objectives and principles.	Support noted
2.2 Vision Statement	Support	Westmark	We are very pleased to see the publication of the Western Riverside Supplementary Planning Document and support it objectives and principles set out in the vision for Western Riverside.	Support noted
Plan 2.3 Summary Masterplan	support	St John's Hospital & Bellots Hospital	Welcome the identification of the TA centre as a possible site for residential development. The charities have concerns about the implications of the SPD on the TA centre in particular whilst the site is let. The charities would wish to see recognition that there will be more detailed plans on phasing etc. There should be reference to the involvement of stakeholders in this process.	Support noted Existing uses within BWR will remain until relocations are secured through redevelopment or Compulsory Purchase. The Phasing Strategy is set out in section 3.2 of the SPD, with Context Plans providing a greater level of detail. As Context Plans have to be submitted with planning applications at BWR, stakeholders have the opportunity to comment on these as part of the planning application process.
Importance of the River Avon to BWR 2.6	support	The Environment Agency	Welcomes the introductory paragraphs which, together with associated text throughout the SPD highlight the importance of the River Avon to BWR, and the opportunity it affords to create a development enhancing and environmentally sensitive landscape feature.	Support noted
Natural edge policy 2.6.12	support	The Environment Agency	Agency supports the Design Criteria for the natural edge of the river corridor, in particular the use of native species to supplement the existing retained planting. The Agency would reiterate that a management plan for dealing with on site Japanese Knotweed should be prepared at the earliest opportunity.	Support noted Agree. New para. in SPD to require management plan for on site Japanese Knotweed.
Design	Support	Bath Preservation Trust	The Design Code sets out 8 excellent principles for façade design (plus 6 for roof design and 3 for landscape). The acceptable materials Schedule 2 must apply to the Western Neighbourhood and the Eastern Zone, as well as to the Northern Bank. In establishing a contemporary architectural genre, B&NES must not be deflected from these principles and in particular must demand the highest quality. Bath stone should be required for all facades facing the street instead of reconstituted materials or stone coloured render.	Support Noted
Design criteria for Green Park Station 2.7.8 - 10	support	Envolve	In addition to the aims stated within this section we would also wish to see the physical structure of Green Park Station used to showcase sustainable energy and ways of living, where the people of Bath and surrounding area can come and be informed of techniques, technology and practice of sustainable living through the provision of an information centre, education space, practical working demonstrations and the like.. Envolve is committed to Green Park Station and is keen to work with the Council to ensure that an innovative solution is found for this important heritage building.	Agree that within Embedded Sustainability section (1.5.26 - 1.5.48) there should be a requirement for a sustainability education centre at BWR, but this should not be limited to Green Park Station. New para. inserted after para. 1.5.48. Noted.
Part 3 Development Context	Support	PC Chas Cannon, Crime Reduction and ALO, Bath Police	There should be reference somewhere within the document to security and design. The principle should be that any design applications should take security into consideration and where possible design should follow the "secured by design" principles.	Agree that there should be reference to Security and Design. New para. after para. 2.5.3.

OBJECT (GENERAL)

Paragraph/Plan No/Proposal	Support/Object	Company	Comments	Council Comments
General Objection (Licensed Premises)	Object	Mr and Mrs Spencer	No bars/nightclubs in or near residential area. Strictly limited to café, bistros and restaurants.	The detailed location of the various commercial uses, including Class A4 Drinking Establishments will be determined through more detailed masterplanning in producing Context Plans and through individual planning applications. In order to enhance vitality of BWR it is likely that there will be an appropriate element of A4 uses.
General Objection (Population Density)	Object	Mrs Martine Smith	Plans for 2300 homes, student accommodation, shops etc will mean far too many people in this area for the infrastructure of the area, particularly the roads.	Both National and Regional planning policies require that optimum use is made of brownfield sites in sustainable locations such as BWR. The SPD allows for this, subject to the impacts being satisfactorily mitigated.
General Objection (Crime)	Object	Charlotte Laurence	Increase drug and alcohol-related crime in an effectively un-policeable corridor through the Green and up into Charlotte Street Car park and the Royal Crescent.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
General Objection (Format and style of document)	object	WPB	The format of the document is unreadable. Its strive for `chic' makes it next to impossible to follow. Its `embedded' jargon will only serve to disengage both those who will wish to comment and its possible intended readership. The typical cross sections imply the existence of finalised options for the site. The generalised zonal spatial masterplan is at best wholly confusing. The approach fails to recognise key relationships in the effort to pigeon hole zonal areas.	Disagree. The SPD follows the structure set out in the CABE guidance "Creating Successful Masterplans". The language of the SPD aims to strike the balance between plain English and being a technical document to guide development in what is a complex set of circumstances. The sections are described as "indicative" because the form of development for the site is not finalised. The spatial Masterplan is zonal, in order to allow for future flexibility, whilst maintaining certain key principles. Do not fully understand final statement.
General Objection (Context Plans)	Object	Westmark	If an approved context plan contradicts or builds upon an issue within the Design Code, which takes precedent? Context Plans are another layer of masterplanning and therefore, once established are above SPDs and therefore Design Codes.	The context plans need to comply with the SPD, and therefore will need to comply with the Design Codes. The Design codes are at a finer level of detail than the SPD, and build upon it. The context plans are intended to be at a framework level not a detailed level.
General Objection (Stakeholder Participation and strategic links)	object	WPB	The current document appears too inward looking in contextual terms. This unfortunately prevents it from truly fulfilling its comprehensive visionary objective. Whilst land use and existing linkage to immediate areas are considered in the spatial masterplan, BWR is an extensive urban site to the west of the City Centre which will have much wider implications for core areas of the City and related areas including the extensive river corridor. Related landuse implications for housing, retail and transport related matters are simply not addressed. How will existing commitments to additional SPD formulation be approached in associated areas? We would be concerned if these commitments were simply an after-thought. We recommend that a key diagram and supporting text is compiled showing the proposed consideration of wider plan making outside BWR especially where there is direct or indirect linkage. Early indications over the defining of suitable boundary of BWR suggested that a proper contextual approach would be adopted to that represented in the draft SPD. There is a need for much wider consideration of the river corridor, existing communities, their travel to work areas and their relate linkage/interface.	Disagree. The role of the SPD is to provide a spatial Masterplan for the BWR area. Where appropriate, off-site requirements and impacts are referred to in the SPD. Otherwise, it is the role of the B&NES Local Plan and other DPDs to control development outside of the SPD boundary. Disagree. It is not the role of the SPD to do this. Commitments regarding other SPDs are set out in the LDS. Disagree. The SPD boundary is set by the allocation in the B&NES Local Plan (Site B1, Policy GDS1). Key relationships to surrounding areas are identified in the SPD at an appropriate level.
General Objection (World Heritage Status)	object	International Council on Monuments & Sites UK	Object to the BWR development in its present form. Believe that the development needs significantly strengthening to take account of the very specific nature of Bath's World Heritage status and its implications for this development. Taken as it now stands it could be highly damaging to the special qualities of the WHS. Nowhere in the current document is the reason for Bath's inscription on the World Heritage list spelt out, nor is the fundamental rationale for World Heritage status alluded to. Where there is a mention of World Heritage Status, this is only in very general terms. The SPD needs to spell out why the WHS was inscribed and to say what this means in terms of the proposed development on the site and on indicate how development might or might not be in line with World Heritage `status'.	Agree. Revise SPD to include the Outstanding Universal Values of the WHS, and acknowledge the important role the site must play in achieving the aims of the WHS management plan. Include reference to World Heritage Site Management Plan in Strategic Framework of SPD. Develop a stronger link in the text between WHS status and the Vision for BWR at 2.2, and include in 2.3, Overarching Design Principles as part of item 6.
General Objection (World Heritage Status)	object	English Heritage	The SPD needs to demonstrate more explicitly that it understands, and that its contents are compatible with, the Outstanding Universal Values of Bath as a World Heritage Site. As a general observation we must express concern that the SPD Is not sufficiently self-contained in providing the evidence and reasoning for its proposals nor does it include references to underpinning source material or empirical data. Of explicit and overriding significance is terms of this omission is the need to demonstrate an understanding of the Outstanding Universal Values of the city as a World heritage Site and how these have been respected.	See response in box above An explanation of the underpinning studies to be included as part of main text between paras 2.1.4 and 2.1.5, to explain how the baseline studies have influenced the SPD guidance. Full bibliography of supporting texts to be included.
General Objection (World Heritage Status)	object	English Heritage	Question the ability of the SPD to successfully foster the necessary "Bath" sense of place. The design codes draw comprehensively on elements of existing historical character in Bath and apply them to character areas. While they understandably focus primarily on the physical attributes which any development scheme would need to possess, the extent to which they are capable of identifying and helping to generate a requisite sense of place is less clear. If not in this document then elsewhere, but the SPD does need to consider how it can promote that quality and help realise it.	The Design Codes could be enhanced in order to produce a more comprehensive study of `Bath' sense of place, with more illustrative material . With possible use as a more general development control design tool across the city
General Objection (World Heritage Status)	object	English Heritage	Suggest that there should be a clear prioritisation of outputs and deliverables. In our view the consideration of the WHS outstanding status should be the highest priority consideration and the integrity of the historic character of the city should not be compromised to satisfy regeneration agendas.	Disagree. RPG10 states that a balance needs to be struck between preserving and enhancing the Bath's unique architectural, historic and landscape quality and encouraging and accommodating sustainable development.
General Objection (WHS Management Plan) Point 6 page 18	object	International Council on Monuments & Sites UK	There is little mention of the Bath WHS Management Plan, which UNESCO World Heritage Centre has accepted as the over-arching document to guide the management of change within the WHS Reference to enhancement of the WHS has no suggestion of what this might mean. Greater clarity is needed.	Include reference to WHS management plan at 2.15. Rephrase item 6 in paragraph 2.4 to exclude "not only in physical terms but also in the management of the existing asset"
General Objection (Design)	object	International Council on Monuments & Sites UK	More explicit reference to design needed e.g. materials, scale, coherence of facades, open spaces, green setting etc	This is addressed by the overarching design principles at 2.3, and by the design codes.
General Objection (Role of Council)	object	GOSW	Would expect the SPD to reflect the more positive and proactive role that Bath & North East Somerset Council will need to play to ensure the successful delivery of this important site.	The Council feels that the various positive and proactive roles that Council will play are set out in paras. 3.1.4 - 3.1.7 (Delivery Roles).
General Objection	object	GOSW	SPD could be developed further to ensure that it is spatial rather than primarily land use. For example consideration should be given to how the community, social and economic aspects of the scheme can be expressed in the Masterplan. In my opinion the document would benefit from considerable editing to provide a more succinct text which focuses upon the key principles. Better use could also be made of the diagrams to inform the reader and illustrate key points.	It is the role of the Sustainability Appraisal Report to assess to what extent the SPD meets community, social and economic objectives. It is considered that the SPD strikes a good balance between text and illustrative material. The document needs to be robust enough to be appropriate over time, and to withstand detailed scrutiny and interpretation.
General Objection (Drainage)	object	Wessex Water	The SPD should also make it a requirement to separate surface and foul water drainage. The existing sewerage system does not have capacity to accommodate surface water drainage from the site. In addition to substantial additional cost to the developer, allowing surface water to discharge to the existing foul drainage system will increase the risk of pollution from foul water flooding as well as being unsustainable in terms of pumping and treatment costs. Support for these views is given the emerging Regional Spatial Strategy; in the Government consultation paper Proposals for introducing a Code for Sustainable Homes; and in Planning Policy Guidance PPG25: Development and Flood Risk.	Include this requirement in a new section 2.14 Drainage and Flooding.
General Objection (Environmental Issues)	object	The Environment Agency	It is felt that greater reference could be made within the SPD itself to certain environmental issues. These include elements of flood defence and groundwater protection/contaminated land, and also the need to adopt stringent pollution prevention measures. However, it is acknowledged that these issues are detailed in associated documentation and are currently the subject of discussions between the Agency and the applicant's agent.	Include this requirement in a new section 2.14 Drainage and Flooding.
General Objection (Sustainability Appraisal)	object	GOSW	The Sustainability Appraisal has made a number of recommendations and the SPD will need to demonstrate how these have been considered and incorporated where appropriate.	Disagree. The Final SA Report will set out how the SPD has changed to respond to the SA.
General Objection (Environmental Assessment)	object	GOSW	The purpose of including this document within the SPD is unclear. I would suggest that work that is intended to inform the EIA process should be undertaken in conjunction with those parties who will be responsible for submitting the Environmental Statement in due course.	The role of the Environmental Appraisal is to summarise the environmental baseline conditions that have influenced the masterplanning process. Including this information as a separate document allows the main SPD document to become less bulky.
General Objection (Public Transport)	object	Royal United Hospital	The SPD should make more explicit reference to the enhancement of pedestrian, cycle and public transport links to the RUH site. Rapid Transport Link mentioned should not adversely affect or undermine the viability of public transport serving the RUH or the roads near the RUH.	Disagree. The SPD makes various references in the text and in diagrams (especially 2.11 Movement and Access Strategy) to the importance of sustainable transport links to and from BWR. It is not considered to be appropriate to make special reference to links to the RUH, particularly as the SPD does not require off-site links between BWR and the RUH to be specifically enhanced. The Rapid Transit Link will be provided as part of an overall network of public transport for Bath, where the importance of services relating to the RUH is recognised. No adverse effect expected. Other elements of the Bath Package Major Bid, if successful, will result in improvements to public transport other routes thus improving access to the hospital.
General Objection (Public Transport)	object	Royal United Hospital	The RUH would welcome the expansion of the Newbridge Park & Ride facility to serve both Bath WRD and the RUH and is disappointed that such a proposal is not included in the SPD.	It is not the role of the BWR SPD to propose Park & Ride facilities for the RUH. Park & Ride facilities, plus other transport infrastructure requirements are set out in Appendix C of the SPD (Developer Contributions).
General Objection (River Transport)	object	The Inland Waterways Association	The issue of using the river for transport in the form of water taxis or a ferry system to the transport interchange at Churchill Bridge appears to have been totally ignored. Such a system would meet the criteria of persuading people away from their cars by providing an alternative and attractive way of transport.	Introduce an additional bullet point at 2.6.4, under River Design Principles Development along the river frontage must accommodate and encourage river traffic. Expand advice within the Design Codes to address specific requirements of river traffic.
General Objection (Traffic modelling)	object	Royal United Hospital	Please confirm the proposals take account of the RUH's masterplan and that they will not have an adverse impact in the access to and from the RUH for staff, patients and visitors.	No adverse effect expected. Other elements of the Bath Package Major Bid, if successful, will result in improvements to public transport other routes thus improving access to the hospital.
General Objection (Legal/Procedural)	object	Southgate Limited Partnership & Morley Fund Management	The Local Plan has not yet been adopted, nor modifications following the Inspector's report published, and until such time as a Statutory Development Plan framework is in place it is premature for the BWR SPD to be progressed.	Disagree. The status of the SPD is clearly set out in paras. 1.1.11 - 1.1.14. The SPD is in accordance with and supplementary to RPG10 and the JRSP, which form part of the development plan. The B&NES Local Plan is at an advanced stage of preparation, which has formed an appropriate framework for the SPD. As stated in the SPD (para. 1.1.13), the SPD will be considered again by the Council once the recommendations of the Local Plan Inspector and the Council's response to those recommendations have been considered.
General Objections (Legal/Procedural issues)	object	St John's Hospital & Bellots Hospital	Concerns about the validity of the SPD having regard to the guidance set out in PPS12.	It is proposed that the SPD is given the status of 93Approved for Development Control purposes94 at this point in time, with the SPD being Adopted following Adoption of the Local Plan.
General Objections (Legal/Procedural)	object	St John's Hospital Trustees	PPS12 states at paragraph 2.43 that SPDs `may expand policy or provide further detail to policies in a development plan document. They must not however, be used to allocate land'. The inclusion of land for retail purposes within the SPD when no land is identified within the Local Plan, as is proposed assuming the Inspector's recommendations re upheld by the Council, is contrary to this requirement.	Disagree. Paras. 1.5.23 & 1.5.24 of the SPD (Retail Development) set out that the SPD does not make specific provision for significant retailing at the site. Where the SPD, in the role of a spatial Masterplan for the period to 2021, states that it does not rule out additional retail development beyond the current B&NES Local Plan period to 2011, it explains that this is dependant upon the Local Development Framework considering this to be acceptable in future.
General Objections (Legal/Procedural)	object	Renrod Motor Group	Significant concerns about the legal status of the SPD and, its validity, having regard to its timing prior to the adoption of the BANES Local Plan and the considerations of the Inspectors report on the Local Plan. Suggest the withdrawal of the SPD, until such time as progress is made on the Local Plan to which it is supplementary. There are serious concerns about whether the Council are able to adopt the Local Plan given that it has not been the subject of a Strategic Environmental Appraisal.	Disagree. The status of the SPD is clearly set out in paras. 1.1.11 - 1.1.14. The SPD is in accordance with and supplementary to RPG10 and the JRSP, which form part of the development plan. The B&NES Local Plan is at an advanced stage of preparation, which has formed an appropriate framework for the SPD. As stated in the SPD (para. 1.1.13), the SPD will be considered again by the Council once the recommendations of the Local Plan Inspector and the Council's response to those recommendations have been considered. It is proposed that the SPD is given the status of 93Approved for Development Control purposes94 at this point in time, with the SPD being Adopted following Adoption of the Local Plan. This is a matter for the Local Plan.
General Objections (Legal/Procedural issues)	object	Stones Coaches	Very significant concerns about the legal status of the SPD and, it's validity having regard to it's timing. Most fundamentally, as noted in the SPD it is prepared prior to the adoption of the Bath & North East Somerset Local Plan to which it is proposed to be supplementary. Such an approach does not conform to the requirements of PPS12. It is considered inappropriate for the SPD to be published at this time, as the Local Plan is unlikely to be adopted until Spring 2007 and the Inspector's report on the local plan found concerns related to retail policy, public transport proposals and existing businesses affected by development proposals.	Disagree. The status of the SPD is clearly set out in paras. 1.1.11 - 1.1.14. The SPD is in accordance with and supplementary to RPG10 and the JRSP, which form part of the development plan. The B&NES Local Plan is at an advanced stage of preparation, which has formed an appropriate framework for the SPD. In accordance with the SPD (para. 1.1.13), the SPD has been considered again by the Council following its consideration of the recommendations of the Local Plan Inspector. It is proposed that the SPD is given the status of 93Approved for Development Control purposes94 at this point in time, with the SPD being Adopted following Adoption of the Local Plan.
General Objections Legal/Procedural issues	object	St John's Hospital Trustees	Concerned about the preparation of the SPD prior to the adoption of the BANES Local Plan. To do so is premature and therefore inappropriate, confusing to members of the public and a waste of resource. Preparation should be halted until the adoption of the Local Plan. It is stated that the SPD was prepared prior to the Council's receipt of the Local Plan Inspectors Report and that recommendations will be taken into account when amending the SPD. This approach does not conform with the requirements of PPS12. t is not appropriate for the Council to produce an SPD on policies which are still under review. The SPD has been produced to support policy GDS1:B1 of the BANES Local Plan. Significant changes to this policy and the related retail policies are recommended by the Local Plan inspector.	Disagree. The status of the SPD is clearly set out in paras. 1.1.11 - 1.1.14. The SPD is in accordance with and supplementary to RPG10 and the JRSP, which form part of the development plan. The B&NES Local Plan is at an advanced stage of preparation, which has formed an appropriate framework for the SPD. In accordance with the SPD (para. 1.1.13), the SPD has been considered again by the Council following its consideration of the recommendations of the Local Plan Inspector. It is proposed that the SPD is given the status of 93Approved for Development Control purposes94 at this point in time, with the SPD being Adopted following Adoption of the Local Plan.
General Objections Legal/Procedural issues	object	Argos Retail Group	Objections that the Council is effectively ignoring the advice of PPS12 in that 93key decisions94 have not yet been addressed or taken which are fundamental to the draft SPD's proposals for BWR. These specifically include the matters identified by the Inspectors Report in relation to the future of those existing businesses wishing to remain within BWR. This matter has largely been ignored in the draft SPD to such an extent that there is not even an indication as to the number of businesses that are likely to be affected and if some were to be relocated, the likelihood of finding suitable, available and viable sites elsewhere.	Disagree. The status of the SPD is clearly set out in paras. 1.1.11 - 1.1.14. The SPD is in accordance with and supplementary to RPG10 and the JRSP, which form part of the development plan. The B&NES Local Plan is at an advanced stage of preparation, which has formed an appropriate framework for the SPD. As stated in the SPD (para. 1.1.13), the SPD will be considered again by the Council once the recommendations of the Local Plan Inspector and the Council's response to those recommendations have been considered. It is proposed that the SPD is given the status of 93Approved for Development Control purposes94 at this point in time, with the SPD being Adopted following Adoption of the Local Plan.
General Objections Legal/Procedural issues	object	WPB	It is unclear whether this SPD has been drafted to comply with relevant sections of the emerging Local Plan. In this regard, does the current document reflect Council's response to the Inspectors Report in regard to both site specific matters and wider housing, retail and transport related matters? Whilst we would encourage forward movement with this SPD we understand that formal response to the Inspectors report will not be debated until later this year. This will involve key decisions over matters directly relating to BWR	Disagree. The status of the SPD is clearly set out in paras. 1.1.11 - 1.1.14. The SPD is in accordance with and supplementary to RPG10 and the JRSP, which form part of the development plan. The B&NES Local Plan is at an advanced stage of preparation, which has formed an appropriate framework for the SPD. As stated in the SPD (para. 1.1.13), the SPD will be considered again by the Council once the recommendations of the Local Plan Inspector and the Council's response to those recommendations have been considered. It is proposed that the SPD is given the status of 93Approved for Development Control purposes94 at this point in time, with the SPD being Adopted following Adoption of the Local Plan.
General Objection (Retail component of BWR)	object	St John's Hospital Trustees	The inspector recommended against the inclusion of large scale retail development at Bath Western Riverside, as it was felt it would `introduce a separate shopping destination' which would compete with shops in the historic core and with new units constructed in the redevelopment of Southgate. The SPD allocates a large area for commercial uses. This is completely contrary to the Inspector's recommendations that retail allocations should be deleted from BWR.	Disagree. Paras. 1.5.23 & 1.5.24 of the SPD (Retail Development) set out that the SPD does not make specific provision for significant retailing at the site. Where the SPD, in the role of a spatial Masterplan for the period to 2021, states that it does not rule out additional retail development beyond the current B&NES Local Plan period to 2011, it explains that this is dependant upon the Local Development Framework considering this to be acceptable in future.
General Objection (Retail)	object	Southgate Limited Partnership & Morley Fund Management	The master plan document as a whole should be re-visited to reflect the fact that sequentially preferable retail development opportunities exist in the city centre. Proposed retail allocation in Bath Western Riverside should be deleted. For Bath city centre to remain vital and viable the BWR SPD must not include references to retail (other than small scale ancillary retailing, the scale of which should be defined) or unspecified commercial development. It would be legally perverse for the Council to be at the same time moving towards the adoption of a development plan, which treated BWR as out of centre and not appropriate for any retail allocation and at the same time to be promoting a draft SPD allowing for the possibility of retail development at BWR, in direct conflict with the development plan strategy. Accordingly, were the current BWR SPD to be adopted by the Council in its present form it would be susceptible to legal challenge whether by judicial review or pursuant to section 113 of the 2004 Act., were indeed the Secretary of State not first to exercise her powers under section 21 to direct modification in line with recommendations made in respect of BWR in the Local Plan Inspection Report.	Disagree. Paras. 1.5.23 & 1.5.24 of the SPD (Retail Development) set out that the SPD does not make specific provision for significant retailing at the site. Where the SPD, in the role of a spatial Masterplan for the period to 2021, states that it does not rule out additional retail development beyond the current B&NES Local Plan period to 2011, it explains that this is dependant upon the Local Development Framework considering this to be acceptable in future. Disagree. The status of the SPD is clearly set out in paras. 1.1.11 - 1.1.14. The SPD is in accordance with and supplementary to RPG10 and the JRSP, which form part of the development plan. The B&NES Local Plan is at an advanced stage of preparation, which has formed an appropriate framework for the SPD. In accordance with the SPD (para. 1.1.13), the SPD has been considered again by the Council following its consideration of the recommendations of the Local Plan Inspector. It is proposed that the SPD is given the status of 93Approved for Development Control purposes94 at this point in time, with the SPD being Adopted following Adoption of the Local Plan.
General Objection (Existing businesses)	object	Renrod Motor Group	Despite setting out objectives for economic regeneration (1.1.5, 1.1.7, 1.5.2 & 1.5.22) the proposals effectively propose to extinguish a series of businesses which contribute significantly to the city economy.	The SPD exists within the context of BWR being required for a high density mix of developments that are appropriate to its location within the City. Businesses that comply with the SPD can remain within BWR, either in their existing locations or on new sites. The Council has recently set up a Business Relocations Group to assist businesses displaced by redevelopment projects, and businesses affected by the SPD proposals will receive support from this group.
General Objection Omitted reference to Argos or Homebase sites	object	Argos Retail Group	There is no reference to the Argos or Homebase sites or to the Council's proposals for any existing businesses within the BWR. These omissions have been recognised in the Inspectors Report into the Revised Deposit Plan. I understand that the Council is still considering this Report and that Proposed Modifications will be published later this year. There is no indication at present of the Council's likely response to Inspector's recommendations and none of these issues have so far been addressed in the draft SPD.	The SPD explains at para. 1.1.13 that it was produced prior to the publication of the Local Plan Inspector's report. In accordance with the SPD (para. 1.1.13), the SPD has been considered again by the Council following its consideration of the recommendations of the Local Plan Inspector.
General Objection Existing businesses adjoining the SPD area	object	Stones Coaches	The SPD should refer to the retention of existing businesses which adjoin the SPD area and the value these have in contributing to the city economy generally and the future vibrancy of the Riverside area.	Disagree. It is not the role of the SPD to consider businesses and sites that adjoin, i.e. lie out side of, the SPD area.
General Objection (Delivery - key objectives are purely aspirational)	object	Sainsbury's Supermarkets Ltd	Until the issue of Sainsbury's relocation is properly planned for and found to be viable, serious doubts must remain over the prospects of delivery of some of the key objectives and aspirations for the eastern end of BWR (eg. the civic plaza and Rapid Transport System). Such objectives are fundamental in ensuring that the BWR area links effectively with the established City Centre. As it stands, some of the key objectives for BWR can be considered as no more than aspirational, in that they are not founded on any clear basis for delivery. Given that key objectives of the SPD are reliant on relocation of the Sainsbury's store, a key weakness of the SPD is that there is no fall-back strategy if SSL were to maintain their current operation at Green Park Station (ie. if relocation is found to be unviable or otherwise unacceptable). This is a conceivable proposition, given the popularity and commercial success of the current store, and the failure to date to identify an appropriate alternative site. Furthermore, there is the issue of whether relocating the Sainsbury's store further away from the City Centre can, in principle, be reconciled with the overriding requirements of retail planning policy. It is also relevant to note the Local Plan Inspector's comments and recommendations relating to BWR, which the Council is currently considering.	The SPD sets out key objectives for the redevelopment of the BWR which is anticipated to take up to approximately 2021 to deliver. Whilst it is accepted that there are challenging issues relating to the delivery of the redevelopment of the eastern zone of BWR, it is important that the SPD establishes the key objectives and requirements for development across the whole of BWR. These established objectives and requirements will then form the basis of more detailed masterplanning work that will produce the required Context Plan for the eastern zone. The key objectives of the SPD are indeed reliant upon the relocation of the Sainsbury's store, particularly with regard to enhancing connectivity between BWR and the City centre, providing a high quality piece of public realm adjacent to the river, and enhancing the setting of Green Park Station. It is, therefore, not considered appropriate to provide a fall-back strategy that proposes an option that fails to deliver key objectives. The retail planning policy issues relating to a re-located Sainsbury's will be addressed through the Local Development Framework, along with the other retail policy implications for the eastern zone of BWR.

Objections PART 1: STRATEGIC FRAMEWORK

Paragraph/Plan No/Proposal	Support/Object	Company	Comments	Council Comments
1.1.6 Sustainable Development	Object	Westmark	There appears to be an inherent tension and conflict between the objectives laid out for sustainability and the urban design objectives laid in the document. The stringent design codes later in the document which limit materials and roof forms making embedded sustainability that much more difficult to incorporate. Based on examples of recent applications - taking into account the WHS status of the city - design is paramount, and and sustainability initiatives are secondary.	Disagree. It is not accepted that measures to achieve embedded sustainability that are designed in from day one are automatically in conflict with design and World Heritage Site objectives.
1.1.13 Status of the SPD	object	Crest Nicholson	It is not clear how the Council's response to the Inspector's Report is to be taken into account during public consultation.	As stated in the SPD (para. 1.1.13), the SPD will be considered again by the Council once the recommendations of the Local Plan Inspector and the Council's response to those recommendations have been considered. It is proposed that the SPD is given the status of 93Approved for Development Control purposes94 at this point in time, with the SPD being Adopted following Adoption of the Local Plan.
1.1.3 Review Process	object	Southgate Limited Partnership & Morley Fund Management	In light of the inherent flexibility of the SPD as outlined in paragraph 1.1.3 object to the remainder of the document and the repeated reference to `commercial' and retail development in the Eastern section of the Masterplan area.	Where the SPD, in the role of a spatial Masterplan for the period to 2021, states that it does not rule out additional retail development beyond the current B&NES Local Plan period to 2011, it explains that this is dependant upon the Local Development Framework considering this to be acceptable in future.
1.1.13	object	National Grid Properties Ltd	It is not clear how the Council's response to the Inspector's Report is to be taken into account during public consultation.	In accordance with the SPD (para. 1.1.13), the SPD has been considered again by the Council following its consideration of the recommendations of the Local Plan Inspector. It is proposed that the SPD is given the status of 93Approved for Development Control purposes94 at this point in time, with the SPD being Adopted following Adoption of the Local Plan.
1.1.14	Object	Westmark	SPD as replacement to SPG - hoped that the former build on the latter. Lack of guidance has created some circumstances - affordable housing - where key worker housing has been objected to on sites within BWR, on what appears to be the whim of the Housing Enabling Team.	Para. 1.2.6 explains that the SPG was the brief for the masterplanning exercise that led to the production of the SPD. It is the role of the SPD to provide guidance. For example, para. 1.5.17 states that individual schemes will have to demonstrate that their affordable element forms part of the overall strategy towards affordable housing at BWR.
1.3 Future for Bath Vision	object	English Heritage	The extent to which emphasis should be given to the Future for Bath Vision as a guiding influence given the nature of its status. While we acknowledge the need for a vision of some description, to identify the city's needs and help guide its future, the document adopted by the Council contains themes and promotes initiatives which are no doubt capable of having a dramatic effect upon the character of Bath. We are unsure of the status of the vision and the extent to which it has been through a consultation process, statutory or otherwise, and therefore the degree of attention it should be afforded as a material consideration in the formation of the SPD. Concerned that this vision has not taken appropriate account of its need to be consistent with the Outstanding Universal Values of Bath's World Heritage Site status.	Most of these points will have to be addressed as part of the production of the Vision document itself. Section 1.3 of the SPD clearly sets out the process that has been undertaken with regard to the Vision, and para. 1.3.6 acknowledges that the Vision currently has little weight in planning terms. It is not considered that the SPD gives more weight to the Vision than is appropriate.
1.5.2 Comprehensive approach	object	Crest Nicholson	Crest Nicholson regard the seventh bullet point as of critical importance. Regeneration will only be secured if the serious viability issues affecting the scheme are reflected in the planning and development model that is adopted for the scheme. This has to be taken into account throughout the SPD.	The SPD sets out objectives and requirements that will remain consistent across the full development period, whereas viability issues such as build costs, interest rates, sales values and availability of gap funding are liable to change over time. Therefore, whilst the need for viability is recognised in the SPD, it is the role of the Local Planning Authority to determine whether any other material considerations (such as viability) outweigh any lack of conformity with any aspects of the SPD when considering individual planning applications.
1.5.2 Viability	object	National Grid Properties Ltd	National Grid Property regards the seventh bullet point as of critical importance. Regeneration will only be secured if the serious viability issues affecting the scheme are reflected in the planning and development model that is adopted for the scheme. This has to be taken into account throughout the SPD.	The SPD sets out objectives and requirements that will remain consistent across the full development period, whereas viability issues such as build costs, interest rates, sales values and availability of gap funding are liable to change over time. Therefore, whilst the need for viability is recognised in the SPD, it is the role of the Local Planning Authority to determine whether any other material considerations (such as viability) outweigh any lack of conformity with any aspects of the SPD when considering individual planning applications.
1.5.4 Gap funding	object	National Grid Properties Ltd	The Draft SPD does not make clear the extent to which the spatial master plan, design codes and approach to developers contributions embodied in the guidance reflect and depend upon assumptions that have been made about "gap funding" from bodies such as SWRDA, English Partnerships and Housing Corporation.	Paras. 3.1.10 - 3.1.13 (Potential Providers of Gap Funding) explain the role of these bodies and makes it clear that no gap funding has been secured to date. No quantifiable assumptions have been made regarding gap funding, therefore, it is not possible for the SPD to set out the extent to which various elements of the SPD are dependent on gap funding.
1.5.4 Viability	object	Crest Nicholson	The Draft SPD does not make clear the extent to which the spatial master plan, design codes and approach to developers contributions embodied in the guidance reflect and depend upon assumptions that have been made about "gap funding" from bodies such as SWRDA, English Partnerships and Housing Corporation.	Paras. 3.1.10 - 3.1.13 (Potential Providers of Gap Funding) explain the role of these bodies and makes it clear that no gap funding has been secured to date. No quantifiable assumptions have been made regarding gap funding, therefore, it is not possible for the SPD to set out the extent to which various elements of the SPD are dependent on gap funding.
1.5.4 Viability	Object	Somer Housing Group	Level of Gap Funding should be determined as soon as possible. This paragraph does not explore the consequences of Gap Funding for affordable housing in particular.	Para. 3.1.11 states that the Housing Corporation has a key role to play if BWR is to successfully deliver a significant amount of affordable housing on site to meet identified local need.
1.5.4 Viability	Object	Westmark	The reference to gap funding introduces the concept of gap funding. The level of this gap funding should be determined as soon as possible. This paragraph does not explore the consequences if gap funding (for affordable housing in particular) is not achieved or provide any contingency approach if it is not to the degree that is required. It is appreciated that this gap funding commitment may only be over the timescales that are defined by Government spending and not for the full period of the development.	Para. 3.1.11 states that the Housing Corporation has a key role to play if BWR is to successfully deliver a significant amount of affordable housing on site to meet identified local need. If gap funding is not forthcoming, the delivery of a suitable amount of affordable housing at BWR will not be possible. It is not appropriate for the SPD to set out a contingency approach for circumstances that are contrary to a key objective of BWR.
1.5.8 Rapid Transit System	object	Crest Nicholson	Here and elsewhere there is reference to a bus-based rapid transport system, also described as "Bath Rapid Transit". However, the Draft SPD does not specify what has been assumed in this respect, both when formulating the spatial master plan and design codes and when assessing the developers contributions set out in Appendix C. Since there is no approved rapid transit scheme at present. the Draft SPD should make explicit what has been assumed in these respects.	The bus-based Rapid Transit System is part of the Bath Package Major Bid that has been submitted to Government and features in the RFA approved by Government. The major bid clearly defines the line of the RTS and this must be reflected in all plans, including the BWR SPD and the Local Plan.
1.5.8 Rapid Transport Scheme	object	National Grid Properties Ltd	Here and elsewhere there is reference to a bus-based rapid transport system, also described as "Bath Rapid Transit". However, the Draft SPD does not specify what has been assumed in this respect, both when formulating the spatial master plan and design codes and when assessing the developers contributions set out in Appendix C. Since there is no approved rapid transit scheme at present the Draft SPD should make explicit what has been assumed in these respects	The bus-based Rapid Transit System is part of the Bath Package Major Bid that has been submitted to Government and features in the RFA approved by Government. The major bid clearly defines the line of the RTS and this must be reflected in all plans, including the BWR SPD and the Local Plan.
1.5.9 Sequencing of Development	object	Renrod Motor Group	At paragraph 1.5.9 there is an explicit reference to the relocation and displacement of certain existing uses needing to be planned for and delivered. It goes on to note that replacement of these uses must be addressed through appropriate alternative provision. Renrod object to this on two key points: Firstly, the SPD should be amended to exclude the existing businesses along Lower Bristol Road, in accordance with the findings of the Local Plan Inquiry Inspector's Report; and Secondly, if businesses are to remain within the SPD area, alternative sites must be identified within the SPD masterplan. This is clearly not the case at the present. Renrod's view remains that their businesses should be omitted from the scope if the SPD, as the Inspector's report recommends. It is inappropriate for existing businesses to be subject to the blight associated with the SPD proposals.	The SPD boundary will be reviewed as part of the consideration of the Local Plan Inspector's recommendations relating to BWR. Disagree. As a zonal Masterplan, it is not the role of the SPD to identify the precise location of re-located businesses remaining at BWR, as the SPD does not identify the precise location of any particular development. This role will be carried out by the Context Plans for the particular zones within BWR.
1.5.9 Sequencing Development	object	Argos Retail Group	Paragraph 1.5.9 states that the displacement of 93certain existing uses must be planned for and delivered.94 However, the draft SPD provides no further clarity or certainty as to which businesses will remain and those that are likely to be relocated, and if the latter whether 93appropriate alternative provision94 is in fact available or achievable. Review of whether these businesses should continue to be included within the regeneration area recommended by the Inspector. This review does not appear to have taken place and there have certainly been no recent discussions with ARG concerning the future of the Homebase site. Even though the Council agreed with the Inspector that the future of existing businesses in the BWR should be addressed in this masterplan SPD there is absolutely nothing in the current draft to indicate what existing businesses might now expect as a result of the Council's proposals for BWR. The Council have not made any decisions about the need for large-scale retail allocations within BWR.	The future of existing uses at BWR will primarily be determined by the degree of conformity with the SPD. Submitted proposals and accompanying Context Plans for zones within BWR will provide the appropriate level of detail in determining what provision is made for existing uses to be retained within BWR. Uses being displaced from BWR will be receive support from the Business Relocation Group. The SPD boundary has been reviewed as part of the consideration of the Local Plan Inspector's recommendations relating to BWR.
1.5.10 Comprehensive approach	object	Crest Nicholson	This paragraph should be consistent with the Local Plan Inspector's Report, which acknowledges that the development of Bath Western Riverside is acceptable in phases, provided that it is consistent with an overall master plan.	Disagree. A piecemeal approach is still unacceptable. The SPD sets out a comprehensive zonal Masterplan for BWR, but allows for more detailed masterplanning of BWR to come forward in zones in the form of Context Plans.
1.5.10	object	National Grid Properties Ltd	This paragraph should be consistent with the Local Plan Inspector's Report, which acknowledges that the development of Bath Western Riverside is acceptable in phases, provided that it is consistent with an overall master plan.	Disagree. A piecemeal approach is still unacceptable. The SPD sets out a comprehensive zonal Masterplan for BWR, but allows for more detailed masterplanning of BWR to come forward in zones in the form of Context Plans.
1.5.16-17 Affordable Housing	Object	Westmark	The reference in this Para to housing for key workers is the only mention in the whole SPD. We contend that there is currently no overall strategy, and if there is it is certainly not implicit within the SPD. This begs the question of how an individual scheme can demonstrate that the affordable element forms part of an overall strategy, when that overall strategy is not made clear within the SPD. We would suggest that there is a clear statement on the quantum of affordable housing required overall, the type of affordable housing required, including key worker housing and the level of gap funding available, at least in the short term. It is acceptable that circumstances will change over the next 15 years; however there is a requirement on the local authority to clearly spell out its affordable strategy and level of funding available. Clear reference should be made to housing need data.	Disagree. The overall strategy for affordable housing for BWR is set out in para. 1.5.16 ie. 30% affordable (80% of which is rented), with an element of low cost home ownership products, some key worker housing, some intermediate rented housing, accommodation with care for older people and supported housing for other needs groups. Therefore, individual schemes have to demonstrate how they are contributing to this overall strategy. It is felt that the SPD is sufficiently clear on this subject.
1.5.16 Affordable Housing	Object	Westmark	We are very pleased to see 30% affordable housing provision proposed for Western Riverside. The reference to specific income levels will be out of date very quickly it would be preferable to establish a range of objectives that the Council wishes to meet in terms of affordability, which could then relate back to needs information in terms of the levels of income that LCHO products would be able to meet. There should be more clarity on the tenure on the remaining % over and above the social rented homes as this is vague at present and open to interpretation. There should be some mechanism for defining who keyworkers are and in particular what % of the affordable housing provision can be allocated to key workers. There should be more reference back to housing need.	Insert footnote to para. 1.5.16 in order to future-proof stated income levels. It is felt that the SPD is sufficiently clear on this subject.
1.5.16 Affordable Housing	Object	Somer Housing Group	Pleased to see 30% Affordable housing provision. However, specific income level referred to will quickly out date. Need to look more long term. More clarity needed on the tenure on the remaining % over and above the social rented homes, these are vague at present and open to interpretation. Need to state what % of affordable housing provision will be made for key workers.	Insert footnote to para. 1.5.16 in order to future-proof stated income levels. It is felt that the SPD is sufficiently clear on this subject.
1.5.17 Affordable Housing	Object	Somer Housing Group	Confirmation of the process and timing for the establishment of the affordable housing strategy that will need to be compiled with should be included.	Disagree. The overall strategy for affordable housing for BWR is set out in para. 1.5.16 ie. 30% affordable (80% of which is rented), with an element of low cost home ownership products, some key worker housing, some intermediate rented housing, accommodation with care for older people and supported housing for other needs groups.
1.5.18 Affordable Housing	Object	Somer Housing Group	The level of gap funding should be determined as soon as possible. This paragraph does not explore the consequences if gap funding is not achieved or provide any contingency approach if it is not to the degree that is required. It is appreciated that this gap funding commitment may only be over the timescales that are defined by Government spending and not for the full period of the development.	Para. 3.1.11 states that the Housing Corporation has a key role to play if BWR is to successfully deliver a significant amount of affordable housing on site to meet identified local need. If gap funding is not forthcoming, the delivery of a suitable amount of affordable housing at BWR will not be possible. It is not appropriate for the SPD to set out a contingency approach for circumstances that are contrary to a key objective of BWR.
1.5.18 Affordable Housing	Object	Westmark	The level of this gap funding should be determined as soon as possible. This paragraph does not explore the consequences if gap funding for affordable housing is not achieved or provides any contingency approach if it is not to the degree that is required. It is appreciated that this gap funding commitment may only be over the timescales that are defined by Government spending and not for the full period of the development.	Para. 3.1.11 states that the Housing Corporation has a key role to play if BWR is to successfully deliver a significant amount of affordable housing on site to meet identified local need. If gap funding is not forthcoming, the delivery of a suitable amount of affordable housing at BWR will not be possible. It is not appropriate for the SPD to set out a contingency approach for circumstances that are contrary to a key objective of BWR.
1.5.20 Affordable Housing	Object	Somer Housing Group	This should reference any successors to Housing Corporation Scheme Development Standards and EcoHomes Excellent - given the long development period. There is no reference to life time homes - consideration should be given to whether any should be included within the development.	Agreed. Amend para. 1.5.20 to reflect this.
1.5.20	Object	Westmark	This should reference any successors to Housing Corporation Scheme Development Standards and Eco Homes Excellent - given the long development period. There is no reference to life time homes - consideration should be given to whether any should be included within the development.	Agreed. Amend para. 1.5.20 to reflect this.
1.5.20 Secured by design standard	object	Crest Nicholson	It is not likely that 93Secured by Design94 will be achieved across the development as a whole because of the way in which the standard is operated in practice. The Draft SPD should express 93Secured by Design94 as an objective, not a requirement.	Secured by design is highly desirable in a new scheme and The Council will expect to achieve this standard unless other considerations indicate otherwise.
1.5.21 Affordable Housing	Object	Somer Housing Group	The expectation regarding a 93sustainable community94 should be defined more thoroughly and referenced to current Government expectations and requirements.	The Sustainable Communities definition at para. 1.1.7 came from the ODPM website and, therefore, reflects current Government expectations and requirements.
1.5.22 Business Development	object	Highways Agency	Whilst the Agency support the concept of sustainable mixed use development, we seek clarification that the proposed `sufficient critical mass' of business development will not be seen to such an extent that it would generate significant amounts of in-commuting into Bath which may have an impact on the Trunk Road Network.	The requirement for business development reflects regional planning policy, which is to enhance Bath's role as a centre for business. Employment development is also required alongside the proposed residential development in order to create a balanced community and minimise the need for out-commuting, with consequent impacts on the trunk road network.
1.5.23 Retail development	object	Crest Nicholson	This will need to be reviewed in the light of the Local Plan Inspector's recommendations.	Agreed. Amend para. to reflect updated Local Plan position.
1.5.23 Retail development	object	National Grid Properties Ltd	This will need to be reviewed in the light of the Local Plan Inspector's recommendations.	Agreed. Amend para. to reflect updated Local Plan position.
1.5.23-4 Retail Development	object	Argos Retail Group	Failure to provide any guidance on the future of existing businesses within the BWR. Whilst these paragraphs confirm that retail development will be permitted in the Eastern Zone, they give no indication of its scale and whether this will include existing businesses. In our view and as the Local Plan Inspector recognised, decisions on the need to retain existing retail businesses and on the need for further `bulky' comparison floorspace are a pre-requisite to ensuring that this SPD is a meaningful document and is sufficiently robust and clear so at to provide a proper basis for considering future planning applications.	The future of existing uses at BWR will primarily be determined by the degree of conformity with the SPD. Submitted proposals and accompanying Context Plans for zones within BWR will provide the appropriate level of detail in determining what provision is made for existing uses to be retained within BWR. Uses being displaced from BWR will be receive support from the Business Relocation Group. The extent of retail development to take place within the eastern zone will be established by the LDF.
1.5.25 Infrastructure	object	Crest Nicholson	Appendix C identifies specific on and off site infrastructure. The Draft SPD should make explicit what infrastructure requirements have been identified and on what basis.	The requirements set out are as a result of transport assessments for the site carried out by Consultants on behalf of Bath and North East Somerset Council.
1.5.25 Infrastructure requirements	object	National Grid Properties Ltd	Appendix C identifies specific on and off site infrastructure. The Draft SPD should make explicit what infrastructure requirements have been identified and on what basis.	The requirements set out are as a result of transport assessments for the site carried out by Consultants on behalf of Bath and North East Somerset Council.
1.5.25 Transport Infrastructure	object	Highways Agency	The Agency welcome the recognition of the SPD that the proposals will address the key importance of transportation and access within the site and linkages to the City Centre and other parts of Bath. However, we seek further clarification that the transport impacts on the wider highways network of the development during and post construction are fully considered.	Para. 1.5.25 states that, having regard to the overarching principle of sustainability, development proposals have to demonstrate how they will reduce reliance on the private car encourage usage of alternative modes. The requirement for planning applications to be accompanied by a Transport Assessment is also set out in para. 3.4.5.
1.5.26 Embedded Sustainability	object	Crest Nicholson	It is reasonable to express 93zero carbon94 and 93zero waste94 as aspirations, but they should not be interpreted as absolute requirements.	These are set out as aspirational objectives, and are not set as absolute requirements.
1.5.26 Sustainability	object	National Grid Properties Ltd	It is reasonable to express 93zero carbon94 and 93zero waste94 as aspirations, but they should not be interpreted as absolute requirements.	These are set out as aspirational objectives, and are not set as absolute requirements
1.5.26 - 1.5.29 Embedded Sustainability	object	Highways Agency	Further mention should be made to ensuring that residents and visitors have access to a clean public transport service such as the Rapid Transit mentioned elsewhere in the document.	Reference is made in para. 1.5.44 to the Rapid Transit system providing a more sustainable mode of transport than the private car, as part of the Embedded Sustainability section.
1.5.40 Eco Homes Excellent	object	Crest Nicholson	Whilst it may be reasonable to aspire to Eco Homes Excellent, it is not likely that this standard will be achieved across the whole development and the aspiration should not be applied as a requirement. Eco Homes Very Good standard is generally regarded as an industry-wide deliverable target.	Disagree. It is considered to be reasonable to set the target at Excellent for a development that will take until approximately 2021 to be constructed.
1.5.40 Energy Targets	object	Crest Nicholson	The table at 1.5.40 appears at face value to require 100% of energy to be from renewable sources. Crest submits that whilst committed to a renewable energy strategy, this cannot be the intention behind the policy.	The table applies the Energy Hierarchy to BWR, ie. renewable sources, followed by low carbon, followed by carbon. This does not mean 100% renewable. In fact, the SPD target is 10% minimum.
1.5.40 Renewable energy	object	National Grid Properties Ltd	The table at 1.5.40 appears at face value to require 100% of energy to be from renewable sources. National Grid Property submits that whilst committed to a renewable energy strategy, this cannot be the intention behind the policy.	The table applies the Energy Hierarchy to BWR, ie. renewable sources, followed by low carbon, followed by carbon. This does not mean 100% renewable. In fact, the SPD target is 10% minimum.
1.5.40 Sustainable construction	object	National Grid Properties Ltd	Whilst it may be reasonable to aspire to Eco Homes Excellent, it is not likely that this standard will be achieved across the whole development and the aspiration should not be applied as a requirement. Eco Homes Very Good standard is generally regarded as an industry-wide deliverable target.	Disagree. It is considered to be reasonable to set the target at Excellent for a development that will take until approximately 2021 to be constructed.
1.5.43 Integrated technologies	object	Crest Nicholson	This is inconsistent with the design codes which appear to preclude roof-mounted technologies for townscape and conservation reasons.	Additional phrase to be added to second bullet point in parenthesis to be added to read: 93Roof integrated photovoltaics and solar hot water generation (where these can be successfully integrated into the roofscape by avoiding prominent roof slopes and using internal roof slopes and hidden / screened roof areas94
1.5.44 Embedded Sustainability (transport)	object	Highways Agency	This section should include reference to the concept of developing a travel plan as the site is brought forward. In accordance with national and local policies we would anticipate a commitment to a comprehensive Travel Plan, encompassing all activities on the site. We would also expect the Travel Plan to be supported by a long term monitoring programme together with legally and financially binding commitments to introducing remedial measures if found necessary.	Agreed. New para. after 1.5.45 setting out requirements for Travel Plans.
1.5.47 Sustainable drainage systems	object	The Environment Agency	Although the Agency is supportive of this text, it is felt that greater weight could be given to the incorporation of Sustainable Drainage Systems rather than simply 'investigated', notwithstanding other references to this issue. As you are aware, the Agency is currently in direct contact with the applicant's agent regarding the overall Surface Water Strategy.	Disagree. It is felt that 93investigation94 is the correct level of commitment to be initially required by the SPD, given the known constraint of ground contamination. It must be recognised that the SPD covers the whole BWR area and it should not be confused with the Crest Nicholson application which only covers part of the BWR site.
1.5.47 Water	object	Wessex Water	We support the view that water consumption and the disposal of waste and surface water are important issues. As such we are currently working with the developers' consultant in order to develop strategies to service their requirements. However, as part of the SPD we would expect to see greater commitment towards targets for reducing per capita consumption of water. This could be achieved by reference to installation and use of water efficient appliances, rainwater harvesting for non potable use, and the use of drought tolerant landscaping.	Expand existing para. 1.5.47 to include this.
1.5.49 Public Open Spaces	object	Crest Nicholson	Appendix C identifies standards for on-site and off-site open space provision that appear to have been formulated in abstract and which certainly do not reflect the approach embodied in paragraph 1.5.49. In the absence of a published Green Space Strategy it is difficult to comment further on this issue beyond noting that the body of the Draft SPD and its Appendices should be consistent with one another and should reflect the underlying objective to secure a viable development. Please refer also to related comments in respect of Appendix C.	Appendix C sets out the requirements of the emerging Green Space Strategy.
1.5.49 Green/Open space	object	National Grid Properties Ltd	Appendix C identifies standards for on-site and off-site open space provision that appear to have been formulated in abstract and which certainly do not reflect the approach embodied in paragraph 1.5.49. In the absence of a published Green Space Strategy it is difficult to comment further on this issue beyond noting that the body of the Draft SPD and its Appendices should be consistent with one another and should reflect the underlying objective to secure a viable development. Please refer also to related comments in respect of Appendix C.	Appendix C sets out the requirements of the emerging Green Space Strategy.
1.5.51 Education Provision	object	Crest Nicholson	There is no objective justification to provide a two-form entry primary school as part of the development. This paragraph should be deleted.	Disagree. Expand para. 1.5.51 regarding the justification for a Primary School.
Cllr Furse, Kingsmead Ward	School		The school is proposed to be located on the Lower Bristol road side of the development. For a number of reasons - road pollution, proximity to existing schools the location is not at all suitable. The BWR proposals show green open space and the primary school should be located near to this so as to maximise the open space usage. The schools location should assist sustainable travel as much as possible and it needs to be built early in the development so as to galvanise a sense of community.	The SPD does not provide a specific location for a new school. Requirements for developers to provide a site for a school and contribute towards the cost of a school are set out in Appendix C: Developer Contributions. The timing of the provision of a new school will be the subject of discussions relating to individual development requirements.
1.5.51 Primary school	object	National Grid Properties Ltd	There is no objective justification to provide a two-form entry primary school as part of the development. This paragraph should be deleted.	Disagree. Expand para. 1.5.51 regarding the justification for a Primary School.
1.5 Development Requirements	object	Southgate Limited Partnership & Morely Fund Management	This section of the Masterplan outlines the mix of uses that will be considered appropriate for the BWR area. Indeed paragraph 1.5.5 refers to the need for an `optimum land use balance' to be achieved through the `interrelationship of housing commercial, retail, culture, leisure and community activities'. In light of the inspector's comments (para 7.17-7.22) it is considered that until such a time as the Inspector's comments have been fully considered and the suggested City centre Strategy document produced, it is considered premature and inappropriate to be considering retail development as a possible use at BWR.	Where the SPD, in the role of a spatial Masterplan for the period to 2021, states that it does not rule out additional retail development beyond the current B&NES Local Plan period to 2011, it explains that this is dependant upon the Local Development Framework considering this to be acceptable in future.
1.5.50 page 9 Creation of Cultural Building	Object	The Theatres Trust	The Theatres Trust welcomes the proposal to create a multi-purpose cultural building in the Eastern Zone. Cultural energy and creative activity is the mark of an innovative community, helping attract and retain well-qualified people and businesses. However we would suggest that a needs and impact assessment be carried out to ascertain the level or requirement for theatre provision to be part of the scheme (page 9 1.5.50). Bath is well provided with quality theatres, most notably Bath Theatre Royal and the recently opened Egg Theatre for children.	The Context Plan for the eastern zone of BWR will be expected to be informed by appropriate baseline assessments that determine the quantum and nature of the resulting mix of uses.
1.7.4 Stakeholder involvement	object	Argos Retail Group	Disagree with the statement as no recent contact has been made with ARG by either the council or its development partners.	The engagement strategy undertaken by B&NES Major Projects has involved the processes set out. The publication of the Draft SPD constitutes further stakeholder consultation. Final SPD to reflect this consultation process.
Insufficient engagement with stakeholders 1.7	object	Sainsbury's Supermarkets Ltd	Given the significance of their landholding interest to the outcome of the SPD, there has been insufficient engagement with SSL, as a key stakeholder, to the extent that the formulation of the BWR SPD is discordant with government policy and guidance (PPS12). SSL re-affirms their desire to engage with the Council on the overall masterplan. The overall soundness of the BWR SPD must be brought into question, as it fails to secure community involvement.	The engagement strategy undertaken by B&NES Major Projects has involved the processes set out. The publication of the Draft SPD constitutes further stakeholder consultation. Final SPD to reflect this consultation process.

Objections PART 2: SPATIAL MASTERPLAN


Paragraph/Plan No/Proposal	Support/Object	Company	Comments	Council Comments
Community	(Comment)	Geoffrey Weeks - Widcombe Baptist Church	No provision made for a church within the SPD	Whilst the spatial Masterplan does not specifically propose a site for a church, if a need can be identified, a church can be accommodated as part of the resulting mix of uses at BWR, as long as it can conform to the other principles of the SPD.
Plan 2.1 & paragraphs 2.1.6 & 3.1.4-9 Retained built form, Zonal development and boundary & Scope of Spatial Masterplan	object	Argos Retail Group	Indicates that neither the Homebase nor Argos stores are proposed as 93retained buildings94. Paragraphs 3.1.4-9 appear to state the obvious, that existing uses fall into two categories, namely those that will remain and those that will have to be relocated 93possibly outside of BWR.94	These buildings are proposed to be retained by the SPD as part of the final redevelopment. Para. 3.1.9 makes it clear that, whilst some uses may remain in their existing locations, others will have to re-locate, including outside of the BWR site.
Plan 2.1 Retained built form	object	Renrod Motor Group	Plan 2.1 identifies both of the RMG premises and related land within the 93development zone.94 RMG consider that this is inappropriate and that the Plan must be amended to exclude their premises. 93Retained buildings94 designation added to BMW Wellsway, Mitsubishi and related land owned by RMG. The CPO proceedings would place very significant financial burdens on the BWR proposals.	Disagree. The buildings referred to occupy sites where redevelopment is required. The Council is aware of the implications of potential CPO proceedings.
Plan 2.1	object	St John's Hospital & Bellots Hospital	The SPD should set out more detail about retained buildings and the plans for the area north of the river. Plan 2.1 shows the development zone and retained buildings. The charities would want the Plan to clearly identify buildings/groups by name and produce a schedule in the SPD clarifying this issue.	Disagree. The SPD shows the retained buildings at an appropriate level of detail for the zonal spatial Masterplan. Greater detail regarding the buildings to be retained and the development of land north of the river will be forthcoming in the appropriate Context Plans.
2.1.6 & Plan 2.1 Development site	object	Crest Nicholson	The area of the spatial master plan may change, depending upon the Council's considered response to the Local Plan Inspector's recommendations.	Agreed.
Development boundary (2.1.6)	object	Stones Coaches	Object to the inclusion of their site in the SPD area. They believe that there is no justification for including an existing thriving business with plans which seek to regenerate. If the land is to be included there must be a clear indication that the site will be retained in its current use together with other businesses such as Bath Press on the south side of the road.	Disagree. The site lies within part of BWR identified for redevelopment. The retention of the business within BWR will depend on the extent to which it can comply with the requirements of the SPD.
Development Boundary (2.1.6)	object	Renrod Motor Group	2.1.6 Sets out that the boundary of the masterplan 93coincides with those areas in need of regeneration, and hence it is drawn more widely than the immediately available sites for redevelopment.94 It is unclear how this definition can lead to the inclusion of the RMG sites. The Renrod sites should be excluded from the SPD area accordingly. The Wellsway motor dealership has been the subject of significant investment and, is the subject of a current planning application for a new mini dealership and apartment development. It is not a site in need of regeneration.	Disagree. The Renrod sites currently accommodate low-density uses that are not considered to be appropriate for an edge-of-centre location such as BWR. They are therefore identified for redevelopment. Part of the Renrod landholding, however, is identified in the Summary Masterplan as being suitable for employment-led mixed use. The current Wellsway planning application will be assessed against the requirements of the SPD. Despite the Wellsway site being described as 93not being in need of regeneration94 it is the subject of a current planning application for an additional showroom and residential accommodation. This demonstrates the need for the SPD to control development proposals at this site.
2.1.6	object	National Grid Properties Ltd	The area of the spatial master plan may change, depending upon the Council's considered response to the Local Plan Inspector's recommendations.	Agreed.
2.1.9 Development of the site	object	Renrod Motor Group	At 2.1.9 reference is made to allowing developments at sites to come forward individually. RMG consider that if the only intention of including their land within the SPD is to 93guard94 against the site being developed individually in the future, the Local Plan Inquiry Inspector's findings are clear that this is not a basis for inclusion within planning policy.	Disagree. The Renrod land is included in the SPD area as it is an integral part of BWR, both physically and functionally. The Renrod land, therefore, needs to be covered by the spatial Masterplan for BWR and also the Context Plan for the western zone in order to provide the required development framework for BWR. Within this framework, the Renrod land could actually be developed individually.
2.1.11 Departure from the spatial Masterplan	support	Crest Nicholson	The flexibility which this displays, enabling alternative, well-founded master plan and design solutions to be entertained, is welcome.	Support noted.
2.2.4 Rapid Transport Scheme	object	National Grid Properties Ltd	The Draft SPD should make explicit what has been assumed about the prospective rapid transit scheme.	A Major Bid has been made to Government for funding of the Bath Package, which includes a bus based Rapid Transit System. This package is also included in the RFA approved by Government. The submission fixes the line of the RTS and details all requirements and assumptions. The SPD must accord with this submission.
2.2.5 Vision Statement for BWR	object	Southgate Limited Partnership & Morley Fund Management	Object to statement that the eastern end of the site will be based on a mix of uses with a high proportion of commercial uses. The phrase `commercial uses' is ambiguous. It should be replaced through a Masterplan with recognised terms, or use classes to ensure that the Masterplan is correctly interpreted in the future.	Disagree. As an extension to the City Centre, the eastern zone is an appropriate location in principle for commercial uses. The LDF, including retail strategy, will inform the development mix here. Given the need for future flexibility over the precise mix of development in the eastern zone, which will be determined by the LDF, 93commercial uses94 is considered to be an appropriate term.
Allotment Footpath (Para2.2.3)	Object	Andrew Dickens	The allotments are not part of the Western Riverside Area; they are on the other side of the river. There is already a footpath through the allotments which has been in use for many years and is perfectly adequate. People are already able to walk in a straight line up to the monument on the existing footpath, providing they are not drunk and are sufficiently interested in wanting to do so. There is already a main road, called Marlborough Lane, less than 100 meters from the Victoria Bridge entrance/exit which has its own pedestrian controlled crossing and goes straight up to the obelisk. It has been suggested that the proposed footpath could mean that up to 11 allotments are under threat. I am 28^th on the waiting list and there is a minimum delay of 3 ^BD years already.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	David Cobley	I support the need for pedestrian links. Without those links becoming a ghetto. I do not see the need, however, for a strong vista from Victoria Bridge Road to the Victoria obelisk. The obelisk is of no architectural interest, and there is already a path through the allotments less than 100 metres from the proposed path. Local residents are fully aware of this path and use it regularly. All that is required is better signage to encourage members of the new community to make use of it too. The allotments are an essential amenity that is in full use. Indeed, there is a 3 year waiting list. The proposed path would mean that I and eight or nine other plot holders would lose their plots, some of which have been in cultivation for over thirty years. It would be decimated by another path, and the creation of two new entrances into the allotments would increase the likelihood of theft and vandalism.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Helen Rayner	The path is unnecessary because there is already a perfectly good path up the middle of the allotments between the lower Bristol Road and Victoria Park. I think that people coming from the new Riverside development will be able to cope with the route not being exactly a straight line. I believe there will be a natural flow of movement along it without having to create a new. It is already a perfectly attractive route. There is also the option of walking up Marlborough Lane, also only a few metres away, which has a view of the Royal Crescent as you walk up. The new path is potentially damaging as it will cause disruption to allotments on the site. Local people work hard to maintain these allotments and they help to create the rural environment which, according to the SPD, the council is commendably keen to support. There are also disadvantages to increasing public thoroughfare. My allotment is next to the existing footpath and last autumn some of my vegetables (six pumpkins) were stolen. I suspect that someone saw them from the path and liked the look of them. Obviously that is the risk that allotment holders take, but having another public path from which people can view allotments will only increase the likelihood of produce being taken by passing opportunists.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	James Lee	With two existing paths, one being the footpath past the BOG gardens and the other being the pavement up Marlborough Lane, a third path seems entirely unnecessary. In addition to this argument, all the allotment holders who will be directly affected by the proposed path will be most unhappy to have members of the public in such close proximity, both from the privacy and the security point of view.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Mr & Mrs Donovan	Security - Our produce will be at increased risk of being stolen. Children - At present our child runs freely on the allotment (as many other children do), safe within the gated area. This is not possible if a pathway runs through the allotment. People waiting for plots - there are over 25 people on the waiting list for allotments. This plan will reduce the number of allotments. The plan will reduce the number of allotments available. Financial Implications - Existing paths are merely 50 metres away.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Louisa Dale	The importance of the site in terms of value to the community as a facility, open space and sustainable resource outweighs the value of the path going through the allotments rather that around it. Suitable, equivalent and an accessible alternative site has not been made a requirement in the SPD. Because of the above reasons the development of the path does not meet Policy CF.8 in the B&NES Local Plan and the Inspectors recommendations and therefore: I am seeking the removal of the footpath/cycle path/green link running through the lower common allotments from the Plans and the SPD.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Michale Vastey	This will remove between 10 to twenty allotments from the allotment stock. This is in direct contradiction to the B.W.R Contributions Formulae document which, following national guidelines laid out in National Guidance document PPG17 requires allotments to be provided to a minimum of 2.8 sq.m. Per person with a minimum site size of 1500 sq.m. /10 plot (pages 10/11). There is however a perfectly reasonable alternative in the use of signposting at the end of Victoria Bridge Road, a crossing opposite the existing path is there because it joins with the path running North through the park.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Miss & Miss Barton	What is proposed is really totally unnecessary, as there are already two very adequate north/south access points, in the very near vicinity. It is far more satisfying to discover these landmarks in their intended tranquil setting We have never known the obelisk as being at the top of the visiting list and a knowledge of local history is really needed to appreciate it Security on the allotments is paramount to us, as there have been on going problems pf theft vandalism etc. etc. - adding yet another path and two more gates to be negotiated and kept locked for obvious reasons, must only add to the problems, both of our access and put security, as well as access for necessary maintenance vehicles.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Peter Moylan	There is already a pathway from the Upper Bristol Road through the allotment to Royal Victoria Park coming out near the Prince of Wales oak and also one can walk up Marlborough Lane into Royal Victoria Park. I am also opposed to having a joint cycle/pedestrian path. From my experience walking along the footpath on the north side of the River Avon, one has to look out for dangerous speeding cyclists all the time.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Barbara Walker	There are already two perfectly good routes on either side of the proposed path. The SPD talks of respecting the dynamics of existing communities, yet this proposal does the exact opposite by splitting in half a well functioning existing community.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Lucy Hewson	The proposed path across the Allotment is outside the main Western Riverside site. The proposed path leads to a non-location, a point where you have to turn left or right to get anywhere worthwhile. The western Riverside development will include a large number of new homes. A number of the new residents will wish to have an allotment plot. This will place increased pressure on the existing nearby allotment sites including the Lower Common site at which there is currently a waiting list for plots. The creation of a new path will split the allotment site into two parts. This will damage the community sprit which exists between plot holders, and open up the site to more vandalism and litter.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Mrs Hudnott	This cannot be allowed. There are already two roads, either side of this area of the park, plus a footpath going through the allotments, plus the path that leads through the children's playground. What would be the point of allowing another access point? I'm sure that having Victoria Park on your doorstep will outweigh the fact that the obelisk cannot be seen from a certain point.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Ms Selene-Sayell	The destruction of 10 or more well-tended allotment plots could not possibly be justified in order to create a vista and more direct access to the park. There exists a well used and adequate path meters away from the proposed site. This path goes far more directly into the heart of then open park area and botanic gardens than the proposed route. The destruction of the ten or more plots would cause untold distress to the plot holders concerned. Most of these individuals have tended these allotments for many years and are part of a well established community.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Rachel Rance	The pedestrian routes either side of the allotments are well established and there is no need for such excessive disruption to allotment holders and to the varied wildlife in this area.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Samantha Elwin	The existing path provides an effective north/south link for pedestrians and cyclists and a further one is unnecessary. It would also increase the incidence of theft, vandalism and anti-social behaviour. By making the allotments more accessible this crime would increase and the safety of allotment holders' children be compromised as they are, at present, able to play on the enclosed site in relative safety. Lower Common allotment holders are also an established, diverse community and the proposed route would divide this community in two. The demand for allotments has dramatically increased in recent years and there is currently a three year waiting list for the Lower Common. Parking problems in nearby roads would also be increased as the two on-site parking areas would be lost.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	Object	Mr M Ware	The proposed `path' from the obelisk in Royal Victoria Park seems to just cut the allotments in two and doesn't seem justified when Marlborough Lane is only a few yards away.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	Object	Mrs Jane Selway	There are already perfectly adequate pedestrian routes to the West and East of the allotments.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	Object	Mr Tim Selway	New route would destroy allotments. There are already perfectly adequate pedestrian routes to the West and East.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	Object	Sarah and Susan Targett	There are already two paths Existing to the East and West of the Proposed The existing community will be hugely effected and upset Disturbance to wildlife habitats Reducing plot numbers will increase the already 3 year waiting list Vandalism and theft - already a problem - will increase.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	Object	John Bosnell	Disruption to the community with loss of allotment plots. Already 2 footpaths in use either side of the development.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	Object	Lydia Downey	2 existing footpaths close by. Would devastate the plots and community on the allotments Increase in crime, vandalism and litter pollution Compromises children's safety	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	Object	Keith Stuffins	Easy pedestrian flow routes on existing paths Divided plots will split the community and compromise security of the site	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments	Object	Cllr Furse, Kingsmead Ward	Currently there is an allotment deficit in the City and removing or reducing allotments on the Lower common would be contrary to the City's need to encourage the take up of allotments. In addition no alternative allotment sites have been proposed to serve these new flats. There should be no reduction in allotments on the lower common.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Andrew Dickens	The allotments are not part of the Western Riverside Area; they are on the other side of the river. There is already a footpath through the allotments which has been in use for many years and is perfectly adequate. People are already able to walk in a straight line up to the monument on the existing footpath, providing they are not drunk and are sufficiently interested in wanting to do so. There is already a main road, called Marlborough Lane, less than 100 meters from the Victoria Bridge entrance/exit which has its own pedestrian controlled crossing and goes straight up to the obelisk. It has been suggested that the proposed footpath could mean that up to 11 allotments are under threat. I am 28^th on the waiting list and there is a minimum delay of 3 ^BD years already.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	David Cobley	I support the need for pedestrian links. Without those links becoming a ghetto. I do not see the need, however, for a strong vista from Victoria Bridge Road to the Victoria obelisk. The obelisk is of no architectural interest, and there is already a path through the allotments less than 100 metres from the proposed path. Local residents are fully aware of this path and use it regularly. All that is required is better signage to encourage members of the new community to make use of it too. The allotments are an essential amenity that is in full use. Indeed, there is a 3 year waiting list. The proposed path would mean that I and eight or nine other plot holders would lose their plots, some of which have been in cultivation for over thirty years. It would be decimated by another path, and the creation of two new entrances into the allotments would increase the likelihood of theft and vandalism.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Helen Rayner	The path is unnecessary because there is already a perfectly good path up the middle of the allotments between the lower Bristol Road and Victoria Park. I think that people coming from the new Riverside development will be able to cope with the route not being exactly a straight line. I believe there will be a natural flow of movement along it without having to create a new. It is already a perfectly attractive route. There is also the option of walking up Marlborough Lane, also only a few metres away, which has a view of the Royal Crescent as you walk up. The new path is potentially damaging as it will cause disruption to allotments on the site. Local people work hard to maintain these allotments and they help to create the rural environment which, according to the SPD, the council is commendably keen to support. There are also disadvantages to increasing public thoroughfare. My allotment is next to the existing footpath and last autumn some of my vegetables (six pumpkins) were stolen. I suspect that someone saw them from the path and liked the look of them. Obviously that is the risk that allotment holders take, but having another public path from which people can view allotments will only increase the likelihood of produce being taken by passing opportunists.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	James Lee	With two existing paths, one being the footpath past the BOG gardens and the other being the pavement up Marlborough Lane, a third path seems entirely unnecessary. In addition to this argument, all the allotment holders who will be directly affected by the proposed path will be most unhappy to have members of the public in such close proximity, both from the privacy and the security point of view.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Mr & Mrs Donovan	Security - Our produce will be at increased risk of being stolen. Children - At present our child runs freely on the allotment (as many other children do), safe within the gated area. This is not possible if a pathway runs through the allotment. People waiting for plots - there are over 25 people on the waiting list for allotments. This plan will reduce the number of allotments. The plan will reduce the number of allotments available. Financial Implications - Existing paths are merely 50 metres away.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Louisa Dale	The importance of the site in terms of value to the community as a facility, open space and sustainable resource outweighs the value of the path going through the allotments rather that around it. Suitable, equivalent and an accessible alternative site has not been made a requirement in the SPD. Because of the above reasons the development of the path does not meet Policy CF.8 in the B&NES Local Plan and the Inspectors recommendations and therefore: I am seeking the removal of the footpath/cycle path/green link running through the lower common allotments from the Plans and the SPD.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Michale Vastey	This will remove between 10 to twenty allotments from the allotment stock. This is in direct contradiction to the B.W.R Contributions Formulae document which, following national guidelines laid out in National Guidance document PPG17 requires allotments to be provided to a minimum of 2.8 sq.m. Per person with a minimum site size of 1500 sq.m. /10 plot (pages 10/11). There is however a perfectly reasonable alternative in the use of signposting at the end of Victoria Bridge Road, a crossing opposite the existing path is there because it joins with the path running North through the park.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Miss & Miss Barton	What is proposed is really totally unnecessary, as there are already two very adequate north/south access points, in the very near vicinity. It is far more satisfying to discover these landmarks in their intended tranquil setting We have never known the obelisk as being at the top of the visiting list and a knowledge of local history is really needed to appreciate it Security on the allotments is paramount to us, as there have been on going problems pf theft vandalism etc. etc. - adding yet another path and two more gates to be negotiated and kept locked for obvious reasons, must only add to the problems, both of our access and put security, as well as access for necessary maintenance vehicles.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Peter Moylan	There is already a pathway from the Upper Bristol Road through the allotment to Royal Victoria Park coming out near the Prince of Wales oak and also one can walk up Marlborough Lane into Royal Victoria Park. I am also opposed to having a joint cycle/pedestrian path. From my experience walking along the footpath on the north side of the River Avon, one has to look out for dangerous speeding cyclists all the time.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Barbara Walker	There are already two perfectly good routes on either side of the proposed path. The SPD talks of respecting the dynamics of existing communities, yet this proposal does the exact opposite by splitting in half a well functioning existing community.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Lucy Hewson	The proposed path across the Allotment is outside the main Western Riverside site. The proposed path leads to a non-location, a point where you have to turn left or right to get anywhere worthwhile. The western Riverside development will include a large number of new homes. A number of the new residents will wish to have an allotment plot. This will place increased pressure on the existing nearby allotment sites including the Lower Common site at which there is currently a waiting list for plots. The creation of a new path will split the allotment site into two parts. This will damage the community sprit which exists between plot holders, and open up the site to more vandalism and litter.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Mrs Hudnott	This cannot be allowed. There are already two roads, either side of this area of the park, plus a footpath going through the allotments, plus the path that leads through the children's playground. What would be the point of allowing another access point? I'm sure that having Victoria Park on your doorstep will outweigh the fact that the obelisk cannot be seen from a certain point.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Ms Selene-Sayell	The destruction of 10 or more well-tended allotment plots could not possibly be justified in order to create a vista and more direct access to the park. There exists a well used and adequate path meters away from the proposed site. This path goes far more directly into the heart of then open park area and botanic gardens than the proposed route. The destruction of the ten or more plots would cause untold distress to the plot holders concerned. Most of these individuals have tended these allotments for many years and are part of a well established community.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Rachel Rance	The pedestrian routes either side of the allotments are well established and there is no need for such excessive disruption to allotment holders and to the varied wildlife in this area.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Samantha Elwin	The existing path provides an effective north/south link for pedestrians and cyclists and a further one is unnecessary. It would also increase the incidence of theft, vandalism and anti-social behaviour. By making the allotments more accessible this crime would increase and the safety of allotment holders' children be compromised as they are, at present, able to play on the enclosed site in relative safety. Lower Common allotment holders are also an established, diverse community and the proposed route would divide this community in two. The demand for allotments has dramatically increased in recent years and there is currently a three year waiting list for the Lower Common. Parking problems in nearby roads would also be increased as the two on-site parking areas would be lost.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotment Footpath (Para2.2.3)	object	Mr M Ware	The proposed `path' from the obelisk in Royal Victoria Park seems to just cut the allotments in two and doesn't seem justified when Marlborough Lane is only a few yards away.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	object	Mrs Jane Selway	There are already perfectly adequate pedestrian routes to the West and East of the allotments.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	object	Mr Tim Selway	New route would destroy allotments. There are already perfectly adequate pedestrian routes to the West and East.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	object	Sarah and Susan Targett	There are already two paths Existing to the East and West of the Proposed The existing community will be hugely effected and upset Disturbance to wildlife habitats Reducing plot numbers will increase the already 3 year waiting list Vandalism and theft - already a problem - will increase.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	object	John Bosnell	Disruption to the community with loss of allotment plots. Already 2 footpaths in use either side of the development.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	object	Lydia Downey	2 existing footpaths close by. Would devastate the plots and community on the allotments Increase in crime, vandalism and litter pollution Compromises children's safety	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments Footpath (Para2.2.3)	object	Keith Stuffins	Easy pedestrian flow routes on existing paths Divided plots will split the community and compromise security of the site	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments (Para2.2.3)	object	Helen Woodley - Allotments Association	Lower Common is one of Bath's earliest statutory allotment sites, acquired for the purpose in 1918, part of the heritage of out World Heritage City, and given special mention in the 2005 adopted Bath city-wide Character Appraisal as a key component of the area's open space. We are told that it will establish a strong relationship with Victoria Park to the north for both new and existing residents. But there are already two such routes: up Marlborough Lane; and up the existing path that separates Lower Common East from Lower Common West. The existing path actually provides more direct access to the park from the south than the proposed route does. I measured the distances on a map as 300m for the proposed route and 220m for the existing one. A planning officer independently measured the distances as 295m and 240m respectively. It is also clear that the existing path would be likely to cope adequately with the additional footfall generated by any new developments. It coped well enough on the night of the three tenors' concert, as several of us can witness. We have a disables member who affirmed it is suitable for disables persons' use. There is also wide concern that any partial destruction of the conifer line could disrupt a crucial bat flight path. Bats roost in the conifers.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments (Para2.2.3)	object	Lower Common Allotments Association	Better signage would enhance the use of the existing footpaths, and new residents could be informed of the existing access routes through a welcoming pack or leaflet mapping the green spaces in the area. Ten Plots would be lost and the tranquillity and enclosed peace of the allotments disturbed. The plots are fully occupied, and according to the council's own website there is a three year waiting list. Adding two more entries to the site would inevitable increase the current problems of night-time vandalism and decrease the safety of the many young children who accompany their parents to garden during daytime hours.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments (Para2.2.3)	object	Tim Baines - Bath Organic Group	The proposed new footpath (and cycle way) which dissects the allotments would displace up to 11 allotment holders and break up a thriving community. Is it merely coincidence that this footpath is actually the boundary of the statutory allotments - those to the East of the line do not enjoy the same level of protection as those to the West? Lower Common is a valuable green space and community asset that should be recognised by B&NES. If another North/South linkage is needed I would suggest that a footpath should be located between the children's play area and the allotments on the Western boundary.	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Allotments (Para2.2.3)	object	Bath Preservation Trust	It creates unnecessary interference with and disruption to the allotments and their enjoyment. The present arrangements of access from within Victoria Park is far preferable	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Plan 2.3 Redevelopment of zone 1 site	object	Sainsbury's Supermarkets Ltd	As it is now clear that the Council wants to redevelop the Sainsbury's store site for alternative uses, SSL is concerned that the BWR SPD does not make specific provision for a replacement foodstore (merely stating that it should go `over the river'). This concern has been compounded by the inability, to date, of the Council to demonstrate that there is a reasonable prospect of relocating the store in a manner that would be satisfactory to SSL from a commercial perspective. The upshot of this is that serious doubts must be raised over the deliverability of significant parts of the BWR masterplan, and that these doubts will remain until such time that a suitable and deliverable relocation site is secured for SSL.	The key objectives of the SPD are indeed reliant upon the redevelopment of the existing Sainsbury's store site, particularly with regard to enhancing connectivity between BWR and the City centre, providing a high quality piece of public realm adjacent to the river, and enhancing the setting of Green Park Station. The existing Sainsbury's site cannot be developed or even planned in isolation, however, as the requirement to produce a Context Plan for the entire eastern zone means that proposals for the existing Sainsbury's site must be proposed alongside the remainder of the eastern zone ie. the likely replacement Sainsbury's foodstore.
Plan 2.3 Summary Masterplan	object	Renrod Motor Group	The BMW Wellsway dealership is identified for 93employment led mixed use.94 This proposal is simply reflective of the existing pattern of uses on the site and those proposed through the current RMG planning application. It is unnecessary to include BMW Wellsway premises within this land designation and the area should be excluded as a whole.	The identification of the Wellsway site as part of the employment-led mixed use part of the Masterplan area has taken into account the desire of the current business to remain at the site and expand. Due to the site's integral relationship with the remainder of the BWR area, which is also north of Lower Bristol Road and east of Windsor Bridge Road, and with the proximity of the identified route of the rapid transit, it is considered that the Wellsway site should remain within the BWR site, with future development proposals there guided by the SPD.
Land use designation for SPD site (Plan 2.3)	object	Stones Coaches	Stones have fundamental objections to their site being defined as being within residential led mixed use area. Stones Coaches have no intention of releasing their premises for redevelopment for residential or other uses. It is therefore inappropriate for the Masterplan to blight the site by this designation. The proposals as currently drafted create blight for existing businesses which as the Local Plan Inquiry Inspector has noted should be excluded in any event.	The role of the SPD Masterplan is to identify how BWR can be redeveloped in order to achieve the optimum use of land in a sustainable location. It is therefore appropriate for the Masterplan to identify new uses for existing sites that are currently occupied by inefficient uses of urban land in sustainable locations. The Local Plan Inspector's recommendations seek to accommodate businesses that are 93compatible with the redevelopment scheme94, however, the coach depot is not considered to be compatible with a high-density mixed-use redevelopment.
2.12.2-3 Zonal Masterplan: Land use	object	Argos Retail Group	Continuing lack of certainty and security as to the future of existing businesses is unacceptable and undermines any confidence or weight that can be attached to the SPD. These paragraphs suggest that the composition of land uses and the scale of retail development in the Eastern Zone is more 93flexible94 and will be determined through further work and the production of the Local Development Framework. In our view, this simply ignores and delays important decisions, which must be made now as part of the production of this draft. Paragraph 2.12.2 also implies that the role that the Eastern Zone will play in the future of Bath has not yet been determined. If this is so, then why is this area included in the draft SPD? A clear example of the SPD's inability to address fundamental questions about existing businesses and the future of this Zone is given in the following paragraph (2.13.3) which merely states that proposals for the Green Park Station area will 93require Sainsbury's moving across the river.94 However, no alternative site is allocated at BWR or in the SPD and the availability of any potential alternative sites to accommodate a store of this scale and format must seriously be questioned. The Local Plan Inspector had considerable sympathy for existing businesses due to the fact that the Deposit Local Plan failed to provide any indication of whether they were to remain or be moved out of the area completely. The inspector recommended that a 93clear indication to existing businesses what they might expect as a result of proposals for BWR94 should be given. The Council have not addressed or responded to the Inspectors recommendations. Paragraph 1.1.13 merely states that the draft SPD was published before the Inspectors Report was available and that the Reports' recommendations will be taken into account before the SPD is adopted. In our view, the Inspectors recommendations are so fundamental to proposals for the Eastern Zone, that the draft SPD should be withdrawn to allow a thorough and proper review, and then re-issued for a further 6 week consultation period once the Council has responded in detail to the Inspectors specific recommendations.	It is considered essential that the Eastern Zone remains as part of BWR in order to connect the Western Zone with the City Centre. As the part of BWR nearest to the City Centre, the Eastern Zone is more likely to have a role to play regarding a potential extension to the City Centre. However, the extent to which the Eastern Zone can do this including, for example, the quantum and nature of retail that should take place, will only be established once key areas of work related to the LDF have been completed. It is, therefore, not possible or appropriate to provide greater certainty at this stage. Informed by this work, more detailed masterplanning of the Eastern Zone, leading to the Context Plan for this zone, will determine solutions such as a replacement site for Sainsbury's. The future of the Eastern Zone within BWR has been considered as part of the Council's consideration of the Local Plan Inspector's recommendations. The result of this is that the Eastern Zone remains as part of the SPD area.
Plan 2.3 Summary Masterplan	object	Renrod Motor Group	The Mitsubishi dealership is defined as being within a residential led mixed use area. RMG have no intention of releasing the Mitsubishi premises for redevelopment for residential or other uses. It is therefore inappropriate for the masterplan to blight the site by this designation. The Mitsubishi land and the other businesses along Lower Bristol Road should be excluded from the proposals.	The role of the SPD Masterplan is to identify how BWR can be redeveloped in order to achieve the optimum use of land in a sustainable location. It is therefore appropriate for the Masterplan to identify new uses for existing sites that are currently occupied by inefficient uses of urban land in sustainable locations. The Local Plan Inspector's recommendations seek to accommodate businesses that are 93compatible with the redevelopment scheme94. The extent of car dealerships that currently exist along Lower Bristol Road is not considered to be compatible with a high-density mixed-use redevelopment, therefore, the eastern portion of these is proposed for redevelopment.
Plan 2.3 Summary Masterplan	object	Renrod Motor Group	The indicative line of the Rapid Transport Route appears to include land owned by RMG, linking the Mitsubishi dealership with BMW Wellsway and providing for car storage essential to the efficient running of the two businesses. Again, there is no prospect of this land being released by RMG.	The Bath Package Major Bid fixes the line of the RTS, in accordance with the submitted drawings, and this must be reflected in the SPD. There is no option to vary the line in the SPD and the necessary land will be obtained using relevant powers.
Plan 2.3 Summary Masterplan	object	Renrod Motor Group	If the Rapid Transport Route is to be shown through the site, its route should be amended to exclude RMG land.	The Bath Package Major Bid fixes the line of the RTS, in accordance with the submitted drawings, and this must be reflected in the SPD. There is no option to vary the line in the SPD and the necessary land will be obtained using relevant powers.
Plan 2.3 Summary Masterplan & 2.4 Key Organising Principles	object	Southgate Limited Partnership & Morely Fund Management	Object to these elements of the SPD. The eastern zone is illustrated here with mixed use material other than that described as `local retail' and shown in the western zone, both to the east and west of the river for some considerable distance. This is not acceptable. Retail development should not be included in the Masterplan. Furthermore, the vast area shown on the Masterplan as suitable for retail development extends unacceptably far. Should retail development be considered acceptable in a future revision of the Masterplan, this must be located where it can support the role and function of the City Centre and should not be allowed to spread for some distance out of the City Centre creating an entirely new retail destination.	Disagree. Paras. 1.5.23 & 1.5.24 of the SPD (Retail Development) set out that the SPD does not make specific provision for significant retailing at the site. Where the SPD, in the role of a spatial Masterplan for the period to 2021, states that it does not rule out additional retail development beyond the current B&NES Local Plan period to 2011, it explains that this is dependant upon the Local Development Framework considering this to be acceptable in future.
2.2.4 Rapid Transit System	object	Crest Nicholson	The Draft SPD should make explicit what has been assumed about the prospective rapid transit scheme.	A Major Bid has been made to Government for funding of the Bath Package, which includes a bus based Rapid Transit System. This package is also included in the RFA approved by Government. The submission fixes the line of the RTS and details all requirements and assumptions. The SPD must accord with this submission.
2.1.2	object	Argos Retail Group	Paragraph 2.1.2 suggests that the aim of the SPD is to provide a 93degree of certainty94, which is certainly not the case for existing businesses.	It is considered that the SPD provides as much certainty as is possible and appropriate given the role of the SPD as a spatial Masterplan for BWR for the up to 2021.
2.2.10 Vision	object	Crest Nicholson	This is superfluous. It duplicates paragraph 2.2.7.	Omit paragraph 2.210
2.3.1 (9) Design Principles	object	Crest Nicholson	This grossly overstates the visual influence and likely visual impact of the development.	Disagree. BWR has a valley floor location, in a City where there are extensive views from surrounding hills.
2.4(3) Rapid Transit System	object	Crest Nicholson	The Draft SPD should make explicit what has been assumed about the prospective rapid transit scheme.	A Major Bid has been made to Government for funding of the Bath Package, which includes a bus based Rapid Transit System. This package is also included in the RFA approved by Government. The submission fixes the line of the RTS and details all requirements and assumptions. The SPD must accord with this submission.
2.4(9) Key Views	object	Crest Nicholson	Plan 2.9 illustrates that the site is not 93exposed to views from all around the city94.	Disagree. The viewpoints on Plan 2.9 are a selection of viewpoints, and these are taken from many locations from around the City, many of them being at elevated, hillside locations.
Plan 2.4 Public Realm Typologies	Object	Westmark	Currently the developable areas to the north and south of the river are shown as shared space. There is no definition of shared space and one has to question how one can develop these areas as well as providing them as shared spaces. Clarification on this issue is required.	The plan needs to be read in conjunction with the other plans for the area. The shared space designation includes buildings.
Plan2.5 Trees	Object	Dr James Dodson	Trees are important to screen the new development visually and importantly, to reduce the noise. The new Plan (Spatial Masterplan Part 2, Plan 2.5 The River Corridor, page 24) seems to include our trees as part of the Urban River Quarter.	Existing trees are important features that have a positive role to play in the redevelopment of BWR.
Noise	Object			The redevelopment of BWR will inevitably result in additional noise. The redevelopment of this site is necessary as explained previously and reasonable mitigation will be provided.
Noise	Object	Charlotte Laurence	Placing a six to eight storey strip of bars and residents within meters of a residential area will seriously reduce the quality of life for residents. Increase noise and disturbance for a relatively densely populated residential area (between 5 and ten households per building). Such is the angle of the Crescent that residents will be disturbed by noise at both the front and back of the building.	It is envisaged that only the ground floor, and potentially first floor, of the commercial buildings will be used for food and drink uses, and these will probably include new residential units on upper floors. The location of food and drink uses, and mitigation measures, will be identified through the production of Context Plans and individual development proposals.
2.6.1 & 2.6.2 The River Corridor policy	object	The Inland Waterways Association	You accept here that the river is currently underused. It is likely to stay that way unless and until you make it attractive for boaters to use. Waterways need boats to bring them to life. Boaters will not use the river or more importantly stop unless moorings are provided with facilities to attract them ashore. When Stothert and Pitt had the same site and the Gas Works was operational boaters traversed through as quickly as possible. The same is now true with the new development. The words `lost opportunity' come to mind. In this case not only will the boating community miss out but so too will the residents and commercial enterprises who are to occupy the site and pay their rates and taxes. A trough between the steel sheet piles may not be their idea of a waterside location. Please consider what other towns and cities have made of their waterways. Birmingham, Bristol, Banbury, Oxford, Newbury and even Reading through the Oracle Shopping Centre are examples. It has been said that the Western approach to Bath is worse than to Wolverhampton. It will not be much better after many millions of pounds have been spent. Consider also the splendid and much admired approach by the Kennet ad Avon canal.	Introduce an additional bullet point at 2.6.4, under River Design Principles Development along the river frontage must accommodate and encourage river traffic. Expand advice within the Design Codes to address specific requirements of river traffic.
2.6 The River Corridor policy	object	English Heritage	It is desirable that the River Corridor character area be part of a city wide strategy for the river. We understand that some work in this respect may already have been carried out by the Council and we would urge that a comprehensive and integrated approach to the treatment of this important resource be pursued.	Noted. At present, however, such a strategy does not exist to assist the production of this SPD.
2.6.4	object	The Inland Waterways Association	All of your other sketches simply show the development sitting back from and looking down into the trough formed by the steel sheet piles. This situation fails completely to meet your and other admirable intentions. Indeed one of the bullet points in para. 2.6.4 specifically on the suggestion of adjusting levels adjacent to the waters edge along a public amenity strip on the river's south bank.	Sketch and Cross-section on Page 21 of SPD demonstrate how the river bank can be cut back to allow immediate access to river.
2.6.4 (point 15) Steel sheet piling	object	The Inland Waterways Association	Object to the `get out clause' as to the retention of the steel sheet piling.	It would be impractical to require the entire sheet piling to be removed throughout BWR.
2.6.4 (point 15) Steel sheet piling	object	The Inland Waterways Association	Strongly object to the apparent acceptance that nothing is going to be done to introduce the `stepped tow path' arrangement that is such a success outside the Rugby Ground below Pulteney Weir. The only place where there is any commitment to lower the capping beam to the steel sheet piling is to the boat dock which appears to be the one and only concession to allow boats on the river to gain entry into the proposed development.	Disagree. The SPD seeks a variety of treatments to the riverside, refer to 2.6.4 and the River Design Principles.
River Design Principals 2.6.4	object	The Environment Agency	It must be noted that any removal of piling will need to be carried out in complete sections following a detailed study to prove that the integrity of the bank will not be compromised, and that there will be no impacts on the function of the Agency's gauging station. Mitigation against loss of flood storage will need to be provided, together with a suitable maintenance access strip. It is important to note that the "Twerton Watercourse" which is a designated Main River, runs across the site and will need to be fully considered as part of any plan for the site.	Amend SPD to reflect these points in new Section 2.14 Drainage and Flooding.
Undefined commercial area - City end of site.	(Comment)	Cllr Furse, Kingsmead Ward	The more detailed plan requested, which will establish the quantum, nature and location of bars and restaurants, will be provided in the future in the form of the Context Plan for the Eastern zone, and also through individual development proposals. It is not appropriate for the SPD to provide this level of detail at this stage.	I am concerned that mistakes with the Canary Wharf development will be repeated, by locating bars and restaurants directly opposite residential property some of which contains a significant amount of social housing. At Canary Wharf it has been acknowledged that placing modern bars opposite some of the least well off in society creates and exaggerates the social divide. Nearly all of Bath has a mixture of housing within adjacent streets or even on the same street. I believe this gives a diversity and richness to Bath as a place to live. A more detailed plan is needed to allow residents to be aware what is to be on their door step.
2.6.11 Natural Edge	Object	Westmark	This introduces the idea of a two tier riverside walkway on the northern edge of the river. It should be made clear that the existing towpath provides an extremely useful and well used river walkway/cycleway linking different parts of the city. To create a further public terrace at a higher level will serve very little purpose. We suggest that the idea of an upper level public terrace is deleted from the SPD and a more generic objective is put in place concerning making links between the existing and improved towpath route and adjacent streets.	This section applies only to the southern bank. See 2.6.11 of the SPD.
2.7 Consideration of the Local Plan Inspectors Report Proposed Zones and the construction framework Density Listed Buildings and Conservation Area Flood Risk	Object Object Object Object Object Object	Bath Preservation Trust	The Draft SPD takes no account of the Inspector's Report findings into the Local Plan. The Inspector attached considerable importance to the principle of comprehensive development (Report paras 5.64 - 5.75). Paragraph 5.69 should be considered in the SPD. We note that there is a contradiction between the acceptance of the comprehensive development principle (1.5.1) and the Phasing Strategy on p48. If adopted Zone 2 (Western Zone - currently Crest Nicholson) is scheduled to be developed before Zone 1 (Eastern Zone), the letter cannot be dealt with in isolation. The Eastern Zone is fundamental to the success of the whole regeneration project; it is a gateway to the Western Zone. We question the figure of 3000 dwellings, particularly when compared with figures in the Emerging Local Plan and the Inspector's Report. This averages out at over 85 dwellings per hectare on the total site of 35 hectares. High density does not mean high rise - see, for example CABE's Better Places to Live (HMSO 2001), Isledon Village in London (near Islington) where they achieved a density of 73 units per hectare (p 100). In its introduction, the draft Regional Spatial Strategy states that `the South West must remain a region with a beautiful and diverse environment', and quotes one of the five headline aims as being `to enhance our distinctive environments and the quality and diversity of lour cultural life'. It should not be forgotten that Bath is a premier tourist destination and that any proposal which prejudices this should be treated with extreme caution. In relation to townscape, it is out view that continuous street frontages would be more in keeping with the character of Bath than stand-alone blocks. We note the statement that `Bath has a strong tradition of excellent corner buildings, this must be continued in the BWR area' (see 2.10.2). We also urge B&NES to avoid great variation in building heights; fairly uniform heights of 3 or 4 storeys would be more in tune with the Bath tradition. The massing of buildings in the Western zone would already dominate the area - a coarser grained solution would be totally inappropriate for the city. We object to the statement on the City Extension that the area should have a `coarser grain' than the residential areas to the West (p.30). PPG15 requires the Planning Authority to respect the setting of listed Buildings. The draft SPD does not guarantee the setting of Norfolk Crescent (listed Grade 1), nor the adjacent group of listed buildings. We support the cogent objections made by the Norfolk Crescent Green Residents Association. Other Grade 2 listed small terraces about the Western Riverside. Extreme care must also be taken to respect their setting. We refer B&NES to the Inspector's Report on the George Yeo site in this regard. Developments which could be sanctioned under the draft SPD as it presently stands could detract from the Conservation Area, particularly the Norfolk Crescent area. Not convinced that the development of the Western Riverside is consistent with PPG25. We would like the Environment agency to declare that it is satisfied in relation to the flood risk.	It is agreed that the Inspector supported the principle of comprehensive development, however, at para. 7.15 of her report she states that, once the SPD is in place, its is difficult to see any reason why individual developers / landowners should not bring forward their sites to be progressed in accordance with the principles of the strategic framework and spatial Masterplan. The SPD facilitates this approach. The final capacity of BWR will be determined by individual development proposals that have to be assessed against the SPD Spatial Masterplan. The principles that maintain the character and tradition of Bath should be ensured by the SPD Spatial Masterplan. It is considered that BWR, as a relatively flat site on the valley floor can accommodate an appropriate range of building heights. As an extension to the City Centre containing commercial uses, it is considered that it would be appropriate for the eastern zone of BWR to have a coarser grain than the western zone, which will be mainly residential. The SPD describes the south bank of the river in this area as the 93Urban River Quarter94 with public and commercial activity fronting onto the public realm creating a new high quality river promenade. Because the Masterplan is zonal, the precise quantum and nature of commercial uses in this area is not defined within the SPD. More detailed masterplanning, required for the Context Plan for the Eastern zone, will establish more detailed parameters for this development, followed by individual development proposals. Mitigation of the likely impacts on existing residents can be considered in more detail at these later stages, and stakeholders will be consulted as the process develops. It is not considered to be appropriate, therefore, to amend the SPD with regard to this matter at this stage. Flood risk issues to be dealt with in new section after 2.13 called Drainage and Flooding.
Listed Buildings Flood Defences	Object Object	Norfolk Crescent Residents Association	Of particular concern is the damaging impact that the scale of the development, especially the two blocks proposed at the eastern end of the Phase 1 site, will have on the historic buildings grouped in this locality, of which Norfolk Crescent is Listed Grade I. It is disappointing that SPG 3.2.2 concerning the setting of individual buildings and groups, in particular the reference to Norfolk Crescent, seems to be disregarded. The design criteria of 1: 100 applied to the Bath Flood Defence Scheme is no longer to current standards and takes no account of climate change. It is evident that 1:100 protection is not afforded everywhere in Bath, hence the identification of flood cells. Given that some of this area is within a flood cell and already at higher risk, without additional protection this part could be flooded as a result of any event just slightly more extreme than that in 2000. This seems confirmed by inclusions in the FRA of the flood zone map provided by the EA (paragraph 3.2) based on a 1:100 year + 20% increase in flood flows due to climate change and in Appendix E, `Floodplain for 1 in 100 year (plus 20%)`storm' plan. We consider rather than a piecemeal approach currently dictated by the planning application for Phase 1, it would be more appropriate that an immediate review of planning policy is undertaken before land is assembled for the remainder of the site towards providing a river corridor strategy to achieve funding of enhanced protection by the developers for third party properties as was originally proposed.	Response subject to further assessment. Flood risk issues to be dealt with in new section after 2.13 called Drainage and Flooding. Noted. At present, however, such a strategy does not exist to assist the production of this SPD. It would not be appropriate to further delay the production of the SPD.
Design		The Bath Society	Development of the Bath Western Riverside land ought to be such that it enhances the World Heritage site and not only by bringing a significant derelict part of the city back into positive use.	It is considered that the SPD reflects this aspiration.
Design Codes (2.7)	Object	Anthony Pearson	Why must all windows have a vertical emphasis? These rules out square windows. Why must all facades have more solid than void? Has no-one seen some excellent Dutch housing which has more void than solid? Apart from a mansard roof what is another proper roof form? Not understood. An allowance has to be made for all concealed external spaces? What does that mean? Why must road names be carved, and if they are not why must the buildings have string courses?	The Design Codes would benefit from further illustrative material to explain these points.
Design Codes (2.7)	Object	Charlotte Laurence	It is vital that traditional local materials of Bath stone, slate, clay tiles, pennant stone etc predominate.	The materials schedule in the Design Codes propose that such natural materials predominate, whilst allowing for carefully controlled alternative materials.
Design Codes (2.7)	Object	Mr M Ware	Most of the housing looks like 1960's high-rise blocks of Lego-style design, overpriced and suitable only for single business-people.	The SPD does not propose specific building designs. This appears to be a comment related to the planning application submitted by Crest
2.7 Character Areas	object	Southgate Limited Partnership & Morely Fund Management	More detail should be provided in this section in relation to Green Park Station, the Civic Area & the Commercial area. More detail should be provided in relation to the uses that will be acceptable and how it is anticipated that the redevelopment of green park station for `craft and design products' will be controlled to ensure this, alongside other proposed uses, does not impact on the existing city centre.	Disagree. Given the uncertainty over the precise development mix in the Eastern Zone, given the need to establish the future retail position through the LDF, it is considered that this section provides an appropriate level of detail.
Plan 2.7 The Western Neighbourhood	support	Renrod Motor Group	Exclusion of the BMW Wellsway business from the plan.	Support noted.
Plan 2.7 The Western Neighbourhood	object	Renrod Motor Group	The plan should be amended further to exclude the Mitsubishi dealership.	Such an amendment would be contrary to the Summary Masterplan (plan 2.3).
2.7.23 Design Principles	object	Crest Nicholson	References such as to 93the bus stop94 are unduly prescriptive for a document setting out general design principles prepared in a context where there is no specific rapid transit scheme to make reference to.	Disagree. It is an important principle that community facilities should be located in close proximity to the bus stop on the rapid transit route.
2.7.7 Design criteria for city extension	object	Sainsbury's Supermarkets Ltd	The design criteria set out in the SPD for the City Extension (the eastern end of BWR) acknowledge that the area will need to accommodate large-footprint buildings but there is no meaningful appreciation in the SPD of the importance of the commercial requirements of potential new and relocated occupiers, including access, parking, and servicing arrangements. Such matters are fundamental to the viability and deliverability of this part of BWR.	Respect for the grain of the City is paramount and the commercial requirements set out will have to be integrated into this. Compromises on both sides are inevitable.
Design Codes (Whole site - lighting)	Object	Campaign for Dark Skies - Michael Tabb	Consider use of light shields Implementation of light curfew Avoid feature lighting of trees Avoid Riverside lighting - unsettles wildlife and the natural reflection upon water	To be considered when Design Codes are reviewed.
2.7.21-22 Western Neighbourhood	Object	Westmark	The expectation regarding a 93sustainable community94 should be defined more thoroughly and referenced to current Government expectations and requirements. This paragraph implies that a density in excess of 86 dwellings per hectare across the Riverside neighbourhood will be required. This is based on predominantly small flats and apartments. There should be a link between providing the 3000 dwellings, the density envisaged and the proposed height. The SPD does not appear to explore these issues in any detail.	The definition of the sustainable community being sought for BWR is set out in paras. 1.1.6-7 of the SPD, including reference to Government guidance. The height policy set out in the SPD takes into account the capacity of the site to accommodate approximately 3000 dwellings.
2.7.26 Embedded Sustainability	Object	Westmark	We endorse the Active River Frontage objective fully. However, in Para 2.6.4 there is a statement that development should be at 90BA to the river edge in order to continue the contextual tradition. In order to maximise active river frontage, it is our view that development should have face the river and not continued to turn its back on the river as has been the historical tradition of Bath. We suggest that at least the development on the northern bank is allowed to face the river, thus providing over-looking views and activities.	The reference to development being at 90 degrees to the river edge is made solely to the northern bank, on the grounds of context, as explained by the SPD, and relates to only 93some94 and not all of the development. The northern bank lies within the Bath Conservation Area, where appropriate respect for context is particularly relevant.
2.7.29 Lower Bristol Road	object	Renrod Motor Group	Recognises the mix of uses along Lower Bristol road, but makes no reference to the retention of these. This should be amended.	The SPD deliberately does not restrict the mix of uses to be provided through the retention of existing uses, the mix can be provided through redevelopment.
2.8.1 Block Resolution	object	Crest Nicholson	The critical dimensions within the design codes must be applied flexibly in order to allow for the variety of types of residential building encouraged elsewhere in the guidance.	Block sizes are flexible. Street widths in the design codes are given to allow for servicing and access. It is possible to vary from the street widths if a case is made and access is maintained.
2.9.1 Location	object	Crest Nicholson	9385can be seen from virtually everywhere94 is a gross exaggeration.	Amend 2.9.1 to refer numerous viewpoints around the City, especially from elevated hillside locations.
Plan 2.10 Scale, Height & Massing	object	Renrod Motor Group	Includes RMG owned land. Renrod consider their business premises should be removed from the Masterplan area.	For reasons set out above, this land will remain within the SPD area.
Plan 2.10 Scale, Height and Massing	object	English Heritage	Concern over the range of heights for the development proposed in terms of the impact that this could have on the historic character city as a whole and in particular its World Heritage Site status.	Rephrase the advice in the SPD to better meet concerns of English Heritage, as follows: Paragraph 2.9.2 93To carefully reflect the distinct roofscape of the city it is important that heights are not consistently applied across the site, or across development blocks. In fact the reverse is required. The skyline of the development needs to display variety across the site and within blocks, with a mixture of heights, scales and roof treatments.94 Add additional note to plan 2.10 933. This plan shows a broad range of floor heights for each zone, it is not acceptable for all the development within each band to be at the highest end of the range. It is essential that variety in height is introduced in the roofscape to reflect the traditions in the city. 93 .
2.9 Building Height	Object	Bath Preservation Trust	Bath has no detailed tall buildings policy (sww2.9.5). Reliance must therefore be placed on the general policies of the Emerging Local Plan relating to scale, height and massing. The recognition that other tall buildings that have been developed have harmed the integrity and balance of City views should also be noted (see 2.9.3). The World Heritage Site Management Plan has not been given sufficient emphasis in the Draft SPD. There are references (e.g. pp.13 and 16) but these are quite inadequate. The comparison with the height of the current gas-holders (see2.9.4) should be resisted as irrelevant. The Design Code should be amended so as to exclude buildings of more than 4 storeys.	Response subject to further assessment. Agree. Revise SPD to include the Outstanding Universal Values of the WHS, and acknowledge the important role the site must play in achieving the aims of the WHS management plan. Include reference to World Heritage Site Management Plan in Strategic Framework of SPD. Develop a stronger link in the text between WHS status and the Vision for BWR at 2.2, and include in 2.3, Overarching Design Principles as part of item 6. It is considered that this paragraph describes the impact of the gasholders in a balanced way. The heights policy is subject to further assessment.
Building Height	Object	Norfolk Crescent Residents Association	Proposals for two eastern blocks or 93Palazzos94 of 7 - 9 storeys are especially worrying and would dominate and overshadow our environment. The proposed building heights of 5-8 floors in the Special Planning Document are inconsistent with the buildings of this World Heritage City which are predominately four storey plus basements.	This appears to be a comment related to the planning application submitted by Crest.
2.9 Building Height	Object	The Bath Society	The plans forming the basis of the outline planning application by Crest Nicholson are, frankly, terrifying. The proposed scale, heights, massing and layout of the buildings have caused this to be so. The traffic and parking implications are also to blame. The relevant Supplementary Planning Guidance (SPG) (2003) states: `At Western Riverside, heights generally should be compatible with average eaves heights of properties in the city centre' (Para 8.23). The respect for contextual scale will help to protect to protect views to the wider landscape' (SPD, Page 18).	This appears to be a comment related to the planning application submitted by Crest. Support noted.
2.9 Building Height	Object	Cllr Furse, Kingsmead Ward	There will be much debate on the height of the buildings but eight stories and above seems excessive considering much of Bath is no more than 5 or 6 stories. The buildings should be proportionate with Bath buildings and give a sense of Bath if not in the Georgian style. Tall buildings fronting onto the river will impact on the sun light currently available to residents along the north side of the river.	Response subject to further assessment.
Building Height (Para 2.9)	Object	Alan Morgan	The 2003 SPG states that heights of new buildings should generally be compatible with average heights of eaves in the city centre which are predominately four-storey buildings. Yet the scheme proposes building heights up to 8 storeys high, which will dominate and overpower the area around.	Response subject to further assessment.
Building Height (Para 2.9)	Object	Alistair Spurr	3 storey buildings to be a maximum to maintain the character of the BWR and Bath area.	Response subject to further assessment. However, a maximum of three storeys would not constitute the optimum use of the site.
Building Height (Para 2.9)	Object	Alethea Smuts-Muller	The 9 story slab buildings would be completely at odds with the rest of the city (matching the height to the gas towers is an unbelievable justification) and the buildings would dominate the Bath landscape. They would be an eyesore for not only the immediate surrounding residential areas, but also all around Bath.	The SPD does not propose 9 storey slab buildings. This appears to be a comment related to the planning application submitted by Crest
Building Height (Para 2.9)	Object	Alistair Lord	Nine and twelve storeys is too high and will lead to a large impact on all of Bath and especially the properties to the North of the development as the size of these buildings will have an impact on light, wind and noise to residents.	These heights are not proposed by the SPD.
Building Height (Para 2.9)	Object	Charlotte Laurence	A tall, North-East facing block of buildings adjacent to the river will lose the sun as early as 3pm, making it a dark and cold place to sit out in the afternoons and evenings.	The detailed scale and location of individual buildings will be established through detailed proposals in response to the SPD.
Building Height (Para 2.9)	Object	Cllr Brian Webber	The target of 3,000 dwellings will prove incompatible with a decent quality of living for the residents and due respect for the architectural character of the city. Care must be taken to ensure that living quality is maintained throughout. The development must respect the character and tradition of Bath in terms of human scale, building heights, roofscape, views, materials, etc. Blocks of 6 or more storeys as human scale and in keeping with the character and tradition of Bath. The typical house in the historic core is 4 storeys (possibly with a basement). High buildings have implications for solar shading.	The final capacity of BWR will be determined by individual development proposals that have to be assessed against the SPD Spatial Masterplan. The principles that maintain the character and tradition of Bath should be ensured by the SPD Spatial Masterplan.
Building Height (Para 2.9)	Object	Dr James Dodson	Ensure that 8-floor buildings are not close to the river. High buildings close to the river will shade the river ends of Norfolk Crescent and Nelson Villas. Further from the river high buildings are more acceptable.	Proposed buildings heights of individual proposals will also have to take into account the importance of the river corridor and the relationship that this has with new buildings.
Building Height (Para 2.9)	Object	James Lee	High rise flats are neither attractive nor appropriate, and have no aesthetic relationship to Bath's existing architectural heritage, or the local industrial history.	Response subject to further assessment.
Building Height (Para 2.9)	Object	Lesley Metcalf	The proposed height is out of proportion to the scale of Bath	Response subject to further assessment.
Building Height (Para 2.9)	Object	Martin Fawley & Daniel Cleverdon	The proposed 5-8 floors is inconsistent with the Georgian heritage and architecture of the city and would significantly reduce the amount of sunlight reaching both Norfolk Crescent and Nelson Villas. Norfolk Crescent is a Grade 1 listed building and we are of the opinion that the surrounding area should be preserved to reflect and protect the heritage of the site.	Response subject to further assessment.
Building Height (Para 2.9)	Object	Mr and Mrs Spencer	Bath has no 8 storey buildings. No new building should exceed the height of existing nearby buildings e.g. St James West shouldn't be higher than 2/3 storeys.	Response subject to further assessment.
Building Height (Para 2.9)	Object	Mrs Martine Smith	There are few high rise buildings in Bath and these nine-storey blocks will be out of place. The Georgian buildings of Bath are no more than three or four storeys in height	The SPD does not propose 9 storey buildings. This appears to be a comment related to the planning application submitted by Crest
Building Height (Para 2.9)	Object	Steve Osgood	References in the Design code for allowable building heights of 5-8 storeys, excluding sub pedestrian level car parking and rooftop plant / lift motor rooms, should be withdrawn since the resulting skyline will undermine Bath's status as a WHS.	Response subject to further assessment..
Building Height (Para 2.9)	Object	Richard Cook	To be in keeping with the existing cityscape no blocks should be permitted to have more than 7 storeys. All roofs should be pitched with service shafts, liftheads etc. inside. This is to maintain and improve the visible impact as seen be 1000's of visitors from the surrounding hills	Response subject to further assessment.
Building Height (Para 2.9)	Object	Elizabeth Freeman	Buildings of between 5-8 floors are far too high for Bath. Having 6 Storey buildings on the site is inconsistent with 1. The WHS 2. The setting of the Listed buildings especially Norfolk Crescent.	Response subject to further assessment.
Building Height (Para 2.9)	Object	Jacqueline Matthews	The height will over-shadow the buildings at the end of Norfolk Crescent, and spoil the setting of the Grade I listed Building	Response subject to further assessment.
Build Quality	Object	Lesley Metcalf	Ensure standards are maintained: The build quality of the new development on the corner of Windsor Bridge Road and the A4 is very poor. The design is also woeful, which gives us no faith in the planning committee. Just because a building uses Bath stone, doesn't necessarily make it a suitable design for Bath.	The SPD and Design Codes set a very high standard for new developments at BWR.
2.9 (Page 40) Linkage to the proposed Two Tunnels Shared Path	Object	Two Tunnels Group	All the green dotted lines should also have blue dots as they should all be shared routes. The bridge currently set aside for the rapid transit link, running approximately east-west behind what is currently the BBC Audio Books building, should be allocated for shared cycle and pedestrian usage, linking on the northern side of the river to the Bath-Bristol path. Such usage should be considered as an early measure and not necessarily linked to the rapid transit system development, which may be many years away - if ever.	Agreed. Such routes should be shared routes in principle. Amend Plan 2.11 to reflect this. Such shared usage may be possible with the implementation of the Rapid transit system, but not in isolation, due to existing use by BBC Audiobooks. It is not appropriate to designate the bridge for this use in isolation from the rest of the Rapid Transit use.
2.11.7 Rapid Transit System	object	Crest Nicholson	The Draft SPD should make clear what has been assumed in this respect.	The Rapid Transit System requirements are clear and it is part of the Bath Package Major Bid that has been submitted to Government. The Major Bid is also part of the RFA which has Government approval. The submission fixes the line of the RTS and details all requirements and assumptions. The SPD must accord with this submission. The RTS is also set out in Policies contained in the Revised Deposit Draft of the Bath and North East Somerset Local Plan and the adopted Joint Local Transport Plan.
2.11.6-7 Movement & Access: Public Transport	object	Highways Agency	The current section on public transport does not provide sufficient detail to provide the Agency with enough reassurance that alternative modes of transport to the car will be sufficiently promoted through the SPD. Further details should be provided in relation to the Rapid Transit System and confirmation that the system will be delivered with the development of the site. With regards to location of bus/LRT stops the SPD may include reference to integration with the network of pedestrian routes through the site as a requirement for the development to ensure that all homes are within a minimum distance of a stop (i.e. 400 metres).	The RTS, along with many other transport routes, forms part of the Bath Package Major Bid to Government. This Major Bid appears in the RFA which has Government approval. Bus stops within the site are proposed at optimum locations and, subject to the success of the bid, it is the Council's objective that, as far as possible, transport systems are delivered ahead of development of the BWR site.
2.11.11 - 2.11.13 Movement & Access: Parking	object	Highways Agency	Whilst the Agency acknowledge detailed reference within the Design Code to parking standards, further mention may be made within the main body of the SPD itself to broadly promote standards on a level which will encourage alternative modes of transportation to the car.	Agreed. New para. after 2.11.14 setting out parking standard and objectives for this.
Road Safety	Object	Alistair Lord	With a potential two-way 93Destructor94 bridge this would increase the already busy traffic on the Upper Bristol Road. A pedestrian crossing should be put in from the path by the side of the Hop-Pole Pub from the river across to the Royal Victoria Park to assist in children crossing this road safely.	It is accepted that the BWR development will increase traffic levels in the local area. Appropriate road crossing facilities between BWR and Royal Victoria Park are listed as required infrastructure in Appendix C.
Parking and Transport	object	Bath Preservation Trust	If there is real commitment to reduce car use on this site, we would expect to see a greater emphasis on how alternative transport measures will be made to work, including how developers will be obliged to subsidise this. We can find neither elaboration of nor justification for a parking standard of 0.7 car park spaces per unit. The current government recommendation for car parking spaces is an average of 1.5 spaces per unit	The requirement for developers to contribute to alternative transport measures is set out in Appendix C: Developer Contributions. In order to strike a balance between discouraging the use of the private car whilst acknowledging that some car use will continue even when a modal shift occurs, it is considered that 0.7 spaces is an appropriate standard on a site that is conveniently located with regard to the City centre and public transport services, particularly the new rapid transit system.
Parking and Transport	object	Friends of the Earth	Provision for transport is crucial to this genuine attempt to create a community that doesn't focus on the car as its main mode of transportation. It is quite possible that the RTS from Newbridge will not be ready as residents move into BWR. The limited parking spaces make it imperative that public transport is available from day one.	Comment noted.
Parking and Transport	object	The Bath Society	The allocation of 0.7 of a parking space per dwelling is a mistake. Car ownership would, we believe, well exceed this ratio, leading to increased pressure on parking in nearby streets. The SPD anticipates the development to provide around 3000 dwellings over the total redevelopment period up to 2026. This equates to 2100 cars. Will the Upper and Lower Bristol Roads be able to take the increase in traffic?	In order to strike a balance between discouraging the use of the private car whilst acknowledging that some car use will continue even when a modal shift occurs, it is considered that 0.7 spaces is an appropriate standard on a site that is conveniently located with regard to the City centre and public transport services, particularly the new rapid transit system. Para. 1.5.25 of the SPD also requires proposals to be brought forward to address the travel demands generated by BWR.
Parking (2.11.11)	Object	Alan Morgan	The allocation of 0.7 of a parking space per dwelling will lead to parking problems in the surrounding areas. The current government recommendation is for an average figure of 1.5 spaces per new house/flat. We consider that the new houses should be based on a minimum of 1.0 parking space per unit.	In order to strike a balance between discouraging the use of the private car whilst acknowledging that some car use will continue even when a modal shift occurs, it is considered that 0.7 spaces is an appropriate standard on a site that is conveniently located with regard to the City centre and public transport services, particularly the new rapid transit system.
Parking (2.11.11)	Object	Alethea Smuts-Muller	The proposed 0.7 parking spaces per new build will only compound an already dreadful parking problem in the areas adjacent to the development, while locating a series of new bars and cafes as proposed will simply increase traffic congestion around the Upper and Lower Bristol Roads.	In order to strike a balance between discouraging the use of the private car whilst acknowledging that some car use will continue even when a modal shift occurs, it is considered that 0.7 spaces is an appropriate standard on a site that is conveniently located with regard to the City centre and public transport services, particularly the new rapid transit system. Para. 1.5.25 of the SPD also requires proposals to be brought forward to address the travel demands generated by BWR.
Parking (2.11.11)	Object	Alistair Lord	Car levels and parking has not been considered carefully in respect of Bath's unique geography and general lack of space. Parking allowance of only 0.7 will drive cars to be parked outside the area and so have an impact on all parking. With increased links across the river then it is likely that this will impact on parking to the North.	In order to strike a balance between discouraging the use of the private car whilst acknowledging that some car use will continue even when a modal shift occurs, it is considered that 0.7 spaces is an appropriate standard on a site that is conveniently located with regard to the City centre and public transport services, particularly the new rapid transit system. Residents parking schemes, to mitigate the potential impacts of overspill parking, are listed as an off-site infrastructure requirement on page 8 of Appendix C (Developer Contributions) of the SPD.
Parking (2.11.11)	Object	Cllr Brian Webber	The parking standard of 0.7 cars per dwelling is unrealistically low. It should be 1 per dwelling, because however much residents of BWR may walk or use public transport, most will still aspire to own a car and some households will feel a need for more than one. It would be intolerable if irresistible demand for more parking were to impact on the streets neighbouring BWR, where there is already a chronic shortage.	In order to strike a balance between discouraging the use of the private car whilst acknowledging that some car use will continue even when a modal shift occurs, it is considered that 0.7 spaces is an appropriate standard on a site that is conveniently located with regard to the City centre and public transport services, particularly the new rapid transit system. Residents parking schemes, to mitigate the potential impacts of overspill parking, are listed as an off-site infrastructure requirement on page 8 of Appendix C (Developer Contributions) of the SPD.
Parking (2.11.11)	Object	David Dunlop	The suggestion of only 0.7 parking spaces per dwelling is naEFve and takes no account of the domino effect on adjoining neighbourhoods.	In order to strike a balance between discouraging the use of the private car whilst acknowledging that some car use will continue even when a modal shift occurs, it is considered that 0.7 spaces is an appropriate standard on a site that is conveniently located with regard to the City centre and public transport services, particularly the new rapid transit system. Residents parking schemes, to mitigate the potential impacts of overspill parking, are listed as an off-site infrastructure requirement on page 8 of Appendix C (Developer Contributions) of the SPD.
Parking (2.11.11)	Object	Mr and Mrs Spencer	There is insufficient parking for existing residents. Indeed the proposed scheme does not include any additional parking for existing residents	It would be contrary to policy for the SPD to specifically require additional parking for existing properties, as this would encourage greater use of the private car by existing occupiers.
Parking (2.11.11)	Object	Mrs Martine Smith	The level of car ownership taken into account in these plans is unrealistic. Parking is already a huge problem in the area, without the thousands of extra cars that will arrive with these proposals.	New residents moving to BWR will have to make their decisions regarding car ownership and use, taking into account the suppressed level of parking to be provided at BWR.
Parking (2.11.11)	Object	Mr M Ware	Underground parking on the floodplain?!	SPD needs to make reference to flood defence matters.
Parking (2.11.11)	Object	Steve Osgood	There appears to be inherent contradiction between the limiting parameter of 0.7 car park spaces average and the reality of car ownership recognized by national statistics, land use distribution of the region, the Ernst & Young report and the Future Vision study.	New residents moving to BWR will have to make their decisions regarding car ownership and use, taking into account the suppressed level of parking to be provided at BWR.
Parking (2.11.11)	Object	Richard Cook	To allow only 0.7 spaces per dwelling is a recipe for disaster. It is not possible to dictate how people lead their lives in this way. At lease 1 garage space should be provided for each dwelling, including the students. No outside parking should be provided.	In order to strike a balance between discouraging the use of the private car whilst acknowledging that some car use will continue even when a modal shift occurs, it is considered that 0.7 spaces is an appropriate standard on a site that is conveniently located with regard to the City centre and public transport services, particularly the new rapid transit system. Para. 1.5.25 of the SPD also requires proposals to be brought forward to address the travel demands generated by BWR.
Part 2 Para 2.11 - movement and access strategy	object	Peter Andrews - Bath Organic Group	The proposed path would break up a thriving community Result in the loss of valuable plots at a time when there is a 3 year waiting list There area existing footpaths Security would be further compromised Path through play park would break up successful open space	Following consideration, officers agree with the objectors that there are already suitable links between the park and BWR, and that the detrimental impact that a further link would have on the allotments would not be justified. This potential route, therefore, is proposed to be deleted from the SPD.
Path through Play Area.	object	Cllr Furse, Kingsmead Ward	The plans show a new entrance to the children's play area and a path running right through it. Parents and children would have their play area split in two - creating supervision difficulties. Also, a path would impact on the play area layout and without a total redesign would not in my opinion be received well by parents using this facility - one of the best in the South West of England.	The key principle is to create a new entrance to Royal Victoria Park at this point, in order to improve linkages with BWR. The route taken by pedestrians once they have entered the park is less important, therefore, a new route within the park is of less importance. Amend Plan 2.11 to delete new route but illustrate provision of new pedestrian access.
Norfolk Crescent Footbridge (Para 2.11.20)	object	Cllr Furse, Kingsmead Ward	The area in and around Norfolk Crescent is entirely residential and linking this area with a bridge into the commercial areas will bring increased noise and associated behaviour when pedestrians go to and from the bars and restaurants of BWR commercial district. In addition Norfolk Crescent is grade 1 listed and a bridge would impact visually and potentially impact the historic structure itself. Is a bridge needed? The proposal gives no alternative location for a bridge - this location is only a few metres from the existing bridge next to Sainsburys, an alternative location could be adjoining the path next to the TA centre - this also is almost in line with the existing path through the Allotments. This site is approximately half way between Destructor bridge and Victoria Bridge.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Alethea Smuts-Muller	The footbridge would turn Norfolk Crescent Green into a throughway, with the accompanying problems of drunken and rowdy late night behavior, and drug and alcohol related crime. This would have a devastating impact on the resident's quality of life as well as change the original nature of a Grade I Listed Crescent.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan. -
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Dr James Dodson	There is a footbridge already only a short distance downstream from the proposed new bridge. The proposed new footbridge would alter the character of the area of Norfolk Crescent and Nelson Place West. The new footbridge would open this quiet elegant cul-de-sac to all the rowdy elements and behaviour associated with already existing bars and late-night drinking.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Jessica Lovelace	Increased noise, traffic pollution and late night entertainment along the water's edge. I am also concerned about environmental issues - wildlife and trees being affected.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Martin Fawley & Daniel Cleverdon	This bridge will only lead to unacceptable noise levels at closing time and an increased risk to damage to cars and property. It will also exacerbate the already dire parking situation in and around the Norfolk green area. There are already 2 bridges in the vicinity that will provide ample access from the Upper Bristol Road side to the new development.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Miss Michanek & Mr Knott Thompson	We believe that this footbridge would have a detrimental impact on Norfolk Crescent and the whole area surrounding the green by making it a thoroughfare for people returning from drinking establishments, with associated noise, disorder and mess. Furthermore, there is an additional existing bridge, also less than a minute's walk to the west of this proposed bridge. Are three links this close to each other really required?	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Mr and Mrs Spencer	The area proposed for development is well served by existing footbridges. No necessity of having extra. The proposed footbridge will destroy the character of Norfolk Buildings as cul-de-sac and also destroy the architectural beauty of the area.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Mr D Almond	That this planned bridge is not needed and compromise the appearance of a Grade 1 listed Georgian Crescent. The planned bridge is half way between two pre-existing bridges which are already within half a mile of each other. The proposed bridge will ruin the appearance and ambiance of surrounding historic areas, and will be another nugatory expense for the long suffering bath council tax payer.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Mr W Farrar	The peace and quiet of the green will be greatly disturbed and that also the bridge will look out of place, also causing great harm to the environment.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Mrs JDA Smith	The intended bridge over the river and consequent noise levels from bars etc. will be damaging to the health and welfare of residents in the immediate vicinity.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge(Para 2.11.20)	Object	Mrs Joan Vaughan	The plan is to have restaurants and bars with late night drinking which will cause massive problems with people using the bridge to gain access to the main road, damage to parked cars; noise and causing a general nuisance to residents will certainly result.	The SPD describes the south bank of the river in this area as the 93Urban River Quarter94 with public and commercial activity fronting onto the public realm creating a new high quality river promenade. Because the Masterplan is zonal, the precise quantum and nature of commercial uses in this area is not defined within the SPD. More detailed masterplanning, required for the Context Plan for the Eastern zone, will establish more detailed parameters for this development, followed by individual development proposals. Mitigation of the likely impacts on existing residents can be considered in more detail at these later stages, and stakeholders will be consulted as the process develops. It is not considered to be appropriate, therefore, to amend the SPD with regard to this matter at this stage.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Ms P.A. Brown	It would be detrimental for an otherwise relatively peaceful residential area, creating a flow of people day and night.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Samantha Elwin	Inevitable increase in parking problems and noise disturbance.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	W G S	There are already two existing bridge within four hundred yards either side of Norfolk Crescent. Norfolk Crescent and Nelson Place is a quiet residential listed building area which would be destroyed by being the main commuter route between Charlotte St car park and Green Park if this proposed bridge was to go ahead	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	ZoEB Ward	I am concerned about the plants and wildlife, noise and pollution and parking. People at Norfolk Crescent do not want volumes of people coming out of pubs and restaurants at all hours.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Andrew Palmer	The bridge would affect the aspect of the Grade I listed Crescent due to increased pedestrian flows It would necessitate the removal of trees in the conservation area There are already 2 perfectly good bridges close by. Increased pollution, crime and noise.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	Object	Jacqueline Matthews	Increased alcohol and drugs related problems Increase in Noise and litter Allow increased access to the park (otherwise secluded and quiet)	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.
Norfolk Crescent Footbridge (Para 2.11.20)	object	Charlotte Laurence - Norfolk Crescent Residents Association	Paragraphs 2.6.7 and 2.11.20: This proposal is to the detriment of the character and appearance of a whole group of listed buildings, to say nothing of the site's special architectural and historic interest etc. In the location shown for the bridge, it seems that disturbance to the structure of No 18 during construction is inevitable. Not only will it be detrimental to appearance and character, but the pedestrian through-traffic will disturb and damage the environment and ultimately lead to decay. A footbridge located on the site will necessitate the felling of some trees which would be detrimental to the quality and amenity of this secluded environment. Mature trees are paramount in supplying the backdrop which contributes to this sense of enclosure and in providing separation from the river and the commercial uses to the south side. The trees are a significant wind-break affording protection to the buildings in the area during severe winds and act as a screen for local residents and visitors to enjoy the use of the green. The Green provides a unique residential amenity, shared by all residents. If the bridge proceeds, it is to be expected the Green will become crowded with visitors, both residents from the Phase 1 development who may need additional public open space to that provided on site, with the users of the city extension development and with pedestrians crossing to and from the south bank. Parking is already limited, the proposed bridge crosses to the path or roadway at the end of the Crescent, and further parking spaces will be lost together with the turning circle. There is much concern that all residents in the area will suffer noise disturbance in their homes, both from the bars and cafes themselves and from customers when they leave the premises - particularly at night. It can be anticipated that pedestrians leaving proposed bars on the southern river bank will not always be quiet and well behaved when walking through the Crescent. Para. 2.11.20 93to support the commercial uses in the City extension94 As the eastern end of the site situated between Victoria Bridge to south of the river and Green Park Station to the north forms the city extension, the proposal for an additional crossing at Norfolk Crescent is misplaced as it will provide no direct connection between the commercial uses in these areas, but merely encroach on a residential area that is quite distinct from the plan. Change Sought: Withdraw the proposal for a new footbridge The proposed usage of the south side of the river as a city extension or `cafE9 quarter' fails to take account of the adjacent residential area. The space between the southern river bank and buildings be increased to reduce noise disturbance whatever use is determined. Norfolk Crescent Green should not be providing additional public open space for the city extension development.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan. The SPD describes the south bank of the river in this area as the 93Urban River Quarter94 with public and commercial activity fronting onto the public realm creating a new high quality river promenade. Because the Masterplan is zonal, the precise quantum and nature of commercial uses in this area is not defined within the SPD. More detailed masterplanning, required for the Context Plan for the Eastern zone, will establish more detailed parameters for this development, followed by individual development proposals. Mitigation of the likely impacts on existing residents can be considered in more detail at these later stages, and stakeholders will be consulted as the process develops. It is not considered to be appropriate, therefore, to amend the SPD with regard to this matter at this stage.
Norfolk Crescent Footbridge (Para 2.11.20)	object	Residents of Cumberland House	We do not need a new footbridge from Riverside Developments to Norfolk Crescent the other bridges are sufficient.	The new bridge is considered to be an essential link between BWR and the area to the north. Linkages between BWR and the existing communities are a key principle of the SPD, and this proposed pedestrian link plays an important role in meeting this objective. It is not proposed, therefore, to delete the bridge from the SPD Masterplan.

Objections PART 3: THE IMPLEMENTATION PLAN

Paragraph/Plan No/Proposal	Support/Object	Company	Comments	Council Comments
Part 3 Monitoring impact	object	International Council on Monuments & Sites UK	Some indication should be given as to how development in the WHS will be measured for its impact on the `outstanding universal value' of the WHS.	It would be extremely difficult to measure how this was being achieved. The SPD takes into account and promotes the outstanding universal value of the WHS, therefore, the degree of compliance with the SPD will indicate the degree of compliance with this particular objective.
Part 3 Project Delivery	object	GOSW	Implementation plan should set out clearly how, when and by whom the project will be delivered. A project of this scale and complexity will require all key parties to agree a process and timetable and I would expect reference to be made to the need for active project management, delivery agreements etc Consider whether a steering group of key stakeholders and organisations should be convened to progress the project	Given that the redevelopment will be delivered in phases, though individual developments, and given the continuing lack of certainty regarding gap funding, it is considered that the Implementation Plan set out in the SPD provides as much certainty over roles and timescales that is possible at this point in time. A steering group comprising representatives from the Council, SWRDA and Crest Nicholson has been set up to progress the project.
Phasing & Implementation 3.1	object	Deeley Freed Estates Ltd	The phasing and implementation plan set out in the SPD is of concern. Given the overall size of the 3 zones shown in the SPD, the broad range of land uses envisaged and the varying aspirations of different land owners, there is a danger that this approach will lead to unnecessary delays in bringing forward appropriate development. An otherwise acceptable proposal that accords with the prevailing policy context and the framework set down in the SPD should not be delayed by the speed at which a context plan can be agreed for the development of the whole of an identified zone. In this respect, it is not clear who is to produce the context plans or how they are to be `approved'. Moreover, given the SPD suggests that applications will normally require the submission of an Environmental Statement (ES); it is not clear how approval for the context plans relates to the requirements of the EIA regime in terms of setting the parameters of a development. There is also no indication as to whether or how the context plans will be subject to appropriate public consultation (given the advice in PPS12 regarding SPDs that they should be subjected to `rigorous procedures of community involvement').	As set out in para. 3.2.3 of the SPD, individual phases (and therefore the size of the zones) have to be significant enough to contribute meaningfully towards the comprehensive redevelopment of BWR. If the phases were smaller, this would involve too fragmented an approach which would erode the objectives of securing a comprehensive redevelopment of BWR. Paras. 3.2.5-6 of the SPD explain the requirements for Context Plans. If a Context Plan does not already exist for the appropriate zone, an application will be expected to be accompanied by a Context Plan. Context Plans will assist in Environmental Statements assessing the cumulative effects of individual proposals alongside other developments within the appropriate zone. Context Plans will be subject to the same public consultation as the planning applications that they accompany. When the Council's Development Control Committee make a resolution regarding an individual application, they will also make a resolution regarding any accompanying Context Plan. SPD to explain this process in new para after 3.2.6..
3.1 Viability	object	National Grid Properties Ltd	The need to explicitly state that should costs relating to the Rapid Transport system; Affordable housing content; the ambition to incorporate low carbon technologies and/or contributions through the 106 or other mechanisms then density and use mix will need to be reviewed with regards to ensuring the schemes viability.	The requirement to consider s106 contributions and have regard to viability considerations is set out in para. 3.3.16 where an 93open book94 approach to development finance is set out.
EIA 3.1	object	Deeley Freed Estates Ltd	Provided that individual development proposals comply with the prevailing policy context, the overriding urban design and townscape objectives, and provide appropriate developer contributions, there is no reason why development in an individual, organic fashion need compromise the overall vision and aspirations for BWR set down in the SPD.	Disagree. The need for individual developments to come forward in the light of a Context Plan for the appropriate zone is considered to be necessary in order to meet the key objective of comprehensive development (paras. 1.5.1 - 13).
3.1 Landowners	object	National Grid Properties Ltd	The need to identify the main landowners of the site as key stakeholders. The majority of the site is currently owned by 5 key landowners whom should be provided with a formal mechanism/forum (i.e. say a landowners group) with which to communicate with the promoting authority and lead developer.	Such a group existed a few years ago, however, progress on the project at this time was uncertain. The Council is satisfied that there are satisfactory communications between the lead developer and the Council and other significant landowners at BWR. The Council will continue to communicate with all landowners at BWR with regard to the project.
3.1 Phasing	object	National Grid Properties Ltd	The need to have a more flexible approach to the size of phases that the Council will support being released at the site. The current proposals are too prescriptive. While National Grid accepts the need for phasing to be brought forward in meaningful phases the current proposals are too prescriptive and large.	As set out in para. 3.2.3 of the SPD, individual phases (and therefore the size of the zones) have to be significant enough to contribute meaningfully towards the comprehensive redevelopment of BWR. If the phases were smaller, this would involve too fragmented an approach which would erode the objectives of securing a comprehensive redevelopment of BWR.
3.1 Viability	object	National Grid Properties Ltd	The document refers to viability and the need for the scheme to be viable on a number of occasions. The word is meaningless without some for of attempt by the Council to define it. Is viable a site value of £1? Is it that the proposed scheme needs to generate site value in excess of existing use value? Is it that a viable project is one at which the landowners can be persuaded to release their land, taking account of their varying development costs. This needs to be defined within the SPD	The SPD does not define viability.
3.1 Viability	object	National Grid Properties Ltd	The need for the council to acknowledge the fact that in identifying viability, account is taken of abnormal development costs, such as those relating to remediation and decommissioning.	This will form part of the 93open book94 process described in para. 3.3.16.
Implementation of CPOs (3.1.7)	object	Stones Coaches	There are a number of references to CPO, and to existing uses within the SPD area, but no detail as to this is to be implemented. It is unclear whether it is the Council's intention to use these, on which sites, and in what timescale. Given this is the case the plan should either omit areas or, this detail must be added.	CPO is a last resort and would not be necessary if the BWR site can be assembled satisfactorily by private treaty. Therefore, it cannot be stated at this stage when CPO will be required and in relation to which sites. At this point in time it is appropriate to state that CPO powers are available and that the Council has specifically resolved to utilise these powers with regard to BWR if necessary.
3.1.7 & 3.1.23 CPOs	object	Renrod Motor Group	There are a number of references to CPO, and to existing uses within the SPD area, but no detail on how this is to be implemented. Specifically, it is noted at 3.1.7 that the Council has CPO powers. It is unclear whether it is the Council's intention to use these, on which sites, and in what timescale. Given that this is the case either the Plan should omit areas or, this detail must be added. The proposals as currently drafted create blight for existing businesses which, as the Local Plan Inquiry Inspector has noted, should be excluded in any event.	CPO is a last resort and would not be necessary if the BWR site can be assembled satisfactorily by private treaty. Therefore, it cannot be stated at this stage when CPO will be required and in relation to which sites. At this point in time it is appropriate to state that CPO powers are available and that the Council has specifically resolved to utilise these powers with regard to BWR if necessary.
3.1.9 Existing Uses & Landowners	object	Renrod Motor Group	At 3.1.9 reference is made to existing uses and landowners. It is unclear to what this statement relates. Detail must be provided in the SPD about uses which are intended to be retained and, if the intention is to seek relocation, details about this. Renrod consider that there are no practical opportunities for the relocation of their businesses within the BWR area or, elsewhere within the City of Bath.	Existing uses and landowners are mentioned in recognition of their role, and the impacts on them, in implementing the redevelopment of BWR. Until development proposals come forward, with accompanying Context Plans, it is not possible to definitively identify the existing uses at the site that will be retained and relocated.
3.2 Phasing strategy	object	Sainsbury's Supermarkets Ltd	The `Phasing Strategy' set out in the SPD, which proposes a further stage of master-planning at a `zonal' level, requires any development proposal put forward to provide a development framework for the whole of the `Development Zone' that the site is located within (a `Context Plan'), or for it to be in accordance with an already approved Context Plan for that zone. In the case of the Eastern Zone (including Green Park Station), this is unsatisfactory for a several reasons. Firstly, there is a danger that this will lead to unnecessary delays in bringing forward appropriate development given the overall size of this zone, broad range of land uses envisaged, and the varying aspirations of different land owners. Secondly, in the absence of an approved Context Plan, uncertainty will remain over the future of this part of BWR. Should it be the Council's continuing intention to plan for the Eastern Zone as a single entity, it should itself provide the required Context Plan that sets out the framework for development, in close consultation with land owning interests and other relevant stakeholders, in order to provide an appropriate level of clarity and certainty for the redevelopment of this part of BWR. Alternatively, the SPD should itself provide sufficient guidance to guide development in the Eastern Zone without recourse to a further tier of master-planning.	The SPD Masterplan covers the development period to 2021. Due to the need for additional guidance, through the LDF, regarding the quantum and mix of uses that will be accommodated in the Eastern zone, and also due to the acknowledged varying aspirations of different land owners, it is considered that the more detailed masterplanning of the Eastern zone, and any consequent delay for development, is necessary to secure the satisfactory comprehensive redevelopment of BWR. It is possible that the Council will be responsible for producing the Context Plan for the Eastern Zone, in conjunction with other landowners and stakeholders.
3.2.1 - 3.2.6 Phasing Strategies	Object	Westmark	This section introduces the concept of Context Plans. This is another layer of detailed masterplanning that sits under the principles of the masterplan laid down in the SPD. A fundamental question is raised by the introduction of Context Plans. That is, if a Context Plan is approved for other zones, does the Context Plan take precedence over the SPD in terms of an application coming forward that confirms to it. Paragraph 3.2.5B suggests that as long as an application accords with the Context Plan that has been approved as part of an application within one of the zones identified, any application that comes forward that accords with that Context Plan should have a presumption in favour of that development. Criterion 3.2.5C provides for some flexibility in this process, in that if improvements can be made to the Context Plan as it affects particular sites coming forward and if these improvements can be agreed with the Local Planning Authority, there will be a presumption in favour of approval.	The context plans need to comply with the SPD, and therefore will need to comply with the Design Codes. The Design codes are at a finer level of detail than the SPD, and build upon it. The context plans are intended to be at a framework level not a detailed level.
3.3.4	object	Crest Nicholson	There is a drafting error. The paragraph does not introduce what follows.	Formatting error. Amend para. 3.3.4.
3.3.5 Pooled contributions	object	Crest Nicholson	For there to be transparency it is necessary for the Draft SPD to make clear on what assumptions the financial elements of the developers contributions policy have been based. At present that information is not set out in the Draft SPD or in Appendix C.	It is considered that Appendix C provides an appropriate level of detail for SPD purposes, however, further justification for the contribution requirements can be provided as part of the 93open book94 process described in para. 3.3.16.
3.3.5 Affordable Housing	Object	Westmark	This introduces the concept of pooled contributions enabling the Council to set contributions on an equal basis for different phases of the development. The method of collecting and spending pooled contributions should be made explicit, as should the priorities and phasing of expenditure. How will cash shortfalls be met if the monies raised under the section 106 are insufficient? Para 3.3 needs to be more explicit about the mechanisms of pooled resources.	The SPD sets out the main principles of the approach. Further details regarding the operation of the approach will be provided during negotiations regarding planning obligations relating to development proposals.
3.3.5 Planning obligations	object	National Grid Properties Ltd	For there to be transparency it is necessary for the Draft SPD to make clear on what assumptions the financial elements of the developers' contributions policy have been based. At present that information is not set out in the Draft SPD or in Appendix.	It is considered that Appendix C provides an appropriate level of detail for SPD purposes, however, further justification for the contribution requirements can be provided as part of the 93open book94 process described in para. 3.3.16.
3.3.18 Administrative charge	object	Crest Nicholson	The proposed administration charge is unreasonable in the context of this scheme, where the Council's role is to co-ordinate the delivery of common infrastructure and, in certain cases, to provide it itself, using pooled contributions.	The monitoring role that the Council has to carry out has resource implications and the administration charge is a reasonable mechanism for covering the cost of those resources.
3.4.1 EIA	object	Crest Nicholson	The requirements for outline applications will need to be restated to reflect the change to the outline planning applications regime that is to be implemented in August 2006. Not all planning applications of whatever scale within BWR will require EIA.	Amend reference to reflect SI 2006 No.1062. Para. 3.4.2 states that an ES will 93normally94 be required. It will be for individual applicants to justify why the flexibility allowed by this statement will apply in any particular case.
3.4.1 Form of applications	object	National Grid Properties Ltd	The requirements for outline applications will need to be restated to reflect the change to the outline planning applications regime that is to be implemented in August 2006. Not all planning applications of whatever scale within BWR will require EIA.	Amend reference to reflect SI 2006 No.1062. Para. 3.4.2 states that an ES will 93normally94 be required. It will be for individual applicants to justify why the flexibility allowed by this statement will apply in any particular case.
3.4.1 EIA	object	Deeley Freed Estates Ltd	In terms of the suggestion in the draft SPD that planning applications will normally be required to be accompanied by an ES, the Council is required by the relevant legislation to screen all received applications to determine whether or not they are development requiring EIA. There are likely to be instances where applications for individual developments at BWR do not require EIA. This should be clearly reflected and provided for in the text.	Para. 3.4.2 states that an ES will 93normally94 be required. It will be for individual applicants to justify why the flexibility allowed by this statement will apply in any particular case.
3.4.2	object	Crest Nicholson	Not all planning applications of whatever scale within BWR will require EIA. The sensitive areas test merely extends the requirement for screening to all Schedule 2 developments regardless of their site area, it does not mean that EIA will be needed in every case.	Para. 3.4.2 states that an ES will 93normally94 be required. It will be for individual applicants to justify why the flexibility allowed by this statement will apply in any particular case.
3.4.2 EIA	object	National Grid Properties Ltd	Not all planning applications of whatever scale within BWR will require EIA. The sensitive areas test merely extends the requirement for screening to all Schedule 2 developments regardless of their site area, it does not mean that EIA will be needed in every case.	Para. 3.4.2 states that an ES will 93normally94 be required. It will be for individual applicants to justify why the flexibility allowed by this statement will apply in any particular case.
Paragraphs 3.1.1-23 Delivery Strategy	object	Argos Retail Group	Sets out the delivery strategy for BWR, but again is simply characterised by comments recognising the important role that existing uses have in delivering the proposals for BWR, without any assessment or explanation of what will happen to them and if they are to be relocated, what allocations are being made for an 93equivalent location in the vicinity94 (paragraph 7.24 of the Inspectors Report refers). Paragraph 3.1.23 alludes to the use of Compulsory Purchase Powers, for what and for where is unclear, simply adding further to the uncertainty and insecurity that the draft SPD seems to offer to all existing businesses within the BWR. For the above reasons, my clients would request that the draft SPD be amended as follows: A. That both the existing Argos and Homebase stores remain as existing and be identified as 93retained buildings94 or 93retained businesses94. B. That any proposals to improve, extend or alter the existing stores should demonstrate that they are consistent with the comprehensive and regeneration aims of the BWR by reference to the relevant policies of the Revised Deposit Local Plan and SPD. Neither the Deposit Local Plan nor the draft SPD provide any good planning or other reasoning for continuing to include the Homebase and Argos store's within the BWR. The principal aim of the BWR allocation is to secure the redevelopment of former employment sites, the environmental regeneration of the riverside area and provision of new housing. The deletion of the Homebase and Argos sites from the BWR would not undermine, prejudice or compromise those aims from being achieved. The costs of relocating the Homebase and Argos stores would also be prohibitive, leaving aside the fact that there are no retail sites allocated in the Deposit Local Plan (nor in the draft SPD) that could accommodate this scale and format of development, if relocation was in fact proposed.	Existing uses and landowners are mentioned in recognition of their role, and the impacts on them, in implementing the redevelopment of BWR. Until development proposals come forward, with accompanying Context Plans, it is not possible to definitively identify the existing uses at the site that will be retained and relocated. CPO is a last resort and would not be necessary if the BWR site can be assembled satisfactorily by private treaty. Therefore, it cannot be stated at this stage when CPO will be required and in relation to which sites. At this point in time it is appropriate to state that CPO powers are available and that the Council has specifically resolved to utilise these powers with regard to BWR if necessary. These uses, which are single-storey retail outlets with extensive surface car parking areas, do not conform with the principles of the redevelopment of BWR. Therefore, they are not identified as being specifically retained in the SPD and any reference to extending or altering these existing buildings in the SPD would be inappropriate. The main principle of BWR is to optimise the development of the site. The review of the BWR allocation boundary, in response to the Local Plan Inspector's recommendations, will take this into account. Further detailed masterplanning, in the form of the Context Plan for the Eastern zone in particular, will take into account delivery and re-location issues at this stage.
3.3.18 Admin charge for legal agreements	object	National Grid Properties Ltd	The proposed administration charge is unreasonable in the context of this scheme, where the Council's role is to co-ordinate the delivery of common infrastructure and, in certain cases, to provide it itself, using pooled contributions.	The monitoring role that the Council has to carry out has resource implications and the administration charge is a reasonable mechanism for covering the cost of those resources.

APPENDIX A: EXISTING RELEVANT POLICIES

Paragraph/Plan No/Proposal

Support/Object

Company

Comments

Council Comments

Appendix A

Existing Relevant Policies

object

Highways Agency

Whilst the policies document includes a reference to PPG13 (Transport) and Local Plan policy, the Agency believes consideration should be made to the findings of the Final Joint Local Transport Plan for the Greater Bristol area published in March 2006 which includes reference to the BWR development (section 10.5).

The purpose of Appendix A is to summarise the main policy requirements found in PPSs/PPGs and development plan documents or potential development plan documents, plus the existing SPG.

APPENDIX C: DEVELOPER CONTRIBUTIONS

Paragraph/Plan No/Proposal	Support/Object	Company	Comments	Council Comments
Appendix C Developer Contributions	object	Deeley Freed Estates Ltd	On the basis of the level of information provided in the SPD and Appendix C, it is not possible to establish the potential level of contribution likely to be expected of a particular development within BWR. In terms of the on-site infrastructure and other requirements there is no basis on which to judge whether the list of items is necessary or directly, fairly and reasonably related to a proposal, as required by relevant legislation and guidance. This is also true of the pooled contributions as it does not appear that the formulae used are based on any detailed assumptions about the actual content of the envisaged development in terms of land uses or occupants.	The requirement for contributions is set out clearly at the end of each section, on a per dwelling or per m2 (commercial or employment uses) basis. This should allow a calculation to be made when applied to individual developments. All of the items set out in Appendix C are required for the BWR development and, therefore, meet the necessary tests. The formulae take into account a quantum and mix of development that results from the masterplanning process undertaken.
Appendix C Developer Contributions	support	Highways Agency	The Agency supports the required transport contributions.	Support noted.
Appendix C Developer Contributions	object	Highways Agency	There is scope to include reference to the requirement for Travel Plans as detailed above within the section 106 requirements.	Appendix C relates to developer contributions only. Agreed. New para. after 1.5.45 setting out requirements for Travel Plans.
Appendix C: Developer Contributions	object	Royal United Hospital	The Appendix refers to offsite infrastructure works and states that these will be funded by a combination of the Bath WRD development, other development in the City and separate bids for funding via the LTP. We assume that the assumptions in the Appendix do not include contributions from RUH towards off site infrastructure but would welcome your clarification in this respect.	The assumptions include contributions from all trip generating new developments within the City of Bath.
Appendix C: Developer Contributions	object	GOSW	This document sets out the Council's approach to planning obligations at Western Riverside; however it is not clear how site viability has informed the approach taken. You may wish to consider whether a joint approach to determining site viability with key partners would be helpful.	Site viability has not directly influenced Appendix C, because it takes a formulaic approach, irrespective of viability. Site viability will be taken into account and established through the 93open book94 approach described in para. 3.3.16 of the SPD.
Appendix C Affordable Housing	object	Crest Nicholson	The text makes no acknowledgement of overall viability or the availability of housing grant, in determining the overall quantum and tenure split that may be yielded by a particular scheme. Reference is made at paragraph 1.5.18 of the Draft SPD to the 93paramount94 role of the Housing Corporation in delivering significant affordable housing across BWR. Paragraph 3.3.16 also identifies that developers may opt for an `open book approach' in order to demonstrate that the Council is placing 93unreasonable burdens on a proposal.94 The dependency of Housing Corporation grant funding should therefore be made more explicit in Appendix C, along with recognition that the amount of affordable housing that will be provided on individual sites will be subject to negotiations between the Council and landowners/developers based upon the specifics of the scheme and its overall viability.	Para. 3.1.11 of the SPD states that the Housing Corporation has a key role to play if BWR is to successfully deliver a significant amount of affordable housing on site to meet identified local need. If gap funding is not forthcoming, the delivery of a suitable amount of affordable housing at BWR will not be possible. Therefore, it is considered that the dependency on Housing Corporation funding is already set out in the SPD.
Appendix C Affordable Housing	object	Crest Nicholson	The current Crest Nicholson outline planning application for the western zone of BWR includes a wide range of market and affordable house products. Within the proposed range of market house products are 160 1 bedroom studios, each averaging 350sq.ft. in size. This equates to approximately 7.5% of the overall housing provision within the scheme. The level at which these units will be priced at will make them inherently affordable. Crest submits that this provision should be taken into account in considering the overall quantum of formal affordable housing on the site.	Disagree. It is understood that such units will be sold at full market value and, therefore, will not qualify as affordable housing.
Appendix C Affordable Housing	object	National Grid Properties Ltd	The text makes no acknowledgement of overall viability or the availability of housing grant, in determining the overall quantum and tenure split that may be yielded by a particular scheme. Reference is made at paragraph 1.5.18 of the Draft SPD to the 93paramount94 role of the Housing Corporation in delivering significant affordable housing across BWR. Paragraph 3.3.16 also identifies that developers may opt for an `open book approach' in order to demonstrate that the Council is placing 93unreasonable burdens on a proposal.94 The dependency of Housing Corporation grant funding should therefore be made more explicit in Appendix C, along with recognition that the amount of affordable housing that will be provided on individual sites will be subject to negotiations between the Council and landowners/developers based upon the specifics of the scheme and its overall viability.	Para. 3.1.11 of the SPD states that the Housing Corporation has a key role to play if BWR is to successfully deliver a significant amount of affordable housing on site to meet identified local need. If gap funding is not forthcoming, the delivery of a suitable amount of affordable housing at BWR will not be possible. Therefore, it is considered that the dependency on Housing Corporation funding is already set out in the SPD.
Appendix C Affordable Housing	Object	Westmark	In order to comply with PPG3 and circular 06/98, it should state in the first paragraph that all schemes involving residential development will be expected to provide 93up to94 30% affordable housing. This provides the flexibility needed in order to assimilate the issue of viability into the affordable housing equation. Affordable housing is a major planning obligation in its own right. We would therefore suggest that it is not justifiable to load further planning obligations on to affordable housing. Under the `occupancy assumption' there should be a statement to the effect that pooled contributions will be calculated on the formulaic basis in relation to each of the scheme elements but will not be relevant to the affordable housing element of any scheme.	Disagree. The Council's policy expects to achieve 30% affordable housing on all threshold sites. Disagree. Affordable housing has very similar impacts to market housing which will require mitigation. It is not considered appropriate, therefore, to give affordable housing an exemption from the planning obligations that apply to BWR.
Appendix C Infrastructure related to BWR	Object	Westmark	It is suggested that developers will be expected to include either physically, or financially the requirement for the relocation of Midland Road Depot - likelihood being residential development. Through its allocation in the SPD this B&NES owned land will have been massively enhanced in value. The idea that developers pay for the relocation so B&NES can profit is contrary to Government policy.	The activities at the existing Midland Road Depot are local authority responsibilities in terms of refuse collection and recycling / disposal and street cleansing. It is considered appropriate that the redevelopment of BWR ensures the continued provision of these local authority services.
Appendix C	Object	Westmark	A robust justification is needed to defend the inclusion of improvements to Locksbrook Road and the Upper Bristol Road as they do not fall within the BWR boundary. As Bath is currently shutting all public toilets due to the drugs problems associated with them, why therefore are there plans to build new ones as shown under `Other On Site Requirements94? There is a commuted sum for street cleaning. This should be deleted as this fee is calculated into Council Tax paid by all residents. There appears to be some double counting going on in the SPD, transport infrastructure for one is linked to a payment per dwelling, and mentioned separately in the SPD. Issues as follows: Enhancing Oldfield Park Station - Bus company responsibilities not BWR Commuted sums to mitigate unforeseen problems A36 P+R. not relevant to BWR Grand Parade Bridge Construction, not relevant to BWR Commuted sum for Bath Freight Consolidation Scheme, not relevant to BWR Claverton Street Subway, not relevant to BWR Expanded P+R at Lansdown and Odd Down, not relevant to BWR. HGV through traffic restrictions, not relevant to BWR Rossiter Road/Widcombe High Street Traffic Management Systems, not relevant to BWR	Initial Transport Assessments have shown potential problems in these locations. Any proposal for development will bring forward the need for an accompanying transport assessment, extending beyond the limits of the site, which will need to examine these issues in more detail. The Council is committed to providing a high quality public convenience service Council-wide, through its Public Convenience Provision strategy which was approved in May 2004. Evidence presented to the Planning Transportation, Economy and Sustainability Overview and Scrutiny panel, the views of the Police Authority and other sources were taken into account in developing the proposal for the provision of the public convenience service. Recommendations to rationalise the service were made whilst at the same time, re-affirming the commitment to improve quality standards to meet the needs and expectations of all users. There are also ongoing discussions and initiatives to consider and include public convenience provision in new developments throughout the district. The SPD is justified, therefore, in seeking onsite provision and contributions towards public conveniences at BWR. To be clarified. This will be clarified through the 93open book94 process described under para. 3.3.16, as the Council will need to know which specific items of infrastructure are being proposed as part of specific developments. All of the items listed, however, are considered to be related and necessary for the development of BWR.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	The absence of an actual delivery mechanism within either the Draft SPD or Appendix C fails to ensure that there will be parity between landowners/developers either in terms of development phasing or site specific infrastructure. For example, the promoters of initial phases of development may be responsible for delivering certain infrastructure items that may also benefit (or even be necessary) for subsequent phases of development. There are currently no mechanisms to ensure that the cost of provision of such infrastructure items (which includes land value) borne by initial development will be recompensed appropriately by subsequent development.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	Whilst Crest Nicholson understands the broad rationale for sub-dividing BWR into three zones, the current delineation leads to unclear linkages between each zone and infrastructure requirements. Crest Nicholson submits that the zones should more closely follow existing land ownerships, which will be the principal determinant to development taking place.	Disagree. In determining the boundary of the development zones for BWR, readily identifiable features should be followed. In this case, the existing north / south route of Victoria Bridge Road has been used as the boundary between zones 1 and 2. Any developments taking place that straddle this boundary will be considered on their merits in terms of infrastructure requirements.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	There appears to be inconsistency in the infrastructure items that have been included and those that have been excluded. Crest does not see the justification for Zone 2 to contribute to the relocation of the Midland Road Depot and therefore submits that this reference should be deleted.	The activities at the existing Midland Road Depot are local authority responsibilities in terms of refuse collection and recycling / disposal and street cleansing. It is considered appropriate that the redevelopment of BWR ensures the continued provision of these local authority services.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	It could be argued that a number of infrastructure items identified in Zone 2 are either necessary for, or will benefit development in Zone 1 (and vice versa). Further clarity is required on how an appropriate part of the cost of providing such infrastructure items borne by landowners/developers in initial phases will be met by subsequent phases of development. For example, the 93strengthening and enhancement of Victoria Bridge94 will benefit the whole of BWR and the cost of doing so should therefore be split across all three zones.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	In determining an appropriate developer contribution overall, the Council could consider an overall scheme contribution either as a proportion of the total cost all the infrastructure requirements within a particular zone or as an equivalent proportion of each infrastructure requirement. In doing so, the Council should have regard not only to capital and revenue contributions, but also land value forsaken by landowner/developer in providing specified items, which should be reflected in the overall consideration of a scheme's viability.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	The 93provision of a fully operational RTS route94 requires further explanation, particularly as no approved scheme currently exists. The Crest Nicholson scheme currently makes provision for a potential RTS route across its application site. There is an opportunity land cost of providing this route. In the likelihood of the Crest Nicholson scheme commencing first, on what basis does the Council envisage subsequent Zone 2 schemes contributing towards these costs?	A current scheme exists, together with assumptions, justification and a fixed route as part of the Bath Package Major Bid to Government. The bid is also contained within the RFA that has been approved by Government. This all needs to be reflected within the SPD, including the fixed route alignment. Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	The list of Zone 2 infrastructure items includes a number of road infrastructure improvements. The wording is ambiguous and there appears to be overlap between some of these items and those items listed separately under the pooled contributions towards Transport Infrastructure (page 8). For example, the eleventh and twelfth items on the list of Zone 2 infrastructure items appear to be duplicated by the eighth and ninth items in the list of off-site infrastructure items under pooled contributions. Crest Nicholson suggests that both lists of infrastructure items should be cross-referred to a plan clearly indicating the extent of each item.	This will be clarified through the 93open book94 process described under para. 3.3.16, as the Council will need to know which specific items of infrastructure are being proposed as part of specific developments.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	Crest Nicholson has submitted an independent report to the Council demonstrating that on the basis of the number of units proposed, there is no demonstrable need for a new primary school as required by the Draft SPD and Appendix C. Crest therefore submits that the provision of a site for a primary school should be subject to identifying a demonstrable need. If in the event that a site for a primary school is to be provided, the land value forsaken by the landowner/developer that incorporates it should be credited against the overall scheme contributions. However, it is not clear who will build the primary school, nor why contributions are not required from Zones A and C, which are also likely to contain a significant residential element.	Disagree. Expand para. 1.5.51 regarding the justification for a Primary School. Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	The Crest Nicholson scheme currently incorporates a 4,000sq.ft GP surgery, which should be credited against the overall scheme contributions.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	The Crest Nicholson scheme currently incorporates a 7,400sq.ft community hall, which should be credited against the overall scheme contributions.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	Flood alleviation works proposed as part of the Crest Nicholson scheme will also be to the benefit of the wider BWR area. Crest Nicholson submits that an appropriate proportion of the cost of these works (including forsaken land value) should be credited against the overall scheme contributions.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 West	object	Crest Nicholson	It is not clear which zones these requirements apply to. Crest Nicholson submits that these items should be listed under the appropriate zones in the preceding lists. It is also not clear how the requirement for public open spaces relates to the separate pooled requirement for green space. For example, CCTV provision presumably relates solely to retail elements within Zone 1.	Clarification will be provided through the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 (West)	object	National Grid Properties Ltd	The absence of an actual delivery mechanism within either the Draft SPD or Appendix C fails to ensure that there will be parity between landowners/developers either in terms of development phasing or site specific infrastructure. For example, the promoters of initial phases of development may be responsible for delivering certain infrastructure items that may also benefit (or even be necessary) for subsequent phases of development. There are currently no mechanisms to ensure that the cost of provision of such infrastructure items (which includes land value) borne by initial development will be recompensed appropriately by subsequent development.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Infrastructure related to BWR - Zone 2 (West) (Appendix C & Plan 3.1)	object	National Grid Properties Ltd	Whilst National Grid Property understands the broad rationale for sub-dividing BWR into three zones, the current delineation leads to unclear linkages between each zone and infrastructure requirements. National Grid Property submits that the zones should more closely follow existing land ownerships, which will be the principal determinant to development taking place.	Disagree. In determining the boundary of the development zones for BWR, readily identifiable features should be followed. In this case, the existing north / south route of Victoria Bridge Road has been used as the boundary between zones 1 and 2. Any developments taking place that straddle this boundary will be considered on their merits in terms of infrastructure requirements.
Appendix C Infrastructure related to BWR - Zone 2 (West)		National Grid Properties Ltd	In determining an appropriate developer contribution overall, the Council could consider an overall scheme contribution either as a proportion of the total cost all the infrastructure requirements within a particular zone or as an equivalent proportion of each infrastructure requirement. In doing so, the Council should have regard not only to capital and revenue contributions, but also land value forsaken by landowner/developer in providing specified items, which should be reflected in the overall consideration of a scheme's viability.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 (West)	object	National Grid Properties Ltd	Flood alleviation works proposed as part of the National Grid Property scheme will also be to the benefit of the wider BWR area. National Grid Property submits that an appropriate proportion of the cost of these works (including forsaken land value) should be credited against the overall scheme contributions.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Infrastructure related to BWR - Zone 2 (West)	object	National Grid Properties Ltd	The 93provision of a fully operational RTS route94 requires further explanation, particularly as no approved scheme currently exists. The Crest Nicholson scheme currently makes provision for a potential RTS route across its application site. There is an opportunity land cost of providing this route. In the likelihood of the Crest Nicholson scheme commencing first, on what basis does the Council envisage subsequent Zone 2 schemes contributing towards these costs?	A current scheme exists, together with assumptions, justification and a fixed route as part of the Bath Package Major Bid to Government. The bid is also contained within the RFA that has been approved by Government. This all needs to be reflected within the SPD, including the fixed route alignment. Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16.
Appendix C Other on-site requirements, or requirements in relation to on-site items	object	Crest Nicholson	It is not clear which zones these requirements apply to. Crest Nicholson submits that these items should be listed under the appropriate zones in the preceding lists. It is also not clear how the requirement for public open spaces relates to the separate pooled requirement for green space. For example, CCTV provision presumably relates solely to retail elements within Zone 1.	Clarification will be provided through the 93open book94 process described in para. 3.3.16.
Appendix C Other on-site requirements, or requirements in relation to on-site items	object	Crest Nicholson	Crest Nicholson submits that Appendix C should make clear when developer contributions will be returned to developers in the event that they are not spent on specified items, for example five years.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16. However, five years is considered to be too limited a period, given the total implementation period for BWR of up until 2021.
Appendix C `Other on-site requirements, or requirements in relation to on-site items'	object	National Grid Properties Ltd	It is not clear which zones these requirements apply to. National Grid Property submits that these items should be listed under the appropriate zones in the preceding lists. It is also not clear how the requirement for public open spaces relates to the separate pooled requirement for green space. For example, CCTV provision presumably relates solely to retail elements within Zone 1.	Clarification will be provided through the 93open book94 process described in para. 3.3.16.
Appendix C `Other on-site requirements, or requirements in relation to on-site items'	object	National Grid Properties Ltd	National Grid Property submits that Appendix C should make clear when developer contributions will be returned to developers in the event that they are not spent on specified items, for example five years.	Such a mechanism will be discussed during the 93open book94 process described in para. 3.3.16. However, five years is considered to be too limited a period, given the total implementation period for BWR of up until 2021.
Appendix C Occupancy Assumptions	object	Crest Nicholson	Crest Nicholson submits that the assumed occupancy for a 1 bed unit does not reflect the likely occupancy of a 1 bed studio, which is likely to be significantly lower. The Crest Nicholson scheme currently includes 160 1 bed studios.	The 1 bed occupancy assumption is based on the 1999 Housing Needs survey and applies to the whole range of 1 bed accommodation, some of which will have an occupancy rate of above 1.31 as well as below 1.31.
Appendix C Occupancy Assumptions	object	Crest Nicholson	The standard occupancy assumptions for non-residential development have been listed. However, only commercial and employment occupancy assumptions have been adopted for the purposes of calculating pooled contributions in the remainder of Appendix C. Crest submits that for clarity, a pooled contribution for all non-residential development should be provided under each pooled requirement.	Clarification will be provided through the 93open book94 process described in para. 3.3.16.
Appendix C `Occupancy Assumptions'	object	National Grid Properties Ltd	Submits that the assumed occupancy for a 1 bed unit does not reflect the likely occupancy of a 1 bed studio, which is likely to be significantly lower. The National Grid Property scheme currently includes 160 1 bed studios.	The 1 bed occupancy assumption is based on the 1999 Housing Needs survey and applies to the whole range of 1 bed accommodation, some of which will have an occupancy rate of above 1.31 as well as below 1.31.
Appendix C `Occupancy Assumptions'	object	National Grid Properties Ltd	The standard occupancy assumptions for non-residential development have been listed. However, only commercial and employment occupancy assumptions have been adopted for the purposes of calculating pooled contributions in the remainder of Appendix C. National Grid Property submits that for clarity, a pooled contribution for all non-residential development should be provided under each pooled requirement.	Clarification will be provided through the 93open book94 process described in para. 3.3.16.
Appendix C Education Facilities	object	Crest Nicholson	Please see earlier comments in relation to the requirement for a new primary school. Whilst Crest supports the principle of a pooled contribution towards nursery and primary school education, it is not clear what the contributions are intended to cover. For example, the cost of constructing new places only, or does this include the cost of providing teachers etc.?	The contributions in this case are to cover the cost of constructing and fitting out the school, and do not include running costs.
Appendix C Youth Facilities	object	Crest Nicholson	The final paragraph refers to 93sports provision94. Presumably, this should read 93youth facilities94?	Agree. Amend final paragraph of page 4 of SPD Appendix C.
Appendix C Community Meeting Places	object	Crest Nicholson	The final paragraph refers to 93sports provision94. Presumably, this should read 93community meeting places94?	Agree. Amend final paragraph of page 5 of SPD Appendix C.
Appendix C Cultural Facilities	object	Crest Nicholson	Appendix C identifies that the pooled contributions will be put towards the provision of a facility that meets previously identified city-requirements. Crest Nicholson submits that in order to demonstrate that the Draft SPD and Appendix C is consistent with national guidance (as currently embodied within Circular 05/2005) and in particular, the tests requiring planning obligations to be 93necessary to make the proposed development acceptable in planning terms94 and 93directly related to the proposed development94, that the relationship between the cost of the provision of the facility and the pooled contributions is made more explicit.	BWR is proposed as a mixed-use redevelopment that will include, in the Eastern zone, town centre type activities. A cultural facility has been identified as being required as part of this mix. Therefore, individual developments within BWR have to contribute towards this mixed-use requirement. Developments within BWR are only being requested to contribute towards BWR's element of the cultural facility, the total cost of which has been derived from contributions from across the whole City of Bath, as set out on page 6 of Appendix C.
Appendix C `Cultural Facilities'	object	National Grid Properties Ltd	Appendix C identifies that the pooled contributions will be put towards the provision of a facility that meets previously identified city-requirements. National Grid Property submits that in order to demonstrate that the Draft SPD and Appendix C is consistent with national guidance (as currently embodied within Circular 05/2005) and in particular, the tests requiring planning obligations to be 93necessary to make the proposed development acceptable in planning terms94 and 93directly related to the proposed development94, that the relationship between the cost of the provision of the facility and the pooled contributions is made more explicit.	BWR is proposed as a mixed-use redevelopment that will include, in the Eastern zone, town centre type activities. A cultural facility has been identified as being required as part of this mix. Therefore, individual developments within BWR have to contribute towards this mixed-use requirement. Developments within BWR are only being requested to contribute towards BWR's element of the cultural facility, the total cost of which has been derived from contributions from across the whole City of Bath, as set out on page 6 of Appendix C.
Appendix C Transport Infrastructure	object	Crest Nicholson	The relationship between the off-site transport infrastructure requirements and their respective costs and the pooled contributions should be made more explicit - particularly without sight of the LTP bid. As it stands, there appears to be no rationale for the difference in contributions between Zones 1 and 2 and indeed, why no contributions are identified for Zone 3.	Clarification will be provided through the 93open book94 process described in para. 3.3.16. Due to boundary changes, there is no longer a Zone 3.
Appendix C Transport Infrastructure	object	Crest Nicholson	Some guidance should also be provided on what happens in the event that the Council's LTP bid is unsuccessful or only partially successful. For example, will the pooled contributions be re-calculated to accommodate any shortfall?	Clarification will be provided through the 93open book94 process described in para. 3.3.16.
Appendix C Transport Infrastructure	object	Crest Nicholson	The list of off-site transport infrastructure requirements currently suggests that there are no infrastructure requirements attaching to Zone 1 only. This cannot be correct.	Clarification will be provided through the 93open book94 process described in para. 3.3.16.
Appendix C `Transport Infrastructure'	object	National Grid Properties Ltd	The relationship between the off-site transport infrastructure requirements and their respective costs and the pooled contributions should be made more explicit - particularly without sight of the LTP bid. As it stands, there appears to be no rationale for the difference in contributions between Zones 1 and 2 and indeed, why no contributions are identified for Zone 3.	Clarification will be provided through the 93open book94 process described in para. 3.3.16. Due to boundary changes, there is no longer a Zone 3.
Appendix C `Transport Infrastructure'	object	National Grid Properties Ltd	Some guidance should also be provided on what happens in the event that the Council's LTP bid is unsuccessful or only partially successful. For example, will the pooled contributions be re-calculated to accommodate any shortfall?	Clarification will be provided through the 93open book94 process described in para. 3.3.16.
Appendix C `Transport Infrastructure'	object	National Grid Properties Ltd	The list of off-site transport infrastructure requirements currently suggests that there are no infrastructure requirements attaching to Zone 1 only. This cannot be correct.	Clarification will be provided through the 93open book94 process described in para. 3.3.16.
Appendix C Sports Facilities	object	Crest Nicholson	Please see earlier comments in relation to the requirement for a new primary school.	Representation needs to be clarified.
Appendix C `Sports Facilities'	object	National Grid Properties Ltd	Please see earlier comments in relation to the requirement for a new primary school (There is no objective justification to provide a two-form entry sports facilities as part of the development. This paragraph should be deleted).	Representation needs to be clarified.
Appendix C `Sports Facilities'	object	Westmark	Sport is for all and therefore this includes all forms of housing bar affordable housing which is already an obligation in its own right.	Disagree. Affordable housing has very similar impacts to market housing which will require mitigation. It is not considered appropriate, therefore, to give affordable housing an exemption from the planning obligations that apply to BWR.
Appendix C Green Space	object	Crest Nicholson	Crest Nicholson has sought unsuccessfully to obtain the Green Space Strategy from the Council referred to in Appendix C and therefore these representation are made in the absence of information contained within the Green Space Strategy. In the absence of a published green space strategy, Crest submits that corresponding references should be removed. The quantity standards appear to make no distinction between the nature of developments. For example, is it appropriate as a matter of principle, to apply the same green space standards to major urban regeneration schemes as it is to suburban schemes? Nor does the quantity standard appear to take account of the proximity of existing green space and its accessibility to any particular scheme	In producing a formula for developer contributions, the emerging Green Space Strategy is the most appropriate source of current requirements. Along with all other contributions requirements, the ability of individual developments to meet the green space obligation requirements will be considered on its merits with regard to viability.
Appendix C Green Space	object	Crest Nicholson	Applying the quantity requirements to the Crest Nicholson scheme yields the following theoretical requirements (assuming the requirements are triggered only by residential development): Formal Green Space = 52,739m² or 5.3ha Natural Green Space = 70,318m² or 7.0ha Allotments = 9,845m² or 1.0ha Total = 13.3ha In the absence of the Green Space Strategy, it is not clear to what extent the requirement will apply to all three types of green space. Whether provided on-site (the application site area is only 18ha) or off-site, the requirement does not appear to be reasonable. By comparison, the current Crest proposals incorporate 3.6ha of green space.	The green space obligation requirements allow for financial contributions in lieu of provision on site. The requirements, therefore, are a benchmark against which proposals can be measured and considered against all other material considerations.
Appendix C Green Space	object	Crest Nicholson	The paragraph preceding the table setting out annual maintenance costs and the table itself, should be clarified to indicate that the contributions are a one-off payment to cover a ten year period.	Agree. Amend paragraph and table to reflect this.
Appendix C Public Art	object	Crest Nicholson	Crest Nicholson submits that the requirement for 1% of construction costs to be contributed towards public art is onerous, particularly in a scheme of the size being promoted by Crest Nicholson. The 1% requirement should therefore be subject to a cap of approximately £500,000 and that in respect of the Crest scheme, it should be acknowledged that this will be integral to Crest's implementation of the hard and soft landscaping proposals.	The 1% requirement, which is a nationally recognised policy, is a benchmark against which proposals can be measured and considered against all other material considerations.
Appendix C Public Art	object	Westmark	Public art is a great benefit to the public realm and we would ask that any public art should be incorporated and integrated into the design of a scheme and building rather than tagged on at some other point. Recent experiences in Bristol has shown that there are far more benefits of integrating public art though the design process at an early stage which brings much greater results than having it as an afterthought.	The 1% requirement is a benchmark against which alternative methods of providing public art within development can be assessed against.
Appendix C `Public Art'	object	National Grid Properties Ltd	National Grid Property submits that the requirement for 1% of construction costs to be contributed towards public art is onerous, particularly in a scheme of the size being promoted by National Grid Property. The 1% requirement should therefore be subject to a cap of approximately £500,000 and that in respect of the National Grid Property scheme, it should be acknowledged that this will be integral to National Grid Property's implementation of the hard and soft landscaping proposals.	The 1% requirement, which is a nationally recognised policy, is a benchmark against which proposals can be measured and considered against all other material considerations.
Appendix C Social Services	object	Crest Nicholson	Given the current scheme provisions for DDA compliance, it is not clear why there is a need for pooled contributions towards the anticipated costs of disability adaptations.	The potential adaptations envisaged would be above and beyond the requirements of the DDA.
Appendix C Social Services	object	Westmark	Obligations to social services are the responsibility of other Government bodies and thus of no relevance. DDA requirements will be implemented in BWR and therefore there is no need for an obligation over and above this.	This relates to a local authority delivered service and is therefore relevant.
Appendix C `Social Services'	object	National Grid Properties Ltd	Given the current scheme provisions for DDA compliance, it is not clear why there is a need for pooled contributions towards the anticipated costs of disability adaptations.	The potential adaptations envisaged would be above and beyond the requirements of the DDA.
Appendix C Libraries	object	Crest Nicholson	Please see earlier comments in relation to the requirement for a new primary school.	Representation needs to be clarified.
Appendix C Libraries	object	Crest Nicholson	The final paragraph refers to 93sports provision94. Presumably, this should read 93libraries provision94?	Agree. Amend final paragraph of page 16 of SPD Appendix C.
Appendix C Primary Health Care	object	Crest Nicholson	The final paragraph refers to 93sports provision94. Presumably, this should read 93primary health care provision94?	Agree. Amend final paragraph of page 18 of SPD Appendix C.
Appendix C Economic Development	Object	Westmark	There is effectively 0% unemployment within Bath and therefore we do not see that this obligation is relevant. This could change over time and therefore one could introduce this obligation when it is necessary.	The Local Employment and Training aspect of the Appendix C is not solely an employment initiative but a sector initiative. Whilst overall unemployment in Bath is very low, the dominant industries in the area are however administrative and professional office services. The developer contributions sought would allow the Council to focus on a sector that is under-represented in the Bath & North East Somerset area. Construction accounts for less than 4% of the employment in Bath & North East Somerset whereas nationally this figure is 8%. The construction industry both nationally and locally has been facing a difficult time recruiting new people into the sector and retaining them to the point where they are sufficiently skilled. The result of this has seen an ageing workforce, and in the South West the average age of a construction worker is over 45. There is also a high occurrence of out migration amongst younger workers entering this sector locally. This has significant implications and there is a high risk the South West could become overly reliant on imported labour to fulfil its construction projects within the next 15 years. This in itself poses a significant risk in Bath & North East Somerset at present. The city is highly dependant on the tourist industry. It is however about to embark on some large scale development, including Southgate, Bath Quays and Western Riverside. A high level of imported labour would have a significant effect on the tourist market through its demands on local temporary accommodation, which would deplete the number of tourists coming into the city for what is a prolonged period. It should also be noted that there are requirements for local opportunities in the blue collar sector. The Norton Radstock area has seen net job losses of around 700 in the past year, primarily from people in manufacturing and engineering trades. A number of these individuals have certain skills that could be utilised through retraining in the construction industry. The successful delivery of an ongoing programme of development in the Bath & North East Somerset area is dependent on access to the requisite skills locally based. The Local Employment & Training aspect of Appendix C will allow local businesses and residents to capitalise on the planned development activity along with allowing for a stronger local skills base to support further activity in the area.
Appendix C Police	Object	Westmark	As far as making a contribution towards the Police is concerned, this is the responsibility of the Home office, not individual developers	The Police service is also funded locally through the Council Tax, and therefore this requirement is relevant.
Appendix C Financial Contribution	Object	Westmark	This needs a complete rewrite and should be based on quantitative information including Need Assessments for the issues that are raised. We also believe that many of the contributions asked for do not meet the tests laid out in Circular 05/05.	Disagree. It is considered that the contributions requirements meet the tests on Circular 05/05 and are based on the most up to date needs information available.

APPENDIX D: DESIGN GUIDANCE

Paragraph/Plan No/Proposal	Support/Object	Company	Comments	Council Comments
Appendix D Design codes	object	Sainsbury's Supermarkets Ltd	The Design Codes set out at Appendix D of the SPD are overly prescriptive. This may stifle imaginative and contemporary architecture in the BWR area, for example, by prohibiting the use of certain materials and design solutions. More importantly, it will be difficult for some building types to conform to the rules set out in the SPD and also meet commercial requirements. PPS1 (paragraph 38) makes it clear that design policies should `avoid unnecessary prescription or detail' and that local planning authorities should not attempt to impose `particular tastes' or `stifle innovation, originality, or initiative through unsubstantiated requirements to conform to certain development forms or styles'. While it is appropriate to seek to reinforce local distinctiveness and to ensure high quality development in the SPD, it is not appropriate to exert unnecessary controls over the design of new development. The SPD should include a set of general principles that will promote good design, but should go no further. In this regard, the detailed design codes contained at Appendix D should not be carried forward into the final SPD.	The design codes are intended to help ensure that development within the site is consistent with the character of the city. The codes are based on the typologies within the city. The prohibition of certain materials is to reinforce the local distinctiveness which is in large part due to the homogeneity of the materials used within the city. The contextual language is so strong, and given the WHS status and the link to the Outstanding Universal Values the need to respect the harmony of the city is of paramount importance. The controls here are not unnecessary, they are central to achieving quality development that respects the special nature of the townscape and landscape.
Appendix D Design codes	object	Deeley Freed Estates Ltd	The Design Codes set out at Appendix D of the SPD are overly prescriptive. This will stifle imaginative and contemporary architecture in the BWR area, for example, by prohibiting the use of certain materials and design solutions. More importantly, it will be difficult for some building types to conform to the rules set out in the SPD and also meet commercial requirements. PPS1 makes it clear that design policies should `avoid unnecessary prescription or detail' and that local planning authorities should not attempt to impose `particular tastes' or `stifle innovation, originality, or initiative through unsubstantiated requirements to conform to certain development forms or styles'. Whilst it is appropriate to seek to reinforce local distinctiveness and to ensure high quality development in the SPD, it is not appropriate to exert unnecessary controls over the design of new development. Design Codes are also not the correct vehicle for specifying land uses for particular parts of the site. The SPD should include a set of general design principles that will promote good design for the mixed use scheme, but should go no further. In this regard, the detailed design codes contained at Appendix D should not be carried forward into the final SPD in their current form.	Disagree. The SPD and masterplan allow for departure from the advice refer to para 2.1.11 when it can be demonstrated that the resulting design is equal or superior to the SPD. Disagree, it is possible to `wrap and cap' large commercial buildings, so they appear more integrated Many of the design codes are expressed as ranges. See also 1.10 of the Design codes which states that architectural styles are not prescribed. For a large part the local distinctiveness of Bath is made by the relatively limited palette of materials.
Appendix D Design	object	GOSW	Some architectural aspects of the scheme have been extensively detailed in the design codes; however successful place making relies upon a broader and more complex interpretation of design. I would suggest that you consider how other factors for instance ecology, topography and sustainable urban drainage would influence the design code.	This is the role of SPD, these issues have been considered.
Appendix D General	object	Crest Nicholson	The Draft SPD and Appendix D do not indicate how the design codes would be applied where the Council has accepted an alternative approach to that embodied within the spatial master plan, on the basis that the alternative is equal to or superior to the spatial master plan in urban design terms.	See paragraph 2.1.11 of SPD. If the design aspirations of the SPD are equalled or exceeded, there would need to be flexibility with regard to the design codes. However, the codes are based on acceptable contextual approaches and baseline study, they are a good indication of appropriate contextual approach.
Appendix D 2.0	object	Crest Nicholson	The general design principles articulated in the document have clearly been derived from the traditional Bath terrace, whereas the Draft SPD acknowledges that much of the new housing within the western quarter will be apartments. The plan form of apartments will be different from the plan form of houses and since good architecture is generated in part from the plan, this is bound to have design implications that the codes should acknowledge.	Many traditional Bath terraces are converted successfully to apartments. The inclusion of the Bath terrace as a typology is correct; they have multiple entrances that makes them highly adaptable. Modern apartments tend to be more sterile with single entrances, the visual effect of a single unit is quite different.
Appendix D 2.1	object	Crest Nicholson	What does 93conscious rhythm and proportion94, 93flat plane with points of emphasis only at focal points94 and 93all buildings must face the public realm94 mean? What is the justification for 93blank facades should be avoided94?	The design codes would benefit from further illustrative material to explain this point and those below. . .
Appendix D 2.2	object	Crest Nicholson	What does 93smaller components94 mean? What does 93proper roof form94 mean? It is a feature of many Georgian buildings in Bath that the roof is behind the parapet for example. The reference to 93all materials must be 93non-reflective94 is unrealistic. All roofing materials are reflective to some extent, including those listed as appropriate in the materials appendices.	See above
Appendix D 2.3	object	Crest Nicholson	What does 93corner buildings must face both principal streets94 mean? How do the Council propose to enforce the 93rule94 concerning road names in relation to adopted streets where it will be the Council's own responsibility - and a matter of their policy - as to what signage is provided?	See above
Appendix D 2.5	object	Crest Nicholson	What does 93large expanses94 mean?	See above
Appendix D 2.9	object	Crest Nicholson	The requirement to locate trees along the full the length of the south side of the river corridor is unduly prescriptive. The proposal to locate groups of trees on the north bank has to have regard to wider planning considerations and should be regarded as an objective, not a prescriptive requirement.	This serves to create a strong landscape structure for the site, a different approach may be valid, but needs to be justified.
Appendix D 2.11	object	Crest Nicholson	It is not clear what is intended in relation to street furniture. Presumably if a suitable 93suite94 is achieved in partnership with a major manufacturer it will become 93off the shelf94. Equally, until a new 93suite94 of this kind exists, street furniture will need to be sourced from manufacturers' existing ranges. This appears to be acknowledged by the subsequent bullet points which refer to the use of bespoke items only in certain locations	Specific suites of furniture would be developed exclusively for the site so would not become off the shelf.
Appendix D 4.0 Table	object	Crest Nicholson	Urban form, scale-height, City Link with Rapid Transit BRTS - the range of heights is not explained or justified. Urban form, scale-street ratio, W:H, City Link with Rapid Transit BRTS - the ratio to parapet is not justified. Urban form, scale-street ratio W:H, Mews/Street - the Mews scale-street ratio is not justified. Urban form, building facades, Midland Road - the requirement for the Wessex Water facade to be part of the street scene is not justified or explained. Urban form, building facades, Victoria Bridge Road - it is not clear what is meant by 93positive relationship must be achieved by both sides of street through the use of a common language94. Open space, to rear of blocks, City Link with Rapid Transit BRTS - is the reference to balconies in rear elevations permissive or prescriptive? Car parking, Mews/shared streets - does this preclude any on-street parking or parking within shared services? It is important to the design principles of Crest's proposed scheme to have activity on streets wherever possible. This can be provided partly through the provision of on-street car parking.	The design codes would benefit from further illustrative material to explain this point and those below.
Appendix D 5.0 Table	object	Crest Nicholson	Urban form, urban river frontage - the requirement for a continuous active frontage parallel to the river is not justified. Open space, public realm, Victoria Bridge Cascade - concept of a terrace stepping down to allow direct access to the river is not justified or explained. It is not clear why a 93design brief94 is required in addition to the application of the design codes within the context of the spatial master plan, given the requirements of the draft SPD for comprehensive design information coupled with the statutory requirement for major planning application to be accompanied by design statements.	The focus of the site is the river, it needs to be addressed positively. Departure from this guide may be justified but a design case needs to be made. The focus of activity on the river around the landmark of Queen Victoria Bridge is justified, by this important landmark which acts as the join between the more residential west and the more commercial east of the site. British Waterways support the need for active boating areas on the river front.
Appendix D Appendix 1 roofs	object	Crest Nicholson	Copper and other metals should be included as acceptable materials in order not to unnecessarily stifle design flair.	The limited materials palette reflects what is found predominantly in the city, departure from this list needs to be justified by the design, as the homogeneity of materials is a key feature of the city.
Appendix D Appendix 1 Main Structure	object	Crest Nicholson	Metal, brick, timber, reconstituted Bath stone and concrete should all be identified as acceptable materials in order not to unnecessarily stifle design flair.	The limited materials palette reflects what is found predominantly in the city, departure from this list needs to be justified by the design, as the homogeneity of materials is a key feature of the city.
Appendix D Appendix 1 Public Realm	object	Crest Nicholson	Brick, block, tarmac should all be included as acceptable materials in order not to unnecessarily stifle design flair.	The limited materials palette reflects what is found predominantly in the city, departure from this list needs to be justified by the design, as the homogeneity of materials is a key feature of the city.
Appendix D Appendix 2	object	Crest NIcholson	It's not clear whether the list of landscape species is permissive or prescriptive, it is, in any case, not sufficiently comprehensive and should allow for a wider range of species to be considered in all categories.	The limited palette is intended to give a strong simple structure, additional species will be considered, but their use needs to be justified in design terms.
Crest Nicholson as Developer	Object (General Comment)	Sulis Meadow's Neighbourhood Watch Area	Crest Nicholson, was praised in a recent WWF report (Bath Chronicle 9/9/05) as being top of the UK house-building companies for environmental and sustainability issues. I don't know how they arrived at that conclusion, but living in a Crest Nicholson housing estate, this is very far from our experience. Ten years after Crest Nicholson received approval to build some 336 houses we are still waiting for the estate to be brought up to standard to enable the council to adopt it.	This appears to be a comment related to the planning application submitted by Crest.

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