As a campaign we have responded to a range of consultations including the West of England Transport Vision, the B&NES Placemaking Plan and the World Heritage Site Management Plan.
B&NES Air Quality Action Plan Consultation, Autumn 2017
In November 2017 we responded to the Council’s proposed updated air quality action plan, due to run for five years from 2018. Our response covers the following:
- The recent ANPR data collection exercise and what should supplement it
- The potential clean air zone – ensuring it is ‘broad catchment’
- Making it a constitutional requirement that every relevant council report include a statement as to how the report’s recommendations impact upon air quality
- Preparing, with community input, and implementing a Local Cycling and Walking Infrastructure Plan, using the Plan, and the city’s monitored progress against it to unlock national funding
- Critically assessing the draft Action Plan against the proposals being drawn up and implemented by other cities in order to draw maximum inspiration and breadth of ideas
- Setting up a dedicated task force, with community input, and under research guidance from Bath University or the University of the West of England, to understand the shortcomings in current bus service provision in the City and surrounding rural areas, including routing, frequency, reliability and pricing, using this information to formulate detailed Bus Quality Partnership and Direct Franchise proposals.
- Putting in place a measurable action plan for negotiating and implementing in the shortest time frame possible, Bus Quality Partnerships and Direct Franchising through WECA.
- That the Plan must cease to refer to there being a 16% increase in P&R patronage as a result of the Bath Transport Package as (sole) evidence of success. Such an assertion is demonstrably false – the data set is highly unreliable, covers passengers not cars off the road and shows a decline in patronage for four of the years, including the last two since the BTP was finished. This misleads both the public and DEFRA into believing it is a future solution that would work for Bath
Please find the full report here
B&NES Parking Strategy
We have commented on the Council’s parking strategy consultation that happened in October 2017 and in doing so called for the parking strategy not to be adopted because it:
- Represents an unacceptable step backwards – the original aims of this parking strategy have been superseded and there is now a real imperative from National Government (Defra) for Bath to improve air quality;
- Lacks an acceptable evidence base:
- The off-street parking evidence used in the supporting technical document is both inaccurate and incomplete, while the evidence used in the park and ride section does not support the conclusions that are made. The move to relocate long-stay parking to the periphery falls down as a strategy because through-the-day parking data, not provided in the evidence base, tells us that commuters do not use these spaces in earnest today. Only Southgate Rail is filled with commuters.
- There is no attempt made to set or quantify this strategy in the context of wider congestion and vehicle movements within the city. There is therefore no indication of the role that this parking strategy would play in achieving broader transport aims;
- Contains no detailed or compelling discussion about what ‘sustain and enhance the vitality and viability’ means for Bath as a World Heritage City and therefore why it is right to pursue such car-centric proposals. This is especially true given the fast-paced and changing nature of cars currently.
- Needs to state explicitly the financial contribution that B&NES receives from parking revenue and how it would change as a result of the draft strategy, so that the public can take this into account when they read the proposals.
See the full response here: BMA Parking Strategy consultation response
West of England Transport Vision to 2036
We commented on the West of England Transport Vision to 2036, where regional-level plans threaten to turn Bathampton Meadows into a transport hub. You will find the consultation together with the Bathampton Meadows Alliance response below:
B&NES Placemaking Plan
The draft Placemaking Plan was submitted to the Secretary of State to be examined by an independent Planning Inspector in April 2016 and should have contained the site that the Council had selected to progress for a park and ride to the East. As they were not ready to do this, they inserted a generic set of standards that any park and ride application should achieve. Our response to this Plan sets out why there is no proven need for any east of Bath park and ride.
Hearings with the Planning Inspector were held in the Autumn of 2016 and we attended alongside the Bath Preservation Trust. The Planning Inspector was concerned that the need for a Park & Ride appeared to have been pre-judged, and questioned the deliverability of the Park & Ride during the plan period, without a site having been brought forward. She has given no conclusion as to the soundness of the park and ride policy within the Plan. It is quite misleading to suggest that the Planning Inspector is happy that need has been established and that the Plan presents no obstacle to the selection of a site for a 4th park and ride.
In January 2017 following these hearings B&NES released their amendments to this plan and there was a consultation on those amendments from 5th January 2017 to 14th February 2017. We are now very concerned that without giving context or explanation, the Council’s amendments to this Plan aim to make developing a park and ride a trade-off rather than a number of hurdles to overcome. As such we have developed our response “Bathampton Meadows Alliance, response to consultation on Main Modifications” to their amendments.
World Heritage Site Management Plan