City of Bath World Heritage Site Statement of Community Involvement

City of Bath World Heritage Site

Statement of Community Involvement Relating to the drafting and adoption of the City of Bath World Heritage Site Management Plan 2016-2022

1 Introduction

1.1 UNESCO’s Operational Guidelines (2013) for the implementation of the World Heritage Convention state that ‘each property should have an appropriate management plan or other documented management system which must specify how the OUV of a property should be preserved, preferably through participatory means’ (section 108). Since 1994 it has been UK Government policy that all UK World Heritage Sites (WHS) should have a Management Plan. The purpose of the management plan is therefore to set out how the commitments of the World Heritage Convention, with regard to the City of Bath, will be applied and delivered.

1.2 As suggested through the UNESCO reference to ‘participatory means’ and in accordance with accepted UK ‘best practice’, extensive consultation is involved in the production of this document. Given the large size of Bath WHS, and the fact that the many of the historic assets are in private ownership, the plan explains that partnership or a participatory approach is key to effective management.

1.3 This statement sets out the measures undertaken to promote a participatory approach.

2 Timescale

2.1 This is the third edition of the City of Bath WHS Management Plan. The first was 2003-2009, the second 2010-2016 and this third edition will cover 2016- 2022.

2.2 Experience from Bath and from other sites has shown that a project to revise a management plan will take around 18 months.

2.3 This statement covers the preparatory period of draft plan preparation (from March 2014 onward) to the close of public consultation (23 May 2016 to 15 July 2016).

3 First steps

3.1 The need for review was first discussed by the WHS Steering Group at their meeting of 18 March 2014. At this meeting a draft initial timetable was circulated and the concept of a sub-group was discussed. (Note: Steering Group minutes are available as public documents at www.bathworldheritage.org.uk/management and older papers are available by request via [email protected] or 01225 477584.

3.2 The sub-group met on 9th September 2014. The membership of the sub- group was as follows:

I. Peter Metcalfe, Steering Group Chair II. Tony Crouch, World Heritage Manager, B&NES III. Caroline Kay, Chief Executive, Bath Preservation Trust IV. Sarah Johnston, Snr Planning Policy Officer, B&NES V. Stephen Bird, Head of Heritage Services, B&NES VI. Dr Kristin Doern, Bath Spa University VII. Rohan Torkildsen, Historic England

3.3 The main points discussed by the sub-group were the plan structure and potential consultation approaches. These proposals were then taken to the Steering Group of 18 October 2014 for ratification. The first Steering Group of 2015 (24 March) further considered these issues plus arrangements for the Stakeholder event.

4 Stakeholder Event

4.1 Holding a ‘stakeholder event’ was proposed and agreed for the following reasons:

 This approach worked well in producing the 2010 plan. It was therefore tried and tested.  This would enable a continuous message and an opportunity to feedback to those who had been involved before.  This gave the opportunity to gather many people involved in WH management together. Some were people who had frequent interaction with Bath WH, others had infrequent contact.  Group interaction enables delegates to see the breadth of views, and to contribute and be inspired by them.

 In terms of efficient use of time, assembling a large number of delegates in one place at one time is more efficient than seeking to see all individually.  This exercise results in a wide range of issues being recorded, providing the ideal starting base for compiling the draft plan and ‘front-loading’ consultation.  The exercise produces an up to date database of contacts who can be targeted during full-consultation, and spreads the message amongst all organisations present that the review project is underway.  The exercise can be used as a ‘thank you’ to all who have been involved previously and who will be called upon to be ambassadors for WH in the future.

The Stakeholder Workshop was held on 21 April 2015 at the Assembly Rooms, Bath. Appendix 1 shows the organisations and individuals who were invited and who attended. The event comprised of a series of presentations and facilitated discussions.

Figure 1. A Workshop session at the Stakeholder Event, April 2015

Results from the Stakeholder event were captured in a table of issues. 136 issues were tabulated and responses recorded against them, of which the most frequent were to state where the issue had been included in the emerging plan, to say that they were not appropriate for this plan but were addressed elsewhere, or to state that they were not World Heritage issues. The response table is shown in Appendix 2. The advantage of the extensive feedback from the event was that it enabled a

3 draft plan to be compiled which already captured and reflected issues raised by a large sector of the community.

Following the Stakeholder event the draft plan was compiled. A series of other opportunities were used to publicise the forthcoming consultation or capture views. These included:

 Presentation to Federation of Bath Resident’s Association. Widcombe Primary School, 30 July 2015.  World Heritage UK conference, Saltaire, 14 October 2015  Institute of Historic Buildings AGM, Gloucester, 15 November 2015  Presentation to B&NES Overview and Scrutiny Panel, 24 November 2015  World Heritage UK Management Plan Workshop, Edinburgh, 25 January 2016  Presentation to The Mayors Honorary Corps of Guides, 22 February 2016  Staffed stall at World Heritage Day, Assembly Rooms, Bath, 17 April 2016. 5 addresses were recorded at this event and electronic copies of the plan subsequently forwarded. One response was made and recorded at the time.  Presentation to the Bath Business Initiative, May 2015

Figure 2. World Heritage Day 2016 included displays alerting people to the consultation, and an opportunity to leave comments or contact details to be sent the full plan. The Mayor’s Guides gave tours of the area.

In addition to the above public contact, consultation within Bath and North East Somerset Council was undertaken. This involved liaison with the following teams or individuals:

 The Sustainability Team  Building Control (Hot Spring monitoring and ‘fracking’)  Planning and Conservation Team  Planning Policy  Environment (landscape and river management)  Transport  Heritage Services  Business Intelligence Team

Full Public Consultation

Public consultation was conducted over an eight week period in line with adopted B&NES Council best practice and to allow groups such as parish councils with infrequent meeting dates to respond. The opening date was 23 May 2016, closing on Friday 15th July.

In advance of consultation opening, a bespoke web page was published on the Bath WHS website.

On the opening day (23rd May) the consultation was the top item on the Council’s electronic consultation page. News of the consultation was issued on the Bath WHS Twitter and Facebook feeds. (with reminders posted midway through consultation on 17 June).

Hard copies of the plan were delivered to Bath Central Library for distribution to other libraries in the district, a copy was delivered to the B&NES One-Stop-Shop at Manvers Street, Bath, and posted to the similar facility at The Hollies, Midsomer Norton.

A group email was sent to all those on the database collated as part of the April 2015 Stakeholder event.

Hard copies were posted to all members of the Steering Group (for dissemination within their organisations) and other copies were distributed to various others on request. These included:

 Les Redwood, Head of Business Development and Partnerships, Bath Tourism Plus  Dr Daniel Keech, University of Gloucestershire  Christopher Pound, Architect and World Heritage Consultant  Paul Simons, Paul Simons Associates

 Economic Development, Planning Policy, Environment Team, Sustainability Team.  Adrian Neilson for distribution to the Planning and Conservation Team.  Sarah Simmonds (Stonehenge & Avebury WHS).  Anne Twitchett, Mayors Corp of Honorary Guides

A stall was manned at the Bath City Conference on 1 July.

A Press Release was issued on Friday 17 June, and is shown in Appendix 3. In addition to the standard issue list used by the Council’s Press Office, Heritage Services also sent the message to 15 specialist heritage publications. The consultation was advertised in the B&NES Arts Bulletin.

On the 29th of June, a letter was sent by the Chair of the Steering Group to all 32 ward councillors within the WHS. A poster advertising the consultation was displayed in the King’s Lounge of the Roman Baths.

Figure 3. The poster displayed in the King’s Lounge of the Roman Baths

Consultation Responses

Public consultation generated 98 responses. These comprised of responses from 73 individuals, 17 organisations, 5 council officers and 3 ward councillors. When added to the list of issues raised during the pre-consultation stakeholder event this gives a total of 232 responses. No respondents disagreed with or challenged the 5 priority subject areas advocated in the draft. In this respect there were no major issues raised which will required a change of direction. As expected in a 73 page document there were numerous suggestions for various alterations of text. These responses were logged and a comment saying how they had been addressed was added. This log is shown in Appendix 4.

Appendix 1.

Appendix 2. Log of Stakeholder Event comments.

Appendix 3 Press Release.

Appendix 4. Log

APPENDIX 1: Invitees and attendees at the Stakeholder Event 21st April 2015

Attended Representing Title Name Job Title Organisation

(Intended to but ill on David International Council on Monuments the day) ICOMOS UK Thackray President & Sites UK Sir Bob Permanent Department of Communities and N DCLG Kerslake Secretary Local Government ENG HERITAGE Head of International Henry Owen- Advice & World N Historic England John Heritage Historic England Historic Rohan Environment Historic England (SW & W Y Historic England Torkildsen Planning Adviser Midlands) Historic Areas N David Stuart Advisor English Heritage Alison Somerset, Avon and Wiltshire Area Y Natural England Howell Team Planning and Landscape Y Cotswolds AONB Andrew Lord Officer Cotswold Conservation Board

N FORESTRY COMMISSION James Fry Field Manager Forestry Commision Wessex Area SENT REP ENVIRONMENT AGENCY Nick Gupta Manager Environment Agency Gary Planning N SPORT ENG Parsons Manager Sport England Local Government Relationship N SPORT ENG Jim Barrett Manager Sport England

Relationship Ruth Manager, South N ARTS COUNCIL Kapadia West Arts Council England THE SW TOURISM Alistair N ALLIANCE Handyside Chairman The South West Tourism Alliance South West Federation of Museums and Art Vicky South West Federation of Museums N Galleries Dawson Chair and Art Galleries General Manager, Bath Y NAT TRUST Tom Boden Portfolio National Trust B&NES COUNCIL OFFICERS Divisional Director John Community Y Place Directorate Wilkinson Regeneration B&NES Council Div. Director B&NES Planning and Transportation N Transport Lisa Bartlett and Planning B&NES Council Planning & Strategic/Spatial Planning & Transport - Mark Group Manager N Development Reynolds Development B&NES Council Head of Heritage Y B&NES Heritage Services Stephen Bird Services B&NES Council Group Manager, Neighbourhood B&NES Parks and Green Carol Environmental Y Spaces Maclellan Services B&NES Council Richard Head of Property N B&NES Property Services Long Service B&NES Council

B&NES People and Strategic N Communities Ashley Ayre Director B&NES Council Sarah Senior Planning Y B&NES Planning Policy Johnston Officer B&NES Council Corporate B&NES Corporate Jane Sustainability Y Sustainability Wildblood Manager B&NES Council Service Manager - Public Protection and B&NES Environmental Health Y Health Sue Green Improvement B&NES Council Group Manager, B&NES Planning, Policy Peter Planning Policy Y and Transport Dawson & Transport B&NES Council Team Manager - B&NES Historic Paula Planning and Y Environment Freeland Conservation B&NES Council

Team Leader, Y B&NES Environment Mark Minkley Environment B&NES Council Group Manager - B&NES Policy and Simon De Policy & Y Environment Beer Environment B&NES Council Customer Services - Comms Hub Emergency Planning & Operations N Business Continuity Stephen Bell Manager B&NES Council Group Manager, Andy Partnership Y Policy & Partnerships Thomas Delivery B&NES Council

Development & Major Regeneration Y Projects Tim Hewitt Team Manager B&NES Council

Highways Networks Kelvin Group Manager: N Management Packer Highways B&NES Council

Group Manager – Transport and Y Parking Services Chris Major Parking B&NES Council Planning and Transport Development - Design and Andrew Landscape Y Landscape Team Sharland Architect B&NES Council

Richard Archaeological Y B&NES Archaeology Sermon Officer B&NES Council Senior Engineer Alison (Accessibility Y Sherwin and Cycling) B&NES Council Green Infrastructure & Planning and Transport Environment Development - Natural Partnerhip Co- Y Environment Team Sue Murtagh ordinator B&NES Council

STRATEGIC PARTNERS Chief Superintendent, Area Commander for Bath & North East Somerset Caroline and South N Public Services Board Peters Gloucestershire Avon and Somerset Police Bath and North East Somerset Clinical N Commissioning Group Tracey Cox Chief Officer Bath and North East Somerset CCG Director of Operations and Bath, Gloucestershire, Swindon and N NHS England Julia Davison Delivery Wiltshire Area Team

Divisional Bruce Director: Public N B&NES Public Health Laurence Health B&NES Council Divisional Director: Adult Health, Social Care and N B&NES Jane Shayler Housing B&NES Council

N Sirona Janet Rowse Chief Executive Sirona Care and Health HAD INTENDED; LATE West of England Local Barbara West of England Local Economic APOLS Economic Partnership Davies Chief Executive Partnership Development Manager, Bath and North East N Public Services Board Jilly Edwards Somerset Quartet Community Foundation Terry Watch Manager Y Avon Fire and Rescue Bamford (Heritage Lead) Avon Fire and Rescue Service Bath Station Y Avon Fire and Rescue Chris Bailes Manager Avon Fire and Rescue Service Victor N Public Services Board DaCunha Chief Executive Curo Housing

N Bath Churches Together Revd Ian Souter Chair Bath Churches Together

N SARI Stand Against Racism & Inequality Federation of Bath Federationof Bath Residents N Residents Associations Robin Kerr Chairman Associations David Trustee & Vice- Y Volunteer Centre Faulkner Chair Volunteer Centre

Rachel N The Care Forum Robinson Chief Executive The Care Forum Caroline N Bath Area Play Partnership Haworth Co-ordinator Bath Area Play Partnership Bath Federation of Small Angela Y Businesses MacAusland Chairman Bath Federation of Small Businesses

N Age UK Janet Dabbs Chief Officer Age UK CITY OF BATH WHS STEERING GROUP

Chairman, City of Bath Peter Y WHS Steering Committee Metcalfe Cabinet Member for Sustainable N B&NES Council Cllr Ben Stevens Development B&NES Council Bath Preservation Trust Caroline Kay Chief Executive Bath Preservation Trust Historic Bryan Environment Y B&NES Council Cllr Chalker Champion B&NES Council

Y B&NES Council Cllr Martin Veal Chairman B&NES Council

Y Bath Tourism Plus David James Chief Executive Bath Tourism Plus Head of Fiona Commercial Y Bath Tourism Plus Humphreys Services Bath Tourism Plus

Y Cllr Cllr Gerry Curran Charter Trustees Executive Director Bath Chamber of Bath Chamber of Commerce and N Commerce Ian Bell The Initiative in Bath Chamber of Commerce

Bath & North East Somerset

Federation of Bath Residents Y FoBRA Nick Tobin Vice Chairman Associations

N Primary Sector Dr Anne Bull Head Teacher Weston All Saints Primary School

Malcolm Y ALCA Cllr McDowell Corston Parish Council

FURTHER AND HIGHER EDUCATION IN BATH Director of Studies, Department of Marion Architecture and Department of Architecture and Civil N University of Bath Harney Civil Engineering Engineering

Martyn Director of N University of Bath Whalley Estates University of Bath

Matt N City of Bath College Atkinson Principal City of Bath College Senior Lecturer in History & Bath Spa University, School of Y Bath Spa University Dr Kristin Doern Heritage Humanities and Cultural Industries

Y Bath Spa University Brandi Hall Student MA in Heritage Management MA in Heritage Management; Treasurer Katherine Council for British Archaeology Y Bath Spa University Collins Student South West

Thomas Y Bath Spa University Hewetson Student MA in Heritage Management Head of Alan Humanities Y Bath Spa University Dr Marshall Department Bath Spa University

SCHOOLS (secondary heads)

Bath Secondary Heads Y Group Tim Withers Principal Ralph Allen School

BATH PRESERVATION TRUST

Laura Head of Y Bath Preservation Trust Beresford Museums Bath Preservation Trust

Curator N Bath Preservation Trust Amy Frost Beckfords Tower Bath Preservation Trust

Tom Committee Y Bath Preservation Trust Marshall member Bath Preservation Trust

Edward Bayntun- Y Bath Preservation Trust Coward Chairman Bath Preservation Trust

Joanna Conservation Y Bath Preservation Trust Robinson Officer Bath Preservation Trust Bath World Heritage Site Enhancement Ainslie Fund Co- Y Bath Preservation Trust Ensom ordinator Bath Preservation Trust

Great Spas of Europe Y Project Paul Simons Paul Simons Associates

MUSEUMS

N Holburne Jennifer Stott Director

Stuart Y Museum of Bath at Work Burroughs Director Museum of Bath at Work

David N Jane Austen Centre Baldock Director The Jane Austen Centre BATH ROYAL LITERARY Vice-Chair of Bath Royal Literary and Scientific Y AND SCIENTIFIC INST Betty Suchar Directors Institution Patrick Y Bath Heritage Watchdog Hutton Chairman Bath Heritage Watchdog Y Bath Heritage Watchdog Jim Warren TRANSPORT GROUPS

General SENT REP First Great Western Rob Mullen Manager Central First Somerset and Avon Ltd

Y Canal and River Trust David Viner Heritage Adviser Canal and River Trust Works Y Canal and River Trust Becky Lakey Programmer Canal and River Trust

N Kennet and Avon Canal Trust Chairman The Kennet & Avon Canal Trust

Y Inland Waterways Association John Gornell Chairman Avon & Wilts Branch Nigel Y Bath Cycling Club Sherwen Bath Cycling Club Malcolm N Sustrans Shepherd Chief Executive Sustrans

N Living Streets tbc BATH CULTURAL FORUM

David Y Bath Cultural Forum Metcalfe Co-Chair Cultural Forum for the Bath Area

Marian N Bath Cultural Forum McNeir Co-Chair Cultural Forum for the Bath Area

N The Bath Bridge Phil Raby Chair The Bath Bridge Senior Arts Development N Cultural Strategy Ann Cullis Officer Arts Development,

Y Bath Festivals Belinda Kidd Chief Executive Bath Festivals Ltd EMPLOYERS N Wessex Water Colin Skellett Managing Wessex Water

Director Zillah Byng- N Future Publishing Maddick Chief Executive Future Publishing LANDOWNERS INTENDED, LATE Deputy Estate APOLS Duchy of Cornwall Nick Pollock Surveyor Duchy of Cornwall Property James Portfolio N St John's Hospital Edmonds Manager St John's Hospital INDIVIDUALS Y World Heritage Consultant Chris Pound Y World Heritage UK (WH:UK) Gillian Clarke Secretary Jurassic Coast World Heritage N World Heritage UK (WH:UK) Dr Sam Rose Site Manager Dorset County Council Director of Y Thermae Bath Spa Peter Rollins Marketing Thermae Bath Spa Richard Y Virtual Museum of Bath Wyatt Director Virtual Museum of Bath Margaret Y Springs Foundation Stewart The Springs Foundation Martin Secretary Alliance of Religions and N Kelston Manor Palmer General Conservation Avebury World Sarah Heritage Site Co- N Avebury World Heritage Site Simmonds ordinator Stonehenge Stonehenge World Heritage World Heritage Y Site Beth Thomas Site Co-ordinator ENVIRONMENT GROUPS

N Avon Wildlife Trust Dr Bevis Watts Chief Executive Avon Wildlife Trust

Claire N BTCV Dinsdale BTCV Avon South West Regional N Friends of the Earth Mike Birkin Campaigner Friends of the Earth Virginia Y Transition Bath Williamson Transition Bath Convenor - Transport and Built Environment Y Transition Bath Dick Daniel Group Transition Bath Regional Manager Woodland Operations N The Woodlands Trust Sally Glass (South West) The Woodland Trust BATH ABBEY

BISHOP OF BATH AND The Andrew Archdeacon of N WELLS Venerable Piggott Bath Diocese of Bath and Wells Y & ANOTHER Charles Footprint Project REP Curnock Director DEVELOPERS/ARCHITECTS Trevor Osborne Property Trevor Y Group Osborne Chairman Trevor Osborne Property Group Y Donald Insall Associates Peter Carey Consultant Donald Insall Associates Merlin N RegenSW Hyman Chief Executive RegenSW Conservation Y RIBA Bristol and Bath Lucy Inder Architect Donald Insall Associates Peter Community N Bath Community Energy Andrews Access co- Bath & West Community Energy

ordinator & fundraiser Stephen Managing Y Future Heritage Green Director Future Heritage Edward Y Nash Partnership Nash Senior Partner Nash Partnership CITY CENTRE MANAGEMENT INTENDED, LATE Bath Business Improvement Andrew APOLS District Cooper Chief Executive Mayor of Bath's Honorary Ann Mayor of Bath's Corps of Honorary Y Guides Twitchett Chairman Guides Tony Crouch : World Heritage Manager Alix Boswell/Visitor Service Assistants Jonathon Myers: Facilitator

APPENDIX 3: Press Release

A New Way Forward for Heritage

Members of the public are invited by Bath & North East Somerset Council to comment on plans to enhance Bath’s World Heritage status.

The City of Bath World Heritage Site Management Plan has been renewed with a draft published for public consultation. Bath is an exceptional site in that the entire urban area is inscribed as a World Heritage Site by UNESCO. Venice is the only other city within Europe which holds this honour.

Bath and the surrounding area benefits from World Heritage Site status as it attracts millions of visitors each year.

The unique merits of this prestigious city help to support many businesses to thrive, and makes Bath and North East Somerset even more attractive to companies looking to invest in the area. People living in and around the city can also benefit from the better quality of life that can be gained from a well-maintained conservation area.

Cities are dynamic places of change where people live and work, so the key challenge is to balance this thriving atmosphere alongside conservation of the globally important heritage.

The World Heritage Site Management Plan will cover the next six years and is produced and overseen by a well-established Steering Group with Bath & North East Somerset Council taking lead responsibility for the site.

Cllr Patrick Anketell-Jones (Conservative, Lansdown), Cabinet Member for Economic Development, said: “The state of conservation in Bath is currently exceptionally good, with considerable new investment being made to protect and preserve many of Bath’s landmark structures. Collectively we need to maintain this whilst carefully delivering growth to ensure the vitality of our world renowned city.”

The purpose of the Plan is to set out how this management takes place, what the main issues affecting the site and its landscape setting are likely to be, and how they will be addressed.

Looking to the future, World Heritage Steering Group Chairman Peter Metcalfe said: “Bath is a living city and the quality of our environment is a product of our exceptional people, both past and present. This is an ambitious new plan which positively seeks to enhance Bath’s position as a centre of heritage excellence and an outstanding place to live, work and visit”.

The draft plan can be viewed and commented upon at http://www.bathworldheritage.org.uk/management-plan or at Council One- Stop-Shops and libraries. The public consultation runs until Friday 15th July.

Ends.

Notes to Editors

Key Facts about Bath World Heritage Site

What is World Heritage?

World Heritage Sites are ‘places of Outstanding Universal Value to the whole of humanity’. ‘Outstanding Universal Value’ means cultural and/or natural significance which is so exceptional as to transcend national boundaries. There are currently (Jan 2016) 1031 WHS world-wide, and UNESCO adds a few new sites each year. Famous sites include the Taj Mahal, Pyramids of Giza, Great Wall of China and the Grand Canyon. The UK signed the 1972 UNESCO World Heritage Convention in 1984 and in doing so committed to identify, protect, conserve and interpret its sites and pass them on to future generations.

There are 29 (2016) WHS in the UK (and its overseas territories).

The City of Bath World Heritage Site

The site was inscribed on 12 December 1987.

The site is exceptional in that the entire urban area (approximately 29 square km) is inscribed. Only Venice provides a comparable example throughout Europe.

The 3 springs at the heart of the site are the only ones classified as ‘hot’ in the UK.

The hottest spring is the Hetling at 48oC and there are 43 minerals in the water.

The most voluminous is the King’s Spring, with a continuous flow of 13 litres per second or 1,106,400 litres per day. This flow will fill a domestic bath tub every 8 seconds.

88, 859 people live within the site.

There are approximately 5,000 listed buildings in the site, with the highest concentration of grade l and ll* listings outside of central London.

The site generates approx. 1,500 applications for Planning Permission and Listed Building Consent per year – undoubtedly the highest of any UK World Heritage Site.

A single conservation area of 1,486ha covers two thirds of the site.

There are 5 scheduled monuments covering 1.4ha (approx. 13% of the central area).

The surrounding landscape is covered by the Bath & Bristol Green Belt, plus the Cotswolds Area of Outstanding Natural Beauty (AONB), surrounding the city on its north, east and south sides.

There are 9 registered historic parks and gardens within the site, with 23 Parks and Gardens of local Historic Interest and 2 Sites of Special Scientific Interest

Approximately 4.5m people visit Bath each year, adding an estimated £380m to the local economy and accounting for an estimated 10,000 jobs.

There are 21 primary schools in or adjacent to the WHS, plus two universities with over 20,000 students.

Additional Journals Targetted:

The Heritage Journal, Antiquity, British Archaeology, Museum Association, Assemblage, Internet Archaeology, Thoroton Newsletter. Museum Association, National Geographic, British Heritage, Current Archaeology, National Geographic, Local History Magazine, Archaeology UK, Young Archaeologists' Club

APPENDIX 4: Table of comments and responses resulting from public consultation (Monday 23 May – Friday 15 July)

The table below details the feedback received during the eight week consultation period on the World Heritage Site Management Plan. In addition to feedback on five main questions the table also lists the response and actions, where applicable, that will be taken to address the consultation respondent’s points.

No. Name Organisation Comments Response to comment 1. Nick Federation Thank you for giving FoBRA the opportunity to comment on the (A response to these points was Tobin of Bath emerging WHS Management Plan 2016-2022 and please fed back to FoBRA on 3 June Resident’s forgive the reasons for the delay in this response for reasons 2016, hence the second FoBRA 21 Mar Association which have already been well-rehearsed. FoBRA’s input response (listed as number 6) 2016 principally covers three key areas: traffic, flooding and student below) (before accommodation. I shall deal with each separately: consulta Traffic tion 1. TRAFFIC officially Background comments opened) Background: accepted and agreed. Section 5.6 largely reflects these Traffic congestion and the associated air pollution is one of the comments already, although main threats to the WHS and the people who live and work in references to vibration and Bath. High volumes of traffic harm the setting of the Key damage to building fabric have Elements of the WHS such as Queen Square and The been added. Circus. Pollution and vibration from traffic threaten the very fabric of the WHS, while high levels of air pollution such as Following discussion at the those in Bath have serious adverse impacts on health. WHS Steering Group of 7 April UNESCO itself has made it clear that a transport plan for the 2016 Action 26 has been city is required. The Bath Transport Strategy (BTS) sets out a amended to read: blueprint for managing traffic in the city, and FoBRA believes the WHS Steering Group and the Management Plan should Action 26: Support actions to support it. FoBRA suggests the following amendments to the reduce air pollution, primarily Table of Emerging Actions table to reflect more accurately the caused by petrol/diesel powered

No. Name Organisation Comments Response to comment need for the Local Authority to deliver the BTS: vehicles, which is a direct risk to people and historic fabric within the WHS. EA 10. Amend to read: “Support action through the Bath Transport Strategy to reduce air pollution, primarily caused by Following discussion at the petrol/diesel powered vehicles, which is a direct risk to people WHS Steering Group meeting of & historic fabric within the WHS.” 7 April 2016 Action 5 was consolidated to read: EA 38. This should be separated into two actions, one to support the Bath Transport Strategy, as follows: Action 5: Monitor and engage with the delivery of the EA 38a. “Give support to and engage with the delivery of the Transport strategy (2014) Transport Strategy to protect the OUV of the WHS and support objectives in so far as they the Placemaking Plan”. relate to the WHS & seek to ensure they have no An additional Action could cover the development of the unacceptable impact on the P&R. However we believe that the term 'unacceptable' is OUV of the WHS and its setting. basically meaningless, because by definition one cannot accept the unacceptable; and moreover unacceptable to This has since been amended whom, and on what criteria? The real issue here is how to (see comment 13 below) balance the need to protect the Bath World Heritage Site by reducing traffic intrusion, and the potential impact on The point regarding the term environmental assets and amenity in the vicinity of the ‘unacceptable’ is noted, but is city. We suggest: retained as this is the term used in the Placemaking Plan policies EA 38b. “Review proposals for development of new or and other policy documents. expansion of existing Park & Ride sites to ensure that a Consistency with these policies reasonable balance is struck between the need to protect the is considered to be important. Bath World Heritage Site by reducing traffic intrusion, and the impact of development on the WHS & its setting.” Inclusion of explicit references to Park and Ride sites was

No. Name Organisation Comments Response to comment 2. FLOODING debated at the Steering Group meeting of 7 April. It was Background: decided to keep the references to transport initiatives at a 1. The Local Flood Risk Management Strategy is not relevant to the strategic level and Action 5 (see flood risk in Bath. It assesses groundwater flooding only. This is made clear in the introduction of the LFRMS. above) was amended 2. The main source of flood risk in Bath is from flooding from the River accordingly. Avon with many Grade I and Grade II listed buildings in the historic centre being at risk of main river flooding. Flood risk through Bath Flooding from the River Avon is the responsibility of the Environment Agency and not covered by the LFRMS. Background noted, although 3. It requires co-operation between B&NES planners and the EA to groundwater flooding is a risk to achieve this. 4. Central Government or outside funding will be necessary to provide archaeology. protection for the historic, residential buildings. 5. Bath is unusual in that many of the historic and significant buildings Agreed, and wording clarified in are in private hands and the WH Management Plan should seek to 5.10. support them in this. 6. The flood risk in Bath described as “unacceptable” in the EA Bristol The need for two actions on Avon Catchment Flood Management Plan. 2012. flooding is questioned. Amended action 23 is currently Therefore we propose that Emerging Action 7 should be the only action addressing this amended as follows: and reads as follows:

EA7a. “Engage with the Environment Agency and all relevant Action 23: Engage with all authorities to actively reduce the risk to the historic relevant authorities to mitigate sustainability of significant parts the WHS, e.g. Great Pulteney flood risk from the River Avon Street, posed by main river flooding. (Described by with regard to impact upon the Environment Agency as an “unacceptable” level of risk)”. OUV, & for parts of the site where groundwater & drainage EA7b. “For parts of the WHS where groundwater and drainage pose a flood risk engage with pose a greater flood risk than the risk of flooding from the River the emerging Local Flood Risk Avon, engage with the emerging Local Flood Risk

No. Name Organisation Comments Response to comment Management Strategy & other relevant documents.” management Strategy & other relevant documents. EA7c. “Undertake a risk assessment with respect to Pulteney Bridge at high river flows, in excess of 300 cumecs.” Your EA7b. See above. Your EA7c. This action would PS. On 17 March the Environment Agency published the fall to B&NES Property Services Severn river basin district flood risk management plan, to deliver. Property Services part of a much greater country wide document. There are have confirmed that recent many generalisations and cross references which are too inspections of the bridge have complex to go into here but it does state that the "Area of been undertaken and this World Heritage Site within area (ha): 2,850" of which 100 specific action is not considered hectares is at "HIGH Risk" of flooding. Rather disappointingly, necessary. it then goes on to say that the main problem in Bath is

"development of the river corridor". When the draft was Noted, and useful evidence to published last year, it stated then that there was no area at inform consultation input into risk, or even in the catchment, within the WHS and no the emerging Waterspace buildings or property. FoBRA is concerned that this continual Strategy. emphasis on development and not historic buildings and

residents in Bath is something the WHS Steering Group might Student Accommodation want to address. The Water Space study may an an

opportunity to get them to at the very least acknowledge the At the Steering Group of 7 April existence of risk. the issue of student housing 3. STUDENT ACCOMMODATION was discussed, prompted by the FoBRA suggestion. Background: The minutes record that: It was Student accommodation development is already and will acknowledged however that this continue to impact on the OUV. Without careful attention, large plan was not the primary means student housing blocks in the centre (= the most sensitive of addressing the subject, and area) could fundamentally change the WHS, and not any impact upon the OUV from necessarily for the better. FoBRA therefore proposes an student housing was indirect.

No. Name Organisation Comments Response to comment accompanying Emerging Action, perhaps a sub paragraph PAJ confirmed that he had within EA 4 as follows: received assurance that the matter would be addressed EA4f. “Engage with stakeholders to produce a workable through the Placemaking Plan. student housing strategy”. It was concluded that the matter should be acknowledged in the 4. BUILDINGS AT RISK text of the plan but for the consultation draft no specific EA16. We are not quite sure why SG members should get action is to be included. priority if their properties are “Buildings at Risk”. Perhaps you could clarify in as maybe there is some interpretation that is The proposed action is passing us by? therefore to add a paragraph to section 5.5 acknowledging the Please do not hesitate to seek clarification if needs be. issue, but directing readers toward the Placemaking Plan for action. The issue will also be added to the WH Risk Register.

Buildings at Risk The reference to SG members was intended to infer that those members should give priority to repairing any buildings at risk within their portfolios, and to set a good example. It is useful however that the FoBRA response has shown that this may be mis-interpreted and Action 27 has been simplified to read:

No. Name Organisation Comments Response to comment

ACTION 27: Act to remove properties (& other attributes carrying OUV) from the Buildings at Risk register.

2. Sue Group Ref page 32 – the air quality text seems to be in the wrong The narrative relating to the Green Manager - place - not under Action 26 which refers. In addition the actions is placed above the Public narrative can be updated and probably also the linked action. action, to act as an explanation. 23 May Protection Rob/Nicola – can you oblige please. The text is therefore placed as 2016 and Health intended but it will remain to be Improvemen seen from other responses if t this is causing confusion. No Bath & amendment proposed. North East Somerset Council 3. Virginia Convenor, Thanks for notifying us of the consultation on the draft WHS Email response 23/5 confirming Williams Transition management plan. that hard copies are available in on Bath food Will a hard copy of the document be available, in the One Stop library & one stop shop. group Shop or the Central Library? 23 May 2016 4. Adrian Corps of I have just spoken with Anne Twitchett. It is I who raised a Email response saying we Amber Mayor’s question over visitor numbers, when I saw the figure of 4.5M would be happy to amend given Honorary per year in the draft ManPlan. The figure of 5.7M came from the credible source of the 31 May Guides the BANES Economic Strategy Review 2014 - 2030. I should statistic. Amendment made as 2016 perhaps explain that I am not seeking to criticize - my simple suggested to include the higher interest is in quoting the correct figure! figure.

5. Anthony N/A 1. What do you most value about Bath as a WHS?

No. Name Organisation Comments Response to comment Grimley That the city isn't sprawling everywhere. The we have natural water springs both as an archaeological

23 May interest and a leisure facility. 2016 That most construction is sympathetic with the surroundings Comments regarding the weir even the modern builds. endorse Action 4 to engage in 2. What do you think diminishes its value? the replacement of Pulteney Ugly weir-side. It's an embarrassment. Weir. Comment to be passed Too many students. And thus too much student housing being through to the Waterspace built. Strategy. No change to the plan Having 'gated' communities such as the Riverside whereby made. residents are restricted on parking and have to pay the management company for upkeep. This is a dangerous The issue of student numbers precedent for the healthy development of housing in Bath. was discussed in Steering 3. What are the key risks to the site which should be Group (see 1 above). No planned for? change proposed. Park and Ride on Bathampton Meadows. It threatens key green space. It facilitates city sprawl eastwards. It does not ‘Gated Communities’ will be solve underlying problem of people driving into the city or as a reported to Placemaking plan route for heavy goods vehicles. authors. No direct role 4. What are the most important immediate improvements envisaged here for the WHS to make? Management Plan and no A proper, protected cycle lane on London Road. It would change proposed. provide an attractive alternative to driving as the current situation is ill conceived and half-hearted. 5. What are the most important improvements to make in the longer term? Join up Park and Rides with local buses and Park and Cycle. This will maintain bus services for local people who can't afford to run cars, and promote healthier alternatives. Park & ride link up suggestion 8. Any other comments noted. The Pedestrianisation of the High Street; the solar compactor

No. Name Organisation Comments Response to comment bins are great. More of this sort of thing.

6. Nick Federation Thank you for your message of 3 June hereunder. The FoBRA This relates to actions 5 and 26 Tobin of Bath Executive and key FoBRA leads for transport, planning, which were discussed and Resident’s flooding and student accommodation have considered your agreed at the WHS Steering 10 Jun Association response and are pleased that some at least of our comments Group of 7 April 2016. 2016 have been absorbed within the Consultation draft. However we are disappointed and not a little dismayed that the WHSSG There was no intention in the does not feel able to give its wholehearted support to the Bath above meeting not to support Transport Strategy. the Bath Transport Strategy and it is felt that there may be some Perhaps most importantly, the WHHSG should recognise that misunderstanding here. the Transport Strategy is official Council policy which was overwhelmingly approved by the full Council with all-party support in 2104. As an official Council-led body the WHSSG is Again there is no intention to surely duty bound to follow and support Council policy prioritise protection of the including the Bath Transport Strategy? setting over that of the site.

Furthermore, the Transport Strategy is the only means by which traffic in the city, with all the problems that it causes, is going to be reduced. Without a coherent, comprehensive approach Bath is either doomed to continue to suffer from traffic congestion and pollution, damaging to the people of Bath and the heritage that the WHSSG is charged with protecting; or at best we will have a series of piecemeal measures which fail to deal with the problem and may indeed cause undesirable and unintended consequences because the issue has not been tackled in a holistic fashion.

It appears that the Steering Group may be motivated by a concern that actions required to protect the WHS may have an

No. Name Organisation Comments Response to comment impact on the setting of the WHS. That at least is the inference we draw from your proposed Action 5. We think it is perverse, particularly for a body charged with protecting the WHS, seemingly to prioritise the setting over the WHS itself. We appreciate that the setting of Bath is important, but this cannot be treated as an absolute. It may be necessary to take actions to protect the WHS which have an impact on the setting. Any such action would need to be fully justified within the context of an overall transport plan. The key concept is the need for balance between the needs of the WHS and of its setting.

Therefore, we urge you to ask the WHSSG to reconsider its position and invite it to give its full backing to the Transport Strategy. Specifically, we ask you to use the wording that we proposed for EA10, and to amend Action 5 to place it in the context of support for the Transport Strategy, and not to treat it as a threat. Delighted, as ever, to discuss this further if necessary.

“FoBRA submitted its comprehensive comments on the first draft of the WHS Management Plan 2016-2022 on 21 February 2016. We were pleased to note that many of our comments on student accommodation, flooding and planning had been absorbed in the latest WHS Consultation Draft dated May 2016 but, in FoBRA’s further response to this draft dated 10 June 2016, we expressed our disappointment and dismay that the WHSSG, at its 7 April meeting, did not feel able to give its wholehearted support to the Bath Transport Strategy. We reminded you that this is official Council policy and requested the WHSSG to reconsider its position at its next meeting and

No. Name Organisation Comments Response to comment invite it to give its full backing to the Transport Strategy, specifically asking it to use the wording that we proposed for EA10, and to amend Action 5 to place it in the context of support for the Transport Strategy, and not to treat it as a threat.”

7. Tom National Just wanted to let you know I’ve received the paper copy – Noted. Acknowledgement email Boden Trust many thanks for this. sent.

13 Jun I’ve had another read through and I don’t have any further 2016 comments to add at this stage. 8. S N/A 1. What do you most value about Bath as a World Heritage On-line response Warren Site? Bathampton Meadows - a key part of the green setting and 19 Jun Green Belt referred to at many points in the document, and the 2016 one through which visitors from London and the east arrive in the World Heritage city, thus setting the tone for their visit. 2. What do you think diminishes its value? The threat to turn Bathampton Meadows into a carpark and dual carriageway. 3. What are the key risks to the site which should be planned for? The key risk is the threat by the countil to turn Bathampton Meadows into a car park, and the threat by Ben Howlett to turn what remains into a dual carriageway. 4. What are the most important immediate improvements to make? Remove the threat of turning Bathampton Meadows into a car park or dual carriageway. 5. What are the most important improvements to make in

No. Name Organisation Comments Response to comment the longer term? Reduce traffic and air pollution by improving availability, frequency and affordability of public transport in the city, and improving and increasing bike and pedestrian routes.

9. J N/A 1. What do you most value about Bath as a World Heritage On-line response Bransto Site? n The views into and across the city, interspersed with mature trees and landmark buildings of historic interest and/or 29 Jun architectural merit. The history of the city that is visible in the 2016 streetscape and landscape. The proximity of green belt and countryside and views outward from city streets into the The Skyline issue is identified countryside. as an attribute of OUV. 2. What do you think diminishes its value? Developments that obliterate and ignore the city's history and Pastiche building is generally prominently impose huge lumps of mediocre architecture into covered through the the landscape. Western Riverside is exactly one such. Placemaking Plan. SouthGate is another. Buildings that interfere with the skyline, such as those at Rush Hill. Buildings that pretend to respect Refuse collection comments history but in fact make a mockery of it, such as developing the noted and will be reported to the Bath Press site and treating the facade as an afterthought. relevant department. Indirectly Beyond that, the city's refuse collection system is not fit for related to the OUV. purpose and the scattered waste is an eyesore. There is nothing beautiful about e.g. the Paragon on a Thursday. Pressure for housing comment 3. What are the key risks to the site which should be supports existing actions 3 & planned for? 32. Pressure to build housing. We need more sympathetic infill before we build on fields, especially fields next to ancient Building of monolithic blocks to monuments such as the Wansdyke, or fields that effectively be reported to and addressed annexe former villages into the city. Sites such as the bottom by the Placemaking Plan. of Wells Rd / Rossiter Rd or Pines Way that were given over to

No. Name Organisation Comments Response to comment urban motorways in the 70s/80s could be completely Comment regarding empty sites remodelled to include small housing developments. Instead I to be reported to Steering see Pines Way will be another monolithic block. Group. Indirectly related to 4. What are the most important immediate improvements OUV. to make? Stop sitting on empty sites like Newark Works and the Corn Planning committee comments Exchange / Cattle market and regenerate these before giving support action 46 on member the go-ahead for edge-of-town housing that requires additional training. transport and infrastructure to get people to work and to city- centre amenities. Architectural competitions 5. What are the most important improvements to make in supports existing action 1 on the longer term? design advisory panel. Have a Development/Planning committee who are better qualified to send developers back to the drawing board where Development of northern slopes necessary. Parcel development land into smaller units to to be referred to the Planning ensure that even a large site is developed piecemeal and Policy Team. sensitively, rather than with brutalist blocks. The beauty of Bath is as much due to the coherence of its older, smaller buildings as it is to the set pieces. Hold more architectural competitions for public-funded projects. We need a bold but sympathetic outlook. Remember that most of the city's important amenities are north of the river and we are not blessed with a surfeit of bridges: therefore focus on sensitively developing city infill, the northern slopes and Lansdown plateau ahead of more southern sprawl.

10. Jasper Cllr I am glad to have the opportunity to add some comments. I feel Acknowledgement sent Becker very strongly that we are putting up some very poor modern architecture in Bath in general but particularly in new buildings 30 Jun going up around Kingsmead Square and South Quays, and 2016 Bath Riverside. In fact, I don’t think we should be putting up The Placemaking Plan leads on

No. Name Organisation Comments Response to comment any modern architecture as it detracts from the unique issues of architectural Palladian architectural heritage which brings so many tourists approach. and shoppers to Bath. The Georgian-style Green Park Student building at Green Park represents a far better alternative. I have tried to lobby fellow councillors on this and architects and I would be happy to expound on this in more detail.

11. Steve 1. What do you most value about Bath as a World Heritage On-line response Campbe Site? personally I like to arrive by boat and moor up by the ll rugby club 2. What do you think diminishes its value? 4 Jul the moorings have been closed, I have had a response to a This is a river management 2016 freedom of Information request that ststes no one knows why issue which is best addressed they have been closed but the moorings have not been by the emerging WaterSpace reopened Strategy. 3. What are the key risks to the site which should be planned for? people could drown because boaters who act as unpaid life guards are not allowed on moorings 4. What are the most important immediate improvements to make? to re open the moorings before someone drowns 5. What are the most important improvements to make in the longer term? to keep the moorings open and to develop them

12. Ian Cllr Most comments relate to specific Objectives and Actions in Acknowledgement email sent. Gilchrist Chapter 5. But first a note about the ‘Widcombe Parade’ scheme completed in June 2015, which is a successful local By email contributor to controlling traffic growth and harm. It has been Widcombe Parade has been expensive (total ~£2m), was difficult in implementation, and added to the list of 2015 even now is not without residual issues, but I think can be achievements.

No. Name Organisation Comments Response to comment considered an examplar for other possible community regenerations in the future [Objective 3 and Action 7]. The comment is in support of Other comments: possible relaxation of building [Action 2, Building Heights] We have to recognise that the height levels whereas the plan population is growing, and there is no reduction in the number is written from the viewpoint of of people who want to live in or near Bath. If we don’t want to restricting heights. However be expanding outwards, then there is only one way to go, action 2 states that heights namely upwards. This means that the Building Heights should be ‘managed’ which is Strategy may need to be relaxed to allow taller buildings than deemed to cover both is currently the case. I’m not talking about City of London scenarios. levels, and certainly would not want to see the Abbey disappear from view, but some upward growth seems inevitable. Steering Group of 28 July [Action 3. Major Plans] There has been talk of a new visitor decided that it would not be attraction, the Aqueye, to be provisionally located in the vicinity appropriate/necessary to of Pulteney Weir. Mention of this is not included in the draft specifically mention this project. plan, though the Radial Gate is. If the Aqueye does achieve lift- off in the sense of submitting a planning application its possible effect on an iconic city view, namely of Pulteney Bridge and the Weir will need careful consideration. [Action 6. Engaging with Central Government and The comment on engagement Neighbouring Authorities]. This is currently very topical with with neighbouring authorities the WoE Devolution Deal about to start public consultation. supports action 6. While this is sensibly rather Bristol-focussed, it should not be overlooked that Bath lies very close to the Wilts border, and that major rail and major road routes come in from this direction. There is the potential with both transport modes to do good for the Bath WHS, but only if they consider transport from Street lighting action is included the Wilts side as well as Bristol. in action 28. [Action 28. Street Lighting] My recent experience with the installation of LED street lighting in residential streets

No. Name Organisation Comments Response to comment (particularly Lyncombe Hill) is that this can lead to a harsh and unsympathetic light, which is not suitable for a conservation area, especially where Bath stone buildings predominate. I understand that ‘warmer’ forms of LED lighting are possible, and I therefore urge that consideration be given to ensuring that they are used wherever possible.

13. Amanda I am writing with regard to the proposals for a Park and Ride Acknowledgement sent. Archer- on the Ancient Meadows at Bathampton (Management Plan Brown Consultation Doc, Batheaston 5:2:31). This response focusses on Park and Ride. The Plan looks to the 7 Jul The evidence stacked against the need for these doomsday ‘Getting Around Bath’ Transport 2016 meadows to be turned into a park and ride is high: Strategy to investigate improved transport in and around the site  Traffic into Bath along the roads this will supposedly and to address any risks to serve has reduced year on year since 2000, the only OUV posed by transportation. increase being in LGVs which appear to be traversing Bath. The consultation draft action on transport read as follows:  The meadows flood - whilst MPs who want to build the P&R claim the river will not be affected they are not Action 5. Monitor & engage with taking into account the enormous loss of soak away the delivery of the Transport these meadows will no longer provide. The Strategy (2014) objectives in so environment agency are unable to give figures on this far as they relate to the WHS & potential impact. This will affect the canal and the river seek to ensure that they have in future. I contacted a published academic in the field no unacceptable impact on the to try to ascertain the level of impact this would have on OUV of the WHS & its setting. the rivers: He explained: "If for example is 50% of the runoff is being retained by the natural surface then At the Steering Group of 28 completely paving over will increase runoff by July, in response to 50%." This might seem obvious, but it appears the consultation comments, the

No. Name Organisation Comments Response to comment council are only using figures which are created from following amended wording was past flooding not predicted flooding incorporating the agreed: impact of the loss of such huge drainage space. Action 5. Engage with and  Existing park and rides are not being used in Bath - monitor the delivery of the SBM can provide you with a list of those days Transport Strategy (2014) (Christmas, Bank Holidays, Marathon day etc) when the objectives & seek to ensure that park and rides are ridiculously under-utilised. Research they deliver maximum benefit & from UWE demonstrates that P&R's do not work and no unacceptable impact to the are favoured primarily by the local elderly community. OUV of the WHS & its setting.

These are just three points of evidence. Bath's beauty has The revised wording leads with survived Romans, Saxons, dissolution of the monasteries, engage, which is a positive three rounds of Plague, Civil War, Cholera, German Bombs - action as opposed to monitor please help us protect the meadows for future generations. which is more passive. It omits the ‘in so far as’ wording in order to give more unqualified support to the strategy and includes reference to benefit to again accentuate the positive. It does not use the word support, as there may be harmful elements in the Transport Strategy which could not be offered support. As discussed at April 2016 steering group, ‘unacceptable impact’ is retained as this is consistent with wording in the Placemaking Plan.

No. Name Organisation Comments Response to comment

14. Ann Arts Preface by Chairman of SG Acknowledgement sent. Cullis Developmen Needs proofing – there are one or two grammatical t, B&NES inconsistencies / infelicities Noted. The Chairman should conclude by thanking Tony Crouch the WHS Manager without whom none of this would be possible – get Helen to write it if you won’t!

P10, 2.3 – boundary There needs to be a diagrammatic / illustrative map very near Agreed. This will be looked at, the beginning of the document, to show the ‘red line’ although it will involve demarcation. There are OS maps towards the end of the considerable re-formatting and document p47ff, but these are more detailed and convey re-numbering. specific info. At the beginning you need something very basic to show where the boundary is. I’d put it immediately before or after the Contents page – gives a sense of place to orient you as you start to read the plan.

P12, 2.6, top of fourth column Agreed. A sentence has been Refers to main tourism season is summer. Should also added. mention November/December = xmas market?

P15, bottom of fourth column. Refers to Destination Marketing Strategy Noted. A sentence has been New Destination Management Plan to be created & published added. during 2016

P21 – box for 2014 achievements Subject to space allowing, this Add? – Publication of the Council’s Cultural & Creative has been added. Strategy

No. Name Organisation Comments Response to comment P22, 4.3 (column 2) Para 4 ‘B&NES Council’ heading in bold – should be Bath & Noted. Agree and this has been North East Somerset Council in full changed. I think it should be in full every time it’s referred to?

P22 column 4 Reference to Bath Spa University – students 5,500 in 2009 Suggest check & update to more recent figure – they have To be checked with Bath Spa expanded a lot Uni.

P23, 4.4 (column 1) Bath Tourism Plus para – line 7 – close space at end of line Refers to over 500,000 visitors p/a to VIC – I think it may be now slightly less – suggest check with BTP. (it’s less because of increase in online activity rather than walk- up)

P29, 5.5 ff If I’m understanding it right, the way this is laid out is that there Noted – to be discussed with are 2 or 3 paras of text and then the point is summarised as the print designer. Objective x, Action x (highlighted amber & pink respectively). Then it moves to another few paras of text on a different topic, and then the point is again summarised as Objective x, Action x. I found this difficult to navigate because I kept reading the ‘Objective x, Action x’ as a header for the text that follows, not as a summary of the text that precedes.

It would work better if the Objective x, Action x were a heading, placed before the relevant text?

No. Name Organisation Comments Response to comment Or, if you need to leave Objective x, Action x after the text as it is now, then I suggest do a double-space after each topic.

P34, 5.15 para 1 No. visitors, jobs in tourism and visitor spend 2013 - suggest check with BTP for more recent figure?

15. Rohan Historic Thank you for sharing the draft Plan and inviting our Torkilds England comments. en & Noted – has been changed. Henry 3.1 Para 1 should be World Heritage Committee not Centre Owen- John Page 21, second column, fifth paragraph. The November 2014 Noted and has been changed. report was submitted by DCMS to UNESCO 8 Jul 2016 Page 21, third column, 2012 box (and elsewhere in text) use Agree and has been changed. Supplementary Planning Document rather than SPD – the latter may not mean anything to the lay reader

Page 24 Section 4.9 should also refer to the National Planning Agree. This has been added Practice Guidance and the section of it that is specifically about under 4.9 World Heritage. This could be added to the footnotes and a link provided. This is a typo and reference to PPG has been deleted. Page 24 Section 4.12 – I don’t understand the PPG 12 reference

Page 25 – 26 section 4.18 about para 172 notifications.

“The high number of reactive monitoring missions sent to the UK have almost exclusively been triggered by major

No. Name Organisation Comments Response to comment developments, which suggests that the planning system is not working wholly in harmony with the expectations of the UNESCO convention. Current moves by UNESCO to get ‘upstream’ of major developments are welcomed.”

Suggest the above is replaced by the below as we do not want to draw undue attention to the high number of RMMs and because the upstream process as defined by UNESCO and Noted and suggested wording the advisory bodies applies to WHS nominations rather than will be used. development proposals.

“Reactive monitoring missions to UK World Heritage Sites are usually triggered by major development proposals. The statutory timescales within which planning applications in England have to be determined can make it difficult for the advice provided by missions and the World Heritage Committee to be taken into account in planning decisions. Via DCMS, B&NES will continue to liaise closely with the World Heritage Centre and ICOMOS in order to address this difficulty.” Valid point and some positive references will be added as Page 28, section 5.1. It would be good if this could be made suggested. more positive - rather than only seeking to ensure that new development does not harm OUV (vital though this is) this Noted. Meeting held with Tim paragraph could emphasize the potential for OUV to inspire Hewitt and panel details excellent new development. ascertained. These will be added. Page 29 section 5.5. Again I think this section could be made more positive about the potential for an understanding of OUV to inspire the new. At Action1 I would suggest that it should be a heritage and design panel or conservation and design panel

No. Name Organisation Comments Response to comment to help ensure that design is influenced by an understanding of place This change has been made. Page 29 section 5.5 para 3 – should be Design Council/CABE I Events have moved on since think (and as above shouldn’t be restricted to just design) this section was drafted.

Page 33, fourth column references to Great Spas of Europe Valid point. The change was should be amended to say that the original 16 towns have now reported to the Steering Group been reduced to 11. who agreed to a wording change. Page 34, action 39 refers only to those with limited mobility. It would be better if the commitment to better access could be extended more widely to those with disabilities

Action 6: Engage with central government & neighbouring authorities as necessary to reduce the impact of major road traffic routes passing through the WHS. Resources An objective of producing link road options for inclusion in Highway England’s funding programme was confirmed in B&NES cabinet budget 2016/17. Monitoring Indicators - Evidence of discussions

- Recognition of Bath as an ‘Exceptional Environmental Noted. Scheme’

- Inclusion of provisions within the 2015-2020 Road Investment Strategy funding programme

No. Name Organisation Comments Response to comment Neither the Bath Transport Strategy, the Core Strategy nor A full answer to this Placemaking Plan appears to make reference to a Link Road. (Exceptional Environmental Is it appropriate for the MP to do so? Scheme) was given at Steering Group, but it was considered What is an ‘Exceptional Environmental Scheme’? unnecessarily complex and the reference will be removed. Is it premature to include an indicator to secure funding when the principle of a Link Road has not been agreed or commitment made to a Link Road in any statutory development plan? This issue was checked with Highways (Peter Dawson) who Historic England do of course recognise the merits of Action no suggested replacement wording 6 to reduce the impact of major road traffic routes passing relating to improvements to the through the WHS but wish to clarify whether it is for the national trunk road network. WHSMP to include and so endorse the principle of a Link Steering Group (28 Jul 2016) Road, where neither the Bath Transport Strategy nor Local agreed. Plan appear to, and in turn, the WHSMP being monitored on the basis of being successful in securing funding for it? Yes. Checked with Tim Hewitt Action 8 and 10: Public realm investment. and references to LEP and As the quality and condition of the historic environment is developer contributions added. related to the economic performance and well-being of the city might the WoE LEP and CIL help to resource the funding of such initiatives? Good suggestion. Reported to Action 9: Ensure that the Bath Pattern Book is adhered to & the Steering Group who agreed. updated as necessary to guide street works in the WHS. Indicator changed accordingly. Monitoring Indicators Incidences of street works undertaken in accordance with the Pattern Book Noted and the action and supporting text will be amended

No. Name Organisation Comments Response to comment A Perhaps a more effective indicator could be rephrased: to refer to the Heritage at Risk Incidences of street works that were not undertaken in rather than Building at Risk accordance with the Pattern Book. registers.

Action 27: Heritage at Risk Paragraph 2.7, 5.1 and Action 27 need to be revisited and augmented as the national Heritage At Risk Register now also includes the condition of CAs, RP&G, Battlefields; Wrecks, Scheduled Monuments and LBs (I&II*). As this national register is maintained and regularly updated it provides a useful means to monitor the condition of most heritage asset types within the WHS. https://historicengland.org.uk/advice/heritage-at-risk/

Action 29: Bring forward Conservation Area appraisals for areas within Bath Conservation Area. Timescale 2016 -17 Monitoring indicator – Number of Appraisals prepared in draft

Conservations Area Appraisals and Management Plans are important tools to inform appropriate change within the WHS and in fulfilling B&NES’s duty under the 1990 Planning (LB and CA) Act to review the conservation area and its boundaries and formulate and publish proposals for the preservation and enhancement of the area (Section 71).

A component of the B&NES Core Strategy is to maintain up to date Conservation Area Appraisals and the Placemaking Plan provides a commitment to complete the Bath Conservation Area Appraisal recognising the lack of a completed appraisal for the Bath Conservation Area is a weakness in its This matter was checked with

No. Name Organisation Comments Response to comment development management function. the Historic Environment Team, but they did not have the It is important that the WHSMP therefore reflects the above certainty over future funding to Local Plan commitment s and statutory obligations more support the timetable as explicitly. Currently the completion of “drafts” within the next 2 suggested. years leaves the matter rather open-ended. Perhaps the Indicator could read “The completion of the remaining Conservation Area character area appraisals in draft by the end of 2018 and their adoption by the end of 2019”.

I hope our suggestions are helpful. If you have any queries do please contact me.

16. David Bath Under 1.6 Aims III if we are going to Aim ‘to maintain and James Tourism promote Bath as a living and working city which benefits from Plus WHS status’ by implication must should have a Marketing 8 Jul Strategy and Marketing Plan to achieve this. The Draft Plan 2016 does not refer to such as Plan. However there are many mentions within section 5 about parts of such a Marketing Plan. Similarly if we are going to have an Aim under 1.6 V to ‘improve public awareness’, a Marketing Strategy and Plan would be very helpful in the delivery of this Aim. We would Noted. This will be changed. suggest that it is the established Destination Management Organisation (DMO) for the City – Bath Tourism Plus, that delivers this support . Figures have been updated. Under 2.6 it states that Bath continues to attract approximately 4.5m visitors which is repeated in the Key Facts. The latest figures we have are the ones you use on section 5.15 Visitor Management. We should be consistent on the data which is correct in section 5.15 Steering Group acknowledged

No. Name Organisation Comments Response to comment the importance of marketing but Under 5.4 Priorities I would like to suggest that we make did not consider this should be MARKETING a priority. Many of the actions under added to the priorities. Interpretation relate to Marketing and as stated above if we have an Aim of promoting the City/WHS status, we should make marketing a priority, delivered by the current Destination Management Organisation, Bath Tourism Plus. A review of wayfinding is currently underway with Under 5.6 Transport we do not refer to the situation we have in consultants appointed (June regards to Coach parking. The Riverside coach area has been 2016) to look at this. Steering removed and the current arrangements may lead to us Group agreed this was an issue attracting less coaches (less environmentally sustainable if which should be monitored and people resort to cars). We want to promote less car use and a new action has been added. more public transport and the use of coaches. Can we identify this as a problem area?

Under Public Realm 5.7 we do not yet refer to City Dressing which can add colour to the City and inform residents and The offer to deliver some visitors about forthcoming events. When major events do come actions under the Marketing the city of full of WARNING signs that roads will be closed Strategy is interesting and will (negative signs) but we do not have a system of dressing the be the subject of discussion. city with colourful banners, bunting, and new creative methods such as lighting up buildings. Council permission can take too long and there is no single point of contact. Surely we should encourage events and city dressing to make the city look even better during events. Who would know for example when the Noted. The wording ‘voluntary Bath Music Festival is on? Look at what Southgate have just contribution has been inserted done with the colourful umbrellas to make the city look into the text and with Steering wonderful for a few months. Group agreement, into the action. Wayfinding is also a major issue and I am asked daily for the

No. Name Organisation Comments Response to comment return of finger posts to be put back in the city.

Under Public Realm could we investigate developing areas Agreed. It was (and is) within the city which are presented differently. Many cities use intended that this action is ‘culture quarters’ and we could have a Spa Quarter, retail delivered by the Destination areas such as Southgate are very different from Milson Place Management Organisation. or Walcott Street, Widcombe etc. could we use signage and public realm to better effect.

Under 5.8 Action 12, 13, 14, 15, 20 and 21 could all be part of an overall Marketing Strategy and Action Plan, delivered by Bath Tourism Plus. Social media, digital platforms such as the Agreed. To be added in 2.6 website, Facebook, literature production, signage, the brand and a WH Day could all be brought under the Marketing remit. I would suggest that Bath Tourism Plus are given the overall responsibility to develop such a strategy and act as the agency responsible to deliver the Plan.

Under 5.15 Visitor Management –I am not aware if we can ‘continue to explore options for a visitor tax. This will be a central government decision and I see no evidence of its support or even if it is being talked about as a future possible option. What we would suggest and support here is a voluntary contribution that is collected and specifically ring fenced to keep Bath “Special and Unique” and directly supports the World Heritage Site and it’s unique mix.

Under Action 41. There is no actual Destination Management Plan in place at the moment (it reads destination marketing plan but should use the word management instead of marketing). The last DMP ran out in 2015 and we are hopefully

No. Name Organisation Comments Response to comment going out to consultation shortly to produce a new DMP for the period 2017-22. A Sustainable Tourism Strategy should be picked up by the proposed Marketing Strategy I suggested above. This again should be orchestrated and managed by Bath Tourism Plus. You don’t need two strategies.

It might be useful to point out that BTP also runs the Bath Christmas Market which obviously takes place within the boundaries of the WHS.

17. Adam Cycle Bath When considering Bath as a heritage site then the primary Reynold focus of any approach to managing Bath has to, at all times, s protect, and where possible, significantly increase the Outstanding Universal Value that the city represents. 8 Jul 2016 As the opening chapter states: “The City of Bath has been a World Heritage Site (WHS) since 1987, recognised as a place of Outstanding Universal Value (OUV) for its architecture, town-planning, landscape, archaeological remains and its role as a setting for social history”

It is within the context protecting and enhancing the architecture and shaping town-planning that the OUV is of primary concern to myself.

However within the city itself there are fundamentally flawed political and local authority structures that hinder and could be The plan is based on working said to justifiably undermine the OUV. within the current local political management framework in place. It would be highly

No. Name Organisation Comments Response to comment unusual and unlikely that the Political Flaws Steering Group would seek to lobby for change in this system. When examining the political structure of Bath and North East Somerset, the current cabinet council has only one cabinet member that lives within the city. When examining the “voter- base” of the current administration (and any future administrations) it can be seen that when the controlling party within the council is from wards outside of the city, any decisions that will be made about the city will not detrimentally impact the external wards and their resident. This creates a scenario where the OUV is threatened by the political structure of the city. Council strategy on this matter It is why an East Park and Ride on the edge of the east side will be in accordance with the city is being proposed by councillors from external wards as adopted Getting around Bath there is perceived to benefit them, but is generally opposed by Transport Strategy (2014) and internal ward councillors. More telling is that a modern rethink this Plan is accordingly linked to of P&R solutions is the “Link and Ride” solution is not being that document. considered . This is where you build a number of smaller car parks next to the conurbations that will be using it and then use This refers to a specific decision existing local bus services. Which means building in Wiltshire, and does not point to any outside of BaNES and therefore not a vote winner. changes in the Plan.

Another example is that there has been a diktat from the Cabinet Member For Transport that no officer is allowed to reduce parking in the city. Something that every other modern city that is trying to tackle congestion is doing. This directly undermines the OUV.

A further example is the refusal by Cllr Tony Clarke of the

No. Name Organisation Comments Response to comment pedestrian crossing across Oakley on Bathwick Hill. This crossing was the final piece in a 14 year jigsaw to connect Combe Down to Bathwick via Rainbow Woods. All the objections were countered by officers stating how many pedestrians and cyclists are trying to use the area and how Not an issue for the Plan and vital this crossing is. The councillors refused it as it might not necessarily supported by impact traffic flow and people are buying more cars these evidence. There is a regular days. It is also a vote winner. The OUV of the city was turnover of staff in many senior undermined by that decision. positions.

What I am saying is that the OUV should be the absolute objective that overrides political games. That the city must be able to make choices that are determined by the OUV and that the transport policy decisions within the city must be to enhance the OUV and not be political maneuvers to pander to This comment does not external wards. accurately reflect the stated aims and ambitions of that Local Authority Structural Flaws strategy.

As with any organisation, and particularly council hierarchies, people slowly move up through the ranks, over 10s of years. What this means is that you can get to the situation where people in very senior positions have extremely fixed ideas about how the city should move forward. This can be reflected within policies that come out of departments and directly undermines the OUV.

This is not a criticism of individuals but more of a criticism of Noted and supported by Action the values and focus that council departments have. 39.

So if you look at the Bath Transport Strategy “Getting around

No. Name Organisation Comments Response to comment Bath”, the emphasis, even within the title, is that it should be easy to get around Bath. However this emphasis translates directly into the Highways department working on maximising vehicular traffic flow.

The BTS states that “Pines Gate Gyratory” should be broken. A hugely significant increase in public space. However Highways refuse to budge on this as it messes with their transport models.

The focus of Highways and other departments should be to protect and enhance the OUV and to not focus on traffic flow, something that again undermines the OUV.

Ironically this can work the other way. Recently a clay path was installed in Green Park, rather than an asphalt path with spray and chip surface. Now, in principle this enhanced the OUV and provided a “more natural” surface. In fact it’s a very hard surface to use a wheelchair on. So the OUV must not sacrifice accessibility.

The way forward The OUV is absolutely critical to Bath and the city should be focused on protecting and enhancing this. In particular it needs to educate the residents to the necessity of protecting the OUV. This education process must also be done throughout the council officers and councillors. That it almost becomes a legal requirement.

The management plan should also have within it recognition of

No. Name Organisation Comments Response to comment good road space design. Where possible it should look to best in class approaches to congestion management from other cities. Examples are:

1. Congestion Charge :- Reduced traffic by 20%. A similar approach to Bath should be considered. 2. A congestion “through” charge:- Where you are welcome to come into the city, but get charged if you drive out on a different road. This builds off the work Assen, Netherlands has done, where cars can only travel into the city and come out on the same route. You can go round the city, not through it. 3. Major routes through the city to be redesigned on “modal share” rather traffic flow. This would enable delivery of segregated space for walking, cycling and driving. Priority is given to pedestrian space, then cycle space, then motor space, finally if there is room, space for onstreet parking. 4. Road space re-allocation (road diets) to be a key part of any road resurfacing programme. Most roads only need lanes 3m wide (and routes with no bus routes can have lanes that are 2.5m wide. 5. Workplace Parking Levy :- Used by Nottingham to fund their tram system. 6. Bath wide Parking Control :- When Bristol brought in RPZ to Clifton there was massive objection. It’s been successful at reducing traffic into the city and P&R saw an immediate 20% increase in use. Note you can keep it cheap/free for residents, but sell permits to commuters at the same rate as the Workplace Parking Levy. 7. Legally capping parking spaces in the centre of Bath,

No. Name Organisation Comments Response to comment then building multi-story underground car parks forcing the removal of on-street parking. Zurich did this to restore streets back to how they should be enabling them to create huge pedestrian zones. 8. Extensive use of rising bollards to pedestrianise the whole of the city centre. Roads that should be “blocked” with rising bollards. Some are Dorchester Street, Milsom Street, Cheap St, Westgate Buildings and three sides of Queen Square. 9. Core principles that cities are adopting when dealing with congestion, is to make it harder to travel through a city. There should be extensive use of “filtered permeability”. When I’m coming down Wellsway heading to the M4, my best and quickest route should not be through the city and up the the Circus. Even getting to London Road can be quicker via Queen Square.

All the above are politically unwelcome choices yet they massively enhance and protect the OUV. They encourage people to walk and cycle. They discourage taking cars into the heart of the city and slowly having the fumes eat away at the fabric of the structures.

What you must do is that many of the above policies will generate significant income for the city and this income must be ring-fenced to transport and to particularly provide better discounted public transport services. The OUV of a city is enhanced every time somebody chooses not to get into a car and drive.

No. Name Organisation Comments Response to comment 18. Les N/A As a private individual and business owner I would Redwoo wholeheartedly endorse the WHS - this has substantial benefit d and value to the city and surrounds and should be a key factor in all strategic decisions that are made in the city. 8 Jul 2016 I fully endorse the key priorities of - Managing Development Transport Public Realm Interpretation and Education Environmental Resilience

I further endorse the Sustainable Use priority

I recommend that the World Heritage Site has a dedicated Marketing Organisation to promote and sustain the WHS - I suggest this should be Bath Tourism Plus

Coaches parking are an issue for the city - with the removal of Steering Group (28 July 2016) the parking - this needs to be addressed decided to include an action on this matter. The community should support the WHS and BTP should be instructed to educate and promote the site

Wellness/Walks/Sports and other physical activity should also be encouraged and supported by the WHS

I specifically endorse the following action points as a priority -

1- advisory panel 2- building height 3- engage with planning policy 4- engage with Major Developments 5- engage with Transport Strategy

No. Name Organisation Comments Response to comment 6- engage with govt and neighbouring LA's on transport 8- public realm improvements 11- interpretation centre and Archway Project - Bath Tourism Plus (BTP) to assist here 12- website - BTP to assist here 13- WH day - BTP to assist here 14 - WH social media - BTP assist 15- WH brand - BTP to assist 16- assist with premises 17- signs and way marking 20 - support ongoing co-ordination of cultural offer 23- flood risk mitigation 26- air pollution action 31- support Bathscape 32 - housing numbers allocation 33- SSSI for hot springs 35- trans national WH bid 36- support conservation funding bids 37- WH enhancement fund 40- plan to make this a Voluntary Contribution - operated and managed by Bath Tourism Plus. BTP to do immediate feasibility study into this proposal . 41- sustainable tourism strategy - to be delivered by BTP. 42- WHS - steering group 43- WHS- SPD 44- reports 45- maintain links 46- training to stakeholders

Please include me as a consultee and kindly copy me in on any enews or on any updates.

No. Name Organisation Comments Response to comment

19. Anonym What do you most value about Bath as a World Heritage Site? ous It's beautiful rural green environment and its hot springs. 2. What do you think diminishes its value? 6 Jul Pollution. 2016 Too many lorries on the London road. Not enough opportunities for cyclists to cycle safely (some of the large pavements, ie. the paragon and the london road are large enough to have cycle lanes on.) Buildings that are not in harmony with the georgian city or its natural surroundings. 3. What are the key risks to the site which should be planned for? overcrowding. Fracking - this should not happen anywhere near Bath, the council has a duty to protect its springs. 4. What are the most important immediate improvements to make? With regards to overcrowding - The Roman Baths should probably do less advertising, as the current numbers of visitors it draws are damaging the roman remains and causing over crowding. With regards to pollution, lorries should be stopped from using Bath as a through route and cycling and bus services should be improved. Bath does not need another park and ride. They See response to comments 13 are not proven to be sustainable transport solutions. Under no & 24 in relation to a possible circumstances should Bathhampton Meadows be considered eastern Park and Ride site. for a park and ride site. This is a historic site of natural beauty and OUV that can be seen from Solsbury Hill. 5. What are the most important improvements to make in the longer term?

No. Name Organisation Comments Response to comment sustainable transport solutions (this does not include park and rides). a greener city. more provision for cyclists. water fountains for tourists and locals to minimise plastic waste (and to give something back). plant lots of trees: plant them to the right of the abbey in abbey square (with the recent festival where the square was filled with trees for the imaginary forest it looked amazing! - lots of people commented on how good it looked.) Plant them down Great Pulteney street (this used to be a tree lined street). Plant trees wherever you can, they give us oxygen and reduce pollution! The green colour of the trees shows off the beautiful Bath stone (it does not obscure it) - I regularly walk past the circus and the tourists love those trees, there are always people under them. 6. Your name me anon e mouse 7. If you are responding on behalf of an organisation please list the name of the organisation below 8. Any other comments Bath does not need another park and ride. They are not proven to be sustainable transport solutions, in fact they encourage car use. The bus service needs to be improved. Under no circumstances should Bathhampton Meadows be considered for a park and ride site. This is a historic site of natural beauty and OUV that can be seen from Solsbury Hill. The issue of fracking is covered by an action in the Plan In recent times the idea of fracking in the Mendip hills has been mentioned. As discussed in this report the council has a duty to protect the springs of Bath and so they need to ensure that no fracking takes place in Bath or the Mendips or anywhere

No. Name Organisation Comments Response to comment nearby, to protect the waters.

Thank you for considering and taking on board all my comments.

20. NC. What do you most value about Bath as a World Heritage Site? Bath Unique attraction to visitors with close links to rural beauty resident spots as well as and key historical site in the City itself for education. 7 Jul 2. What do you think diminishes its value? 2016 Poorly thought out modernisation which is not in keeping with the value of Bath (as above). Modernisation for its own sake and with financial gain as short term goal. 3. What are the key risks to the site which should be planned for? No comments. 4. What are the most important immediate improvements to make? No comments. 5. What are the most important improvements to make in the longer term? No comments. 6. Your name NC, Bath resident since 2002. 7. If you are responding on behalf of an organisation please list the name of the organisation below 8. Any other comments The Park & Ride to the East of Bath is a major concern. There is no clear evidence suggesting that Park & Rides significantly reduce congestion. Opinions are thrown around as though they are fact, especially by the local MP who appears to be looking for a "legacy" moment. Facts about the effectiveness and overall use of the P&R sites

No. Name Organisation Comments Response to comment needs to be set out before any consideration of building a 4th site should be undertaken. A P&R car park can be built in a short amount of time but the area affected can never be returned to its natural state if it turns out that a P&R was not a good idea in the longer term. If the meadows are destroyed then 100s of years of slow development of a site of natural beauty will be lost forever. Who is going to gain from the P&R financially? I imagine it is they who are lobbying strongest for the P&R rather than a real need for such an enterprise.

Thanks.

21. Alex What do you most value about Bath as a World Heritage Site? Field The Georgian architecture alongside the parks and the countryside around the city. 7 Jul 2. What do you think diminishes its value? 2016 Inappropriate and ill-considered development, for example the proposed park and ride on Bathampton meadows. 3. What are the key risks to the site which should be planned for? Loss of green space e.g Bathampton meadows (the uniqueness of Bath comes from the architecture in a beautiful setting. Also, over exploitation, local people unable to afford to live in Bath and the loss of independent shops to chains. 4. What are the most important immediate improvements to make? Abandoning the proposed park and ride for Bathampton meadows. 5. What are the most important improvements to make in the longer term? More bus and trains between Bath and neighbouring towns.

No. Name Organisation Comments Response to comment 6. Your name Alex Field 7. If you are responding on behalf of an organisation please list the name of the organisation below 8. Any other comments I think the proposed Park and Ride on Bathampton meadows is exactly what should not be happening to a world heritage site. The site is unique and part of what makes Bath precious. To dig them up for a car park would be an example of vandalism and makes a joke of any concern for Bath as a world heritage site.

22. P Davis What do you most value about Bath as a World Heritage Site? Its surrounding fields and hills, providing a green backdrop to a 10 Jul Georgian gem, are visible from almost everywhere in the City. 2016 The two together complement each other. The history, pre-Roman through to 20th century innovation, adds a hidden but important dimension as a cultural meaning to the architecture and its setting, not least the continuing impact of the hot springs. 2. What do you think diminishes its value? Poor 19th and 20th-21st century buildings which clash with the mellow and harmonious Georgian inheritance. 3. What are the key risks to the site which should be planned for? The loss of Bath's hot water would be disastrous to the City's prosperity and well-being - perhaps hundreds of million pounds per annum. Fracking anywhere between Bath and the sources (which may be in the Mendips or equally distant places) could destroy the paths which direct the hot springs to Bath. Building of roads, car parks, housing on the green setting of Bath would risk damaging the entire WHS. Housing etc should

No. Name Organisation Comments Response to comment be either on brownfield sites or beyond the Bath skyline. Traffic in the centre is out of control, affecting both culture and built environment (as well as health). 4. What are the most important immediate improvements to make? Making the A350 the default route for north-south traffic (especially for HGVs). Introduce a congestion charging zone for the City centre at rush hours. 5. What are the most important improvements to make in the longer term? Prepare for the impact of driverless cars, which if unchecked could multiply the load on Bath's parking and road space. Large underground parking would be needed, but could be situated anywhere out of sight since their occupants would have alighted at more convenient places, typically in the centre.

23. Stephen B&NES Copy of the draft returned with annotated changes. Bird Heritage Services 24. Fiona Bathampton We write to you on behalf of the Bathampton Meadows Received via the World Heritage Powell Meadows Alliance (BMA), a community based organisation established email inbox. Receipt Alliance to protect Bathampton Meadows from inappropriate acknowledged via email as development, including a current plan by Bath and NE requested. Somerset Council to build park and ride for up to 1600 cars.

Bathampton Meadows are an intrinsic part of the setting of the World Heritage City, we therefore welcome the opportunity to comment on the Management Plan 2016-2022. It should be noted that residents of the villages to the east of Bath are not

No. Name Organisation Comments Response to comment represented by FOBRA (they have not supported their one member Batheaston Forward when it comes to the content of Avon Local Councils Assoc. this letter), nor are we represented on the WHS steering group. (ALCA) represents parishes on As such we have not been offered an opportunity to shape this the Steering Group plan to date.

The Management Plan has identified at 3,5 that:

‘The distinctiveness of the city to a large degree results from the harmonious relationship of the built form and the natural landscape of the city including its green spaces, the river and canal corridors and the surrounding countryside which enfolds and extends right into the heart of the city.’

Such a description is surely inspired by Bathampton Meadows, endowed as it is with so many of the attributes of Outstanding Universal Value (OUV) set out in the plan and endorsed by Bath & North East Somerset Council (cabinet 14 May 2014). The meadows lie upon ‘the incised plateau of the Avon Valley’, they provide one of the ‘green fingers that stretch right into the city’ they are surrounded by ‘green undeveloped hillsides’, are lined with ‘tree belts’ and provide ‘an agricultural landscape with grazing and land uses which reflect those carried out in the Georgian period’.

Any plan that does not fully protect this asset would therefore fail to protect the WHS. Indeed Objective 11 under Section 5.11 (Conservation) sets out to protect and ascribe equal importance to the setting:

‘Ensure that the natural setting of Bath, as a key attribute of

No. Name Organisation Comments Response to comment OUV, is afforded equal importance to the built element and is protected, conserved and interpreted’ Noted. This refers to implementation of the plan We urge you to uphold this objective in everything that you do. rather than any changes to the Once developed, the setting is tarnished forever. draft document.

This representation seeks to address matters related to Bathampton Meadows and is focused mainly, but not exclusively on section 5. We will therefore begin with our comments on this section before turning to other matters.

Section 5 Issues to be addressed

The plan has identified that Bath is about to witness another phase of redevelopment with major housing schemes, the Riverside development and other major projects including at the Rugby ground. The Transport Strategy is a Transport to serve these developments will need to be recently adopted strategy. sustainable, but we do not agree that the Transport Strategy in its current form provides a sustainable or inclusive solution. The Transport Strategy is heavily weighted towards park and ride. This is land hungry and threatens the setting of the city, in particular at Bathampton Meadows. Park and ride is used exclusively by car users and so is not an inclusive mode of transport, rather it draws passengers away from rural bus services placing these services at risk.

th The recent vote by the cabinet (29 June 2016) to accept the devolution package, along with the Buses Bill, which is due to

No. Name Organisation Comments Response to comment reach Royal Assent early 2017, present an opportunity to revise this strategy, by giving the council the ability to control buses and therefore reduce their strategy’s reliance on park and ride. We therefore believe that The City of Bath World Heritage Site Management Plan 2016-2022 should predict and This amendment is not deemed encourage such change. This would be possible if action 5 necessary to make at this time. were amended to include the words highlighted in bold. It is possible to make changes to the actions within the lifetime Action 5: Monitor and engage with the delivery of the Transport of the plan if any major changes Strategy (2014) and any subsequent revision in so far as in other key strategies occur. they relate to the WHS & seek to ensure they have no The same applies to other key unacceptable impact on the OUV of the WHS & its setting. strategies such as the Core Strategy and Placemaking Plan Aside from our general disagreement with transport policy, the BMA has grave concerns about how this has been interpreted by the draft management plan being consulted upon and therefore recommends deletion or revision of 5.6 and also the revision of Objective 3

5.6 Transport ‘…The ‘Getting Around Bath’ transport strategy was adopted on 13th November 2014 by B&NES Council and contains a range of measures including expansion of existing park and ride facilities and exploration of a potential new site to the east of the city. Whilst there is apparent demand for such measures (there are currently (2015) 2,860 park & ride car parking spaces, with demand frequently outstripping supply) and benefits could follow, implementation could also harm the OUV and an action is included to ensure that proposals take full account of the impact on the WHS.’

No. Name Organisation Comments Response to comment

Our comments:

1. The 2014 Transport Strategy does not commit to Noted. building an East Park and Ride, instead Policy GABP8 sets out that the Council should ‘Establish the need for increased Park and Ride capacity as part of a wider parking strategy’. The council has yet to do this. It has failed to carry out any rigorous research on either demand for a new east of Bath P&R, or the impact of its development on any proposed sites. The phrase ‘contains a range of measures including expansion of existing park and ride facilities’ should therefore be Noted, and due to the amended to; ‘requires the council to establish the disagreement around the need for increased park and ride facilities’ subject of need, references to this have been removed from 2. We disagree entirely that there is apparent demand for the Plan these measures…with demand frequently outstripping supply. B&NES has not demonstrated the need for increased P&R spaces. Based upon B&NES own entry and exit data, the 3 existing park and ride sites are on average 41% full. There were only 22 occasions last year when one or more of the existing park and ride car parks was full. These coincided with known events such as the Christmas Market and rugby matches that could be predicted and managed by overflow parking and additional trains and buses. This statement should therefore be deleted and any reference to the usage of Noted. See above response. park and ride should be correctly quantified rather than remain inaccurate.

No. Name Organisation Comments Response to comment 3. Demand for P&R has in fact not increased over the last 5 years. A survey in 2011 used in a background document to the Transport Strategy showed 1550 spaces used at the busiest time of day. The annual usage figures for the 12-month period to March 2016 show 1546 spaces used at the busiest time of day. This is illustrated on the graph below. Note that there are 2,777 spaces available.

4. In 2015 an additional 248 P&R spaces were provided at Newbridge, but after a full year of operation P&R usage across all 3

No. Name Organisation Comments Response to comment sites had only increased by 19 cars on average a day.

5. This evidence is derived from the council’s own strategy documents and parking data. It was presented to the council at a scrutiny hearing on the 22nd March 2016. The data has been professionally analysed by Andrew Lea, an insight professional with more than 30 years experience. It has never been disputed by the council. Please see section 5 of the BMA report to Scrutiny for a full analysis of the council’s parking data (appendix 1) 6. It should also be noted that the Council do not measure the success of their existing sites in any meaningful way that has been presented to the public. Council policy is based upon infrequent snapshot surveys of users interviewed at existing car parks several years apart. Section 5 and 6 of the BMA scrutiny report explains that the need for expansion is limited to overspill parking across the city for special events, not for more permanent parking.

7. The Council has now moved on from focusing on current demand and suggesting that an East P&R will bring any immediate benefit (as quoted in Section 5.6 Transport). Instead and in response to our work looking at their own full year data, have issued usage projections out to 2029, with no short or medium term benefit quantified. This forecast is of great concern to us as the driver-parking pattern used is unlike that of the last 5 years and includes a shuttle for the Royal United Hospital. This idea was not initiated by the RUH and they have provided no data or patient trend information to support this.

8. There has simply been no case made as to the benefits Noted. This reference has been that could follow from expanded park and ride, so this removed along with the assertion should also be removed. Indeed the original reference to demand.

No. Name Organisation Comments Response to comment stated aims of the public consultation included reducing congestion and improving air quality. Both of these have since been proven not to be true. The Council’s own consultants (Mott McDonald) have stated that there would be only 5% improvement in traffic on the London Road, and previous consultants (CH2MHill) have stated that traffic in this location in the afternoon would get worse. This model also does not take into account suppressed demand from those using back streets or other routes, which may take up this 5% reduction, if created. Please see the letter to cabinet (appendix 2) for a detailed appraisal of demand and the lack of tangible benefit.

9. Given this, it is clear that there is no demonstrated (and we say demonstrable) benefit which would justify siting a park and ride east of Bath, and very certainly not on Green Belt land at Bathampton Meadows in the setting of the World Heritage Site. If 5.6 is retained we suggest it is amended in the following way; Changes of wording have been made as outlined above, with 5.6 Transport deletion of references to 1. ‘…The ‘Getting Around Bath’ transport strategy was demand and benefits. The adopted on 13th November 2014 by B&NES Council words ‘the need for’ have also and requires the council to establish the need for been added as suggested. increased park and ride facilities. Future demand for such measures is contested and on average 59% of the available space is unfilled, sites reach capacity only during predictable events such as the Christmas Market. Implementation of this measure could harm the OUV and an action is included to ensure

No. Name Organisation Comments Response to comment that proposals take full account of the impact on the This objective focuses on the WHS.’ desire to make the centre an easier place to walk about in and facilitate further Objective 3: pedestrianisation of streets Work to control traffic growth and harm, and encourage and (where appropriate). This focus promote less car use, especially in the city centre. on the very busy city centre is deemed appropriate and should Our comments; not be construed as meaning that other areas are of lesser This objective causes serious concern since it seeks to importance. prioritise the needs of the city centre over that of the setting and can be used to justify a park and ride within the setting. Agree. We suggest that ‘especially in the city centre’ is deleted from this sentence

The site boundary is the municipal boundary of the city. No geographical area has been identified as more important than any other in the draft management plan, rather it is the attributes that are considered when planning applications are determined.

The management plan should be informed by the growing body of academic evidence that show how park and ride Noted. The Plan does not increases traffic and pollution where they are located and have however support a new park a minimal impact on traffic into town. Please refer to the study and ride, but refers to the by Zijlstra, Vanouttrive and Verhetsel 2015 as set out in section Transport Strategy which (as 4 of the BMA report to Scrutiny (appendix 1). outlined above) considers the need for such a facility. Supporting a new park and ride therefore goes against Action 26 (5.10 Environmental Resilience), which:

No. Name Organisation Comments Response to comment

‘Support(s) actions to reduce air pollution, primarily caused by petrol/diesel powered vehicles, which is a direct risk to people & historic fabric within the WHS.’

As set out previously, a park and ride will not improve congestion or air pollution in the city centre and indeed will worsen it in the setting, with consequences there for peoples’ health.

Please also note that Defra no longer recommend park and ride as a method to reduce pollution in city centres. This has been deleted from their Air Quality Policy Guidance 2016 that replaced the 2009 version.

Finally on this subject, you will see from both appendix 1 and 2 of our submission that we are calling for Bath and NE Somerset Council to conduct the research it has yet to do into why people are on the roads at certain times of day. We have conducted our own automated five-week traffic count in Batheaston using the same company that the Council employs. From this data we learned that 33% of traffic in Batheaston in the morning peak is the school run. This is vs. the 10% the council suggested were the school run at the Public Scrutiny Day in March 2016. Until the council understands the causes of its own traffic movements better (instead of the volumes that they have currently measured), they can never be sure that their solution of a park and ride will work.

Other matters This remains the challenge.

No. Name Organisation Comments Response to comment The Vision

BMA welcomes the Vision statement that;

‘The Outstanding Universal Value of the City of Bath World Heritage Site will be conserved and enhanced for this and future generations.’

But is concerned that it will prove impossible to ‘balance the needs of an inventive and entrepreneurial 21st century place with the conservation and enhancement of the unique heritage which is of world-wide significance’.

This is because BATHNES council, the principle Steward of the World Heritage Site is also the principle landowner and the decision maker for development in the city. This is a clear conflict of interest that has the potential to cause harm to the OUV of the city if measures are not put in place to prevent this.

BATHNES owns part of Bathampton Meadows and has a stated intention to develop this, or another part of the meadows currently in private ownership, for a large park and ride. Planning Policy has been weakened rather than strengthened with respect to this as plans emerge.

The management Plan identifies that Policy BH4 of the council’s core Strategy states; The Core Strategy has recently been adopted and is therefore There is a strong presumption against development that would the framework within which the result in harm to the Outstanding Universal Value of the World Plan must seek to operate. Heritage Site, its authenticity or integrity. This presumption

No. Name Organisation Comments Response to comment applies equally to development within the setting of the World Heritage Site. Where development has a demonstrable public benefit, including mitigating and adapting to climate change, this benefit will be weighed against the level of harm to the Outstanding Universal Value of the World Heritage Site.

But this is a weakening of the previous policy BH1 which stated:

Development… which would harm the setting of the World Heritage Site will not be permitted

Such change enables the council to carry out their stated aim to develop park and ride on Bathampton Meadows. We are concerned that despite the clear statement repeated within the vision that;

‘There will be a strong presumption against development that would harm the Outstanding Universal Value of the World Heritage Site itself, or its setting’

neither the management plan, nor any other means at UNESCO’s disposal are able to counter such plans. If this were to occur Bath could never be considered a ‘centre of excellence for urban heritage management and conservation…’ as set out in the Vision. The city council would instead have caused irretrievably harm to the ‘Outstanding Universal Value’ which this plan seeks to protect.

Finally, the Bathampton Alliance believes that Bath can and should be ‘accessible and enjoyable to all’ but should not be

No. Name Organisation Comments Response to comment reliant upon an out dated and inefficient measure such as park and ride, which is only available to those who have a car (this is likely to exclude the poor, elderly, sick and disabled). This is generally an operational matter rather than a matter for The Management plan should not give credence to such plan wording. The plan development but should challenge the Council to consider identifies attributes of OUV, more sustainable and equitable alternatives. which are the key focus of protection.

2.3 Boundary

The plan makes it very clear that the site boundary is the municipal boundary of the city, something that is quite exceptional in world-wide terms, since almost every other city worldwide covers only a part of the urban area and not the entire settlement.

This statement is welcomed and it is noted that no

geographical area has been identified as more important than

another. It would be useful therefore if this were explicitly

stated beyond the lack of distinction made between city and

setting made in section 5.11 and welcomed on page one of this

submission.

With regard to Bathampton Meadows, this would make it clear The assessment of individual that a policy of exporting congestion and associated pollution development proposals is from the centre to the green setting is not an acceptable undertaken through the solution. Planning system, which is the primary protection measure 2.4 Setting upon which the Plan relies. The Planning Process takes full

No. Name Organisation Comments Response to comment The BMA disagrees with the statement at 2.4 that; account of the WHS is assessment of proposals. ‘planning policy and The City of Bath WHS Setting Supplementary Planning Document provide effective protection and are therefore considered to negate the need for the designation of a formal buffer zone’

Neither of these things protect Bathampton Meadows from development as a park and ride since exceptions can be made within planning policy for this. Also because BATHNES council, the principle Steward of the World Heritage Site, is also the principle landowner and the decision maker for development in the city, including landowner on Bathampton Meadows.

If the management plan does not explicitly speak out against such development it will fail to protect the setting. This reference is considered acceptable, and is intended to

differentiate the transport Section 3 significance of the site system in Bath from (for

example) tram or metro based At page 15 the management plan refers to negotiations to systems used in other cities. transfer key areas of land to the National Trust. We are not

aware of which key areas of land are referred to but would

support a proposal for council owned land at Bathampton

Meadows to be transferred in this way.

The following statement at page 15 referring to transport

improvements should be amended. It currently states:

‘Transport improvements are based principally around a bus- based network and pedestrianisation, as outlined in the

No. Name Organisation Comments Response to comment Management Plan.’

It is misleading to state that transport improvements are based around a ‘bus-based network. The current transport strategy relies heavily on park and ride which encourages the use of the private car, rather than a true bus network which uses public transport for the entire journey.

3.3 Attributes

The BMA endorses this section, in particular section 5 The green setting of the City in a hollow in the hills which aptly describes the value of Bathampton Meadows to the site Bathampton Meadows is endowed with many of the attributes of the WHS as agreed by Cabinet in May 2014 and should therefore not be explicitly threatened within the same plan by This reference, in the Statement acceptance of a park and ride in this area. of OUV, is to previous negotiations relating to Beechen 3.5 Natural Value Cliff

The BMA endorses this section, in particular the reference to Steering Group (28 July 2016) the importance of the River Avon, its valley and associated agreed with this point and the water meadows example has been removed.

4.13 Local Planning Policy

We note the reference to citizens being able to shape policy and comment on proposals, but suggest an amendment to the example used as this is misleading in its current form and our experience is that policy is not shaped by public opinion.

No. Name Organisation Comments Response to comment ‘a 2015 consultation on a potential new (eastern) park and ride site attracted over 4000 comments’

The consultation referred to resulted in 51% being against a park and ride, this needs to be included if this example is to be used. Given that several aspects of this consultation’s administration were flawed, you may wish to select another example as best practice.

We have referred previously to policy B4 of the Core Strategy and consider this to be a weakening of policy. Similarly the draft Placemaking Plan (currently at inspection stage) seeks to allow development within the setting for park and ride, which we are contesting.

4.18 Analysis of current management

The BMA agrees with the concern expressed in this section and suggest some solutions.

‘…the WH system can struggle to keep pace with urban change. Under section 172 of the UNESCO Operating Guidelines the State Party is requested to inform UNESCO of ‘major restorations or new constructions which may affect the OUV of the property’. With the constant change experienced in a contemporary western city such as Bath it can be a difficult judgement call as to what to report to UNESCO and when’… There is also a continuing need to train, educate and influence decision makers which, as previously described, have a very short life compared to the historic buildings which they are stewards of, and each new decision maker needs to

No. Name Organisation Comments Response to comment understand the importance of the WHS’

We agree that key decision makers need on-going training with regard to the importance of the WHS, but would go further.

The BMA suggest that UNESCO should be informed of any major planning application made by the council itself where there is need to weigh public benefit against the level of harm to the Outstanding Universal Value of the World Heritage Site.

We additionally suggest, that the council itself should not make decisions on their own major applications where there is need to weigh public benefit against the level of harm to the Outstanding Universal Value of the World Heritage Site.

Such decisions can never be free from the perception of bias, if not bias itself, given the council’s extensive ownership of land, commercial interests and political interest in delivering schemes such as an east of Bath Park and Ride. The Plan does not promote or The Management Plan should specify that such applications sanction specific transport be heard by an independent body set up for such purpose or proposals. by the secretary of state. To do so would ease public concerns

and avoid Judicial Review.

A local authority can co-opt independent members onto its

planning committee and The 2012 London Olympic Games set

a precedent for special arrangements to be made for planning.

The Olympic precinct straddled 4 London boroughs meaning

that applications would have to be heard by each authority. To Noted. avoid such a cumbersome process and potential conflict the

boroughs set up the Joint Planning Authority (JPAT) and a joint

No. Name Organisation Comments Response to comment planning committee. This suggests that there is no barrier to making suitable planning arrangements where necessary.

In conclusion we urge you to look closely at the evidence that is now available and conclude that there is no case, and can be no case for allowing ‘Exceptional Harm’ to the WHS through the damage to its setting that would occur from a park and ride on Bathampton Meadows.

The World Heritage Site Management Plan should not promote or sanction this and indeed should go as far as to say that there has been no case made for a park and ride to the East of the city within the setting boundary. This is of vital importance to maintain the independence of the World Heritage Site management team, given that the very same Council’s development plans are also the key threat to the WHS setting in this case.

Members of the Bathampton Meadows Alliance would be pleased to speak to you further on this subject.

NOTE: There are two appendices accompanying this submission, which are too long to reproduce here.

25. Mark Greenway The attributes of the World Heritage Site are facets which O’Sulliva Lane Area contribute to and enhance understanding of the Outstanding n Residents' Universal Value, and have been endorsed by Bath & North Forum East Somerset Council and the City of Bath World Heritage Site Steering Group. They are set out in the draft World Heritage Site Management Plan; and they include “The Green Setting of the City in a Hollow in the Hills”, and in particular (a)

No. Name Organisation Comments Response to comment green, undeveloped hillsides within and surrounding the city, Agreed (b) trees and woodlands, and (c) fingers of green countryside which stretch right into the city.

2 The National Planning Policy Framework (2012) sets out the conservation of heritage assets as one of the twelve core principles of planning (§17) and requires that great weight should be given in planning decisions to the conservation of heritage assets (§132). Policy B4 of the Core Strategy (The World Heritage Site and its Setting) (2014) declares “There is a strong presumption against development that would result in harm to the Outstanding Universal Value of the World Heritage Site, its authenticity or integrity. This presumption applies equally to development within the setting of the World Heritage Site.” The Bath City-wide Character Appraisal SPD (2005) remarks, “6.1.2 One of the valued characteristics of Bath is the way buildings respond to the distinct topography and are designed with consideration of the surrounding landscape and adjoining spaces. Many buildings and terraces follow contours, often overlooking open ground to panoramic views across the city….The ingenuity and variety of architects’ responses to the topography contribute greatly to the unique appearance of Bath…. 6.1.3 Fingers of green, whether woodland, open farmland or grassland, extend well into the city softening and contrasting with the built form. 6.1.4 Bath’s unique topography gives opportunities to exploit a multitude of views. It is clear from these views that the city is characterised by a limited colour palette of muted tones. 6.1.5 Many parts of the city have views to wooded skyline or undeveloped slopes.”

3 The World Heritage Site Setting SPD (2013) stresses

No. Name Organisation Comments Response to comment the importance of the Statement of Outstanding Universal Value and of the Site’s attributes, and of the part the setting plays in supporting the Outstanding Universal Value and its attributes in conjunction with a strong policy to ensure the protection of the Site and its setting. It also picks up (at Appendices 3 and 4) a series of places within Bath which have offered culturally important vistas over the last 400 years, both into and away from the centre of the city. The Council has also adopted a Green Infrastructure SPD (2013), which stresses the importance of public and private playing fields and other green spaces to which the pubilc have access.

4 Against this background, one would assume that the protection of green space and of an undeveloped feel was among the most important considerations in the minds of members and officers when considering proposals for development. Yet this seems too often not to be the case. Three current examples within the World Heritage Site in the south of Bath might be mentioned:

i) Bath University, Claverton Down: The east of the University site is within the Cotswolds AONB and almost the whole of the site is surrounded by the AONB; and the area known as Bushey Norwood to the east of the site is acknowledged as being a very special place and is in the ownership of the National Trust. The draft Placemaking Plan, however, is curiously hesitant in its language about conservation in this area. One might think that an obvious measure would be restrictions on the height of additional university buildings, allied with a substantial woodland belt along the boundary of the site

No. Name Organisation Comments Response to comment to provide good year-round screening which would protect the AONB. Neither of these is mentioned; instead, the draft says merely, “the design response would need to provide a sensitive edge to the campus in respect of Bushey Norwood and [that] a “landscape-led” approach should be a crucial guiding principle”. Even in relation to the land by Bushey Norwood, “University related uses” including student residential accommodation are “acceptable in principle”, though where the developable land runs right up to the boundary it is grudgingly conceded that decisions “should be guided in part by the Cotswold AONB Management Plan, where relevant”. This is hardly the full-throated support for conservation of the World Heritage Site attributes that one might have looked for.

ii) Fox Hill, Mulberry Park: A large ex-MOD site on the summit of one of the highest hills in Bath is currently being developed for housing by Curo in partnership with commercial developers. Buildings several stories high are to be permitted in the centre of the development, and little thickening of the one-tree-wide screening belt at the northern edge is proposed. The Council has granted outline permission on the basis of limited visualisations of the views into the site, which were based on summer tree cover and omitted, for example, views from the Lyncombe Valley and from further out in the AONB in the Midford area. Opportunities here are not yet wholly lost, since details are yet to be approved, but the extent to which World Heritage Site issues were referred to in the discussions on the outline application

No. Name Organisation Comments Response to comment was disappointing.

iii) Beechen Cliff School: The Bath Boys’ School was built on the southern side of the hill in 1932, and is now Beechen Cliff Academy School. Beechen Cliff Hill is highlighted in the World Heritage Site Setting SPD as culturally, aesthetically and historically the most important of the vantage points within the Site, in relation to views in every direction; and the whole hilltop is identified as one of the Green Hillsides Forming Prominent Features of the Landscape Setting. The Bath City-wide Character Appraisal SPD remarks “The contained, yet sky-filled, formal open space of Alexandra Park, the intimate field network of the eastern slope fields and the rather more open and exposed school playing fields are three quite different areas of open space. However, they merge and blend together to form one coherent and distinctive landscape”. Originally set unobtrusively into the hillside, the school has in recent years been permitted to extend its buildings widely across its curtilage in a variety of designs; for The issue of whether a some months now it has been permitted to disfigure the summary of the Plan could be very centre of its playing fields with a heap of spoil picked up as an SPD is included removed in the course of building works (photograph in the Plan and will be attached showing the present view of these fields from investigated. Notes on the the Fosse Way entering Bath). This seems an individual cases given are unsatisfactory way to treat a hilltop recognised by the useful and will be retained for Council as one of the most important in the World reference. Heritage Site.

5 Against this background, the Greenway Lane Area

No. Name Organisation Comments Response to comment Residents’ Forum considers that the importance of heritage and conservation issues, though of course already strongly represented in the draft World Heritage Site Management Plan, could usefully be strengthened still further; and indeed that the Management Plan might itself be adopted in some form by the local planning authority as a statutory SPD. We note the important points made by FoBRA in relation to transport and other matters, and we support them. But we would ask that they should not be addressed so far as to be to the detriment of the natural, historical and cultural heritage which is the life- blood of our city – and of course the main focus of the Plan.

26. Jan Widcombe The Widcombe Association has considered this document and Shepley Association believes it represents a positive statement of objectives and actions which it wishes to support and commend to the B&NES Council to adopt as part of its suite of plans and policies which will guide decision-making on proposals for development and change over the next few years. As a member of FoBRA, the WA has supported the responses of that body to the earlier consultation document and is pleased to note that most of the comments have been accepted and changes made. As Widcombe lies at the heart of the WHS, the place where the city meets the countryside, the Widcombe Association is particularly keen to ensure the design principles and environmental objectives of the Management Plan are applied equally to the south as well as the north of the river and indeed throughout the WHS. We are currently actively engaged in seeking improvements to the environment within the neighbourhood, specifically looking at the quality of the river and canal corridors and the pedestrian linkages with the city centre as well as related issues of air quality and road Yes. Any actions, unless stated safety for all users. otherwise, apply across the site. In this context, the WA welcomes the WHSMP Objective 5 – to ensure new street works and other developments are completed to high and consistent design standards allowing good accessibility to

No. Name Organisation Comments Response to comment all - supported by Actions concerning the quality of pavement surfaces, the use of the Bath pattern book and expansion of pedestrianisation of streets where appropriate. It is important that these principles are applied throughout the WHS and not confined to the city centre. The WA also welcomes the statements on Environmental Resilience – Objective 8 – to ensure that all environmental risks to the OUV are identified, managed and mitigated, as far as possible – with Actions including no 25 – to support the establishment of an effective holistic management structure for the River Avon and Kennet and Avon Canal – and 26 – to support actions to reduce air pollution. We also support the statements on Conservation – Objective 9 – to ensure that damaged and disused structures within the Site are monitored, repaired and maintained and where appropriate reused – and 10 - to ensure that the natural setting of Bath, as a key attribute of OUV, is afforded equal importance to the built element and is protected, conserved and interpreted. However, along with FoBRA, we are concerned that the WHSSG has not been more unequivocal in its statement on what is a key element of the Bath Transport Strategy – ie an eastern P&R site. We accept the group’s autonomy and right to take a different view from the decision made by the Council, but feel that it is the duty of the SG to make clear its priorities – and that the protection of the city itself should take precedence over that of its setting, if and when there is a conflict between the two.

The fact that the Plan defers to the Transport Strategy on this matter is deliberate.

The Plan is clear (objective 11) that the Natural Setting is

No. Name Organisation Comments Response to comment afforded equal importance to the built element. 27. Ian The Abbey There is much in this document which we would support but it Perkins Residents is unclear how its conclusions and actions will be implemented. Association Priorities We would like to propose two additional priorities: 1. Pollution and air quality – current levels of pollution exceed WHO The Plan addresses this. guidelines in several areas. Pollution impacts the health, comfort of

both residents and visitors and damages the history structures which caused the city to be selected as a WHS. 2. Protecting communities - Bath is unique in the number of people who choose to live in the city centre and in the social and economic diversity of those who live there. Your own report talks about Bath This is important but tangential as a thriving 21st-century community. Venice demonstrates what to protection of the OUV. This happens if a WHS loses its community structures. does however need to be picked up across the board in Actions Council and other strategies.

Managing Development It will be very important to have proper coordination of the many major, and some of the minor, development projects to avoid disruption and damage to the WHS in the short to medium time and to minimise costs. The management mechanism for assessing this is generally Transport through the planning system, The action “Monitor & engage with the delivery of the Transport into which World Heritage Strategy (2014) objectives in so far as they relate to the WHS protection policies are included. & seek to ensure that they have no unacceptable impact on the OUV of the WHS & its setting” begs the question who will Cycling is included largely decide on acceptability and what criteria will they use. because there is significant It is not clear why cycling has been pulled out of the Transport funding forthcoming to introduce Strategies and accorded special consideration ahead of other cycle friendly measures. as

No. Name Organisation Comments Response to comment issues such as parking. The assumption seems to be that noted, these need to be cycling has an entirely positive impact on the city a contention watched/managed to ensure the that many residents would dispute. measures are beneficial and not harmful. Public Realm There are a number of issues impacting the public realm which These are generic city do not get mentioned here including street drinking, street management issues which stray living, busking, begging and litter. beyond the remit of the Plan. In addition, the quality of public realm infrastructure, particularly in the city centre, continues to fall way below the standard achieved by many peer cities which do not have the benefit of World Heritage Site status. Funding of the city’s own Public Realm and Movement Strategy, which would have remedied many of these deficiencies, has ceased after a The Stakeholder Event (April promising start and should be restored. 2015) invited representatives from 150 organisations. Other observations Attempts have therefore been The stakeholders in the WHS referenced in this report and the made to be as inclusive as list of those to be used in initiating actions seems to have been possible. selected from a rather narrow pool which may well reflect the situation at the time the last plan was prepared. There is a need to create an effective database both of the assets of the WHS in terms of historical and archaeological records and artefacts but also the key stakeholders and gatekeepers who need to be engaged if the objectives of this plan are to be realised.

28. Cllr Historic I think that it is a very well presented document and also most Peter Environment comprehensive. Turner Champion From my business background though I have picked up on Noted. A risk assessment for RISK. There is mention of risk assessment but not necessarily the site is complied, but is a of mitigation. The document including the gap analysis tool, to background working document.

No. Name Organisation Comments Response to comment be fair ,has yet to be produced. However statements like...... "the WH will struggle to keep pace with urban change " and...... " A smaller number of projects which can realistically be delivered" are worrying in the context of risk. Most importantly to conserve " the green setting of the City in a Hollow in the Hills. How do we educate those " non passionate" members of our community as to how the inscription of the WHS which spreads across the whole City and the importance to conserve our WHS for this generation and for future generations? The action plan includes web site , social media and way finding. I think that we need some measurement of effectiveness to ensure if we can ,that the message of pride, charm and sustainability is reaching our " non passionate " guys and girls especially the young. ( I note the section on Education). In a similar vein the list of objectives and actions are lengthy but concise. However it is easy to derive the benefits but again the engineering term , measurement of effectiveness, applies. How will we measure effectiveness of quite a large number of actions

29. Sophie B&NES The Council’s Corporate and Communities Sustainability Team By email. Acknowledged. Kirk Sustainabilit is keen to ensure that the WHS Management Plan and y Team associated policies support environmental sustainability and 18 Jul align with local Climate Change Policies (Core Strategy 2016 Objective 1, CP1, CP2, CP3).

The Sustainability team welcomes the inclusion of “environmental resilience” as a top 5 priority of the plan. We also welcome the following objectives and actions that support environmental sustainability including those that seek to:

No. Name Organisation Comments Response to comment

o Control traffic and promote less car use (Objective 3) o Mitigate against flood risk (Objective 8, action 23) o Guard against fracking (Objective 8, action 24) o Reduce air pollution (Objective 8, action 26) o Conserve and enhance the key setting of Bath including via farming and grazing (Objective 11, 31).

Please find additional comments on specific WHS management objectives and policies below:

WHS Management Plan objective 1: Ensure that new buildings and other developments do not harm the OUV of the site. Comment - Ensuring energy efficiency and reducing carbon emissions is an important consideration for the city. The Council seeks to encourage the sensitive retrofitting of energy efficiency measures in historic building whilst safeguarding the special characteristics of these heritage assets for the future. Ensure that any forthcoming guidance aligns with the following Core Strategy Policies:

o Policy CP1 Retrofitting Existing Buildings o Policy CP2 Sustainable Construction o Sustainable construction and Retrofitting Supplementary Planning Document . WHS Management Plan Action 28: Work toward a framework which provides clear & consistent guidance for street & other lighting across the WHS, including the issues of light pollution.

Comment: The sustainability team understands the issues

No. Name Organisation Comments Response to comment with the current roll out of the low energy lighting schemes using LEDs. Ensuring environmental sustainability and reducing carbon emissions is an important consideration for the city. Using energy efficient lighting solutions is a way of Suggestion agreed by Steering achieving this. We’d like to recommend a change to the Group and the wording has wording of Action 28 as follows: been added

Work toward a framework which provides clear & consistent guidance for street & other lighting across the WHS, including the issues of energy – efficiency and light pollution

The only thing I’d like to add is reference to Core Strategy Policy CP3- Renewable energy, and draft Policy SCR1 & 2 in the PMP which requires that major developments produce a 10% cut in the regulated emissions from their buildings by use of renewable energy (pending adoption). Policy SCR2 outlines design requirements for PV to be acceptable (inc in the WHS).

30. C What do you most value about Bath as a World Heritage Site? Walton While appreciating the whole site, I personally get most value from the setting 14 Jul 2. What do you think diminishes its value? my concern that the 2016 setting will be damaged 3. What are the key risks to the site which should be planned for? The council's own plan for a large P&R at Bathampton Meadows. The council should plan to scrap this idea once and for all 4. What are the most important immediate improvements to make?

No. Name Organisation Comments Response to comment Transfer Bathampton meadow to the National Trust support real buses, cycling and walking instead of park and ride expansion in the management plan as P&R is too land hungry, exports the problem from the centre to the setting and does not work to reduce congestion encourage longer staying visitors over day trippers as they spend more money in the local economy and have less impact on the city in terms of traffic and pollution. Educate decision makers. 5. What are the most important improvements to make in the longer term? More of the same, create a culture of more respect for our heritage assets

31. Stephen What do you most value about Bath as a World Heritage Site? Little Its architecture 2. What do you think diminishes its value? Lack of attention to 14 Jul the riverside 2016 3. What are the key risks to the site which should be planned for? Rogue developers 4. What are the most important immediate improvements to make? Tighter monitoring and enforcement of planning decisions 5. What are the most important improvements to make in the longer term? Tighter monitoring and enforcement of planning decisions 8. Any other comments The WHSM Plan states (p15) that it “aims to address the key tensions between development and conservation“, and, quoting the NPPF, (p24) that “substantial harm … should be wholly exceptional”. It goes on to say (p26) that the site is vulnerable to small scale cumulative change which can impact

No. Name Organisation Comments Response to comment on the OUV.

On p38, the Plan states that “conservation and protection of the WHS is heavily reliant on the planning system”, while action 3 on p39 aims “to ensure the significance of the WHS’s Steering Group agreed that OUV is safeguarded”. there should be reference to planning enforcement in the What is lacking is any mention of the need for rigorous plan. This was added under monitoring of permitted works to listed buildings while in section 4.13 progress, and robust enforcement of any breaches of planning or listed building permission. Without these elements, the planning system becomes merely advisory, and does nothing to deter rogue developers from building or altering however they like, with no regard to the impact on the surroundings.

Monitoring and enforcement need to be incorporated in the Plan to prevent the gradual erosion of the OUV and consequent threat to the WHS status.

32. Victoria What do you most value about Bath as a World Heritage Site? Wells Walking on flat countryside from town Kensington Meadows to Bathampton Meadows . This is accessible landscape for 14 Jul disable people Which is hard to achieve in Bath . I love my city 2016 but also love the open green spaces of the meadows being able to sit by the river next to the meadows gives me a sense of peace. 2. What do you think diminishes its value? Building park and ride - shrinking the green spaces that Bath sits in comfortable countryside . 3. What are the key risks to the site which should be planned for?

No. Name Organisation Comments Response to comment Noises pollution , pollution, not accessible if you disabled person ( need school buses ) cost on local businesses such as holiday rentals . Eyesore upsetting and distressing for local community ... Could have effect on metal and physical health in park and ride is built. Houses will be devalued etc 4. What are the most important immediate improvements to make? School buses -stop the school run traffic - more outlining buses to local villages between Bath and wilts. 5. What are the most important improvements to make in the longer term? School buses -train to Corsham 8. Any other comments Please do tackle long public transport

33. Jim What do you most value about Bath as a World Heritage Site? Mackrell The beautiful historic architecture and wonderful green hills and green belt land 14 Jul 2. What do you think diminishes its value? 2016 Looking too industrial on key entry routes, damage to natural landscapes and wildlife habitats 3. What are the key risks to the site which should be planned for? Ongoing plans at Bathampton Meadows for a Park and See response to comments 13 Ride or Ring Road & 24 in relation to a possible 4. What are the most important immediate improvements to eastern Park and Ride site. make? Considering less damaging areas for Park And Ride such as the old Charmydown Airfield (with access via the old Gloucester Road and bus lane at lambridge extended to traffic lights) 5. What are the most important improvements to make in the

No. Name Organisation Comments Response to comment longer term? Protection of green areas in Bath 7. If you are responding on behalf of an organisation please list the name of the organisation below 8. Any other comments There are numerous attempts to spoil Baths beauty with needless and badly designed structures. Consideration for who would actually USE an Eastern Park and ride when considering position and allowance for the new electrified railway and vastly under used river should be taken.

34. Tabby What do you most value about Bath as a World Heritage Site? Grist It's beautiful countryside and architecture and the amazing Parker culture. Souvenir shops point noted, 2. What do you think diminishes its value? Tacky souvenir although this is beyond the 14 Jul shops and stalls that don't have anything to do with Bath. remit of this Plan. 2016 3. What are the key risks to the site which should be planned for? New builds that eat into the countryside, park and rides where we don't need them (e.g. Bathampton meadows) and more tacky tourist/souvenir shops. Bath is a beautiful and unique city, we honestly don't need these things. 4. What are the most important immediate improvements to make? Work on improving public transport, train and bus links. Also make sure rates are cheap, so more people are tempted into using public transport. And create more cycle routes. 5. What are the most important improvements to make in the longer term? Public transport, cycle routes, making the city more See response to comments 13 environmentally friendly, whilst still encouraging sustainable & 24 in relation to a possible tourism. eastern Park and Ride site.

No. Name Organisation Comments Response to comment 8. Any other comments No park and ride on Bathampton meadows! This would fbsolutelyruin this beautiful and picturesque part of Bath.

35. Catharin What do you most value about Bath as a World Heritage Site? e Brown The mix of gorgeous Georgian architecture and open green spaces. 14 Jul And that within walking distance of the city centre there are so 2016 many open spaces 2. What do you think diminishes its value? When the city centre expands in all directions The lorries driving through the centre because there's no bypass 3. What are the key risks to the site which should be planned for? More housing especially on old MOD sites increasing traffic within the city 4. What are the most important immediate improvements to make? More school buses - most traffic problems significantly lessen in school holidays 5. What are the most important improvements to make in the longer term? Build a bypass so lorries don't come through the centre of town 36. Katrina What do you most value about Bath as a World Heritage Site? Beautiful greenery against wonderful architecture. 14 Jul 2. What do you think diminishes its value? Over development. 2016 3. What are the key risks to the site which should be planned See response to comments 13 for? Park and ride on Bathampton Meadows. & 24 in relation to a possible 4. What are the most important immediate improvements to eastern Park and Ride site. make? Conservation of our outer-city wildlife areas.

No. Name Organisation Comments Response to comment 37. David What do you most value about Bath as a World Heritage Site? Hughes The blend of beautiful architecture & counter setting 2. What do you think diminishes its value? Encroaching park & 14 Jul ride 2016 3. What are the key risks to the site which should be planned for? Losing its status because of short term planning 4. What are the most important immediate improvements to make? Traffic calming measures and removing HGV from the city streets 5. What are the most important improvements to make in the longer term? Pedestrianisation

38. Rachel What do you most value about Bath as a World Heritage Site? Priday The green spaces and unspoilt views from the vantage points around the city. The belief that these are protected spaces 14 Jul from development to preserve the beauty of the city and its 2016 surroundings for future generations 2. What do you think diminishes its value? Over development of the belt around the city leading to a city seen in isolation from its surroundings 3. What are the key risks to the site which should be planned for? Increased visitors and associated pollution 4. What are the most important immediate improvements to make? Improved bus services into the city from outlying villages and towns 5. What are the most important improvements to make in the longer term? A practical, viable, forward looking transport plan to enable easier access into the city. One which will not seek to damage the green spaces surrounding the city , spaces which play

No. Name Organisation Comments Response to comment such a crucial role in the health and well being of all Bath residents and visitors

39. David What do you most value about Bath as a World Heritage Site? Wilton It's incredibly important 2. What do you think diminishes its value? 14 Jul The threat to green space, and in particular the proposed car See response to comments 13 2016 park on Bathampton Meadows. & 24 in relation to a possible 3. What are the key risks to the site which should be planned eastern Park and Ride site. for? Traffic pollution 4. What are the most important immediate improvements to make? pedestrianisation of more of the city centre, greater encouragement for residents to use public transport, walking or cycling, affordable public transport, air quality improvement. 5. What are the most important improvements to make in the longer term? all of the above

40. Stuart What do you most value about Bath as a World Heritage Site? Feasey The beautiful architecture surrounded be even more beautiful countryside. 14 Jul 2. What do you think diminishes its value? Ugly and 2016 unnecessary development, especially of green belt land. 3. What are the key risks to the site which should be planned for? More thought should be put into the long term planning of baths traffic problem. See response to comments 13 4. What are the most important immediate improvements to & 24 in relation to a possible make? eastern Park and Ride site. Scrap the proposed park and ride on Bathampton meadows and insure they are protected from any future development.

No. Name Organisation Comments Response to comment 5. What are the most important improvements to make in the longer term? Improvements in public transport and the provision for safer cycling in and around the city would help in reducing the amount of traffic in Bath. 8. Any other comments Bath isn't just about the city centre and its buildings, the outskirts of the city and the green spaces we have are just as important. We must protect our green spaces as much as we should protect our historic buildings, they offer a haven away from the city centre for residents and visitors alike, we must not allow the irreversible vandalism of our meadows at Bathampton for the sake of a park and ride which would damage the entrance to our World Heritage City

41. Catherin What do you most value about Bath as a World Heritage Site? e Giles The surrounding natural beauty and historical architecture. 2. What do you think diminishes its value? Roads traffic car 14 Jul parks big business 2016 3. What are the key risks to the site which should be planned for? Concrete roads and traffic 4. What are the most important immediate improvements to make? Reduce traffic noise and pollution 5. What are the most important improvements to make in the longer term? Preserving wildlife, the canal and reducing noise and pollution 8. Any other comments The people of Bath enjoy an environment friendly lifestyle. We walk and cycle and appreciate the natural beauty of the area. Please don't allow our city to become a concrete jungle.

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No. Name Organisation Comments Response to comment 42. Steve What do you most value about Bath as a World Heritage Site? Bathampton Meadows the gateway from the east 14 Jul 2. What do you think diminishes its value? 2016 1990's thinking for parking and traffic management and a glad handing, grand standing MP with no understanding of local people , farming business, water level management 3. What are the key risks to the site which should be planned for? Shorted sighted planning and a MP who has parachuted in and a man who calls genuine local concern a noisy minority 4. What are the most important immediate improvements to make? A better and more inclusive transport plan that uses real bus services rather than park and ride and encourages walking, cycling, and investment in a school bus network. 5. What are the most important improvements to make in the longer term? Better rail links

43. Polly What do you most value about Bath as a World Heritage Site? Green space alongside beautiful architecture 14 Jul 2. What do you think diminishes its value? Inappropriate use of 2016 the area 3. What are the key risks to the site which should be planned for? See response to comments 13 Concern about things like the proposed park and ride on the & 24 in relation to a possible meadows at bathampton eastern Park and Ride site. 4. What are the most important immediate improvements to make? Secure the immediate safety of the area 5. What are the most important improvements to make in the longer term? Provide a future for the area which is appropriate and sustainable

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No. Name Organisation Comments Response to comment

44. Susan What do you most value about Bath as a World Heritage Site? Cook It's outstanding culture and beautiful surrounding countryside 2. What do you think diminishes its value? To much 14 Jul concrete,Tarmac areas at the expense of my loved and used 2016 meadows 3. What are the key risks to the site which should be planned for? Tarmac flooding loss of beautiful green space 4. What are the most important immediate improvements to make? Traffic congestion there are alternatives to look at should not be down to the cheapest option should listen to the people and protect our green areas for us our children grandchildren wildlife the list goes on and on. 5. What are the most important improvements to make in the longer term? Traffic congestion but not at the sacrifice of our green areas which are as important as Baths heritage city 6. Your name 8. Any other comments I'm sure there are alternatives or the Beckford spur which was discussed 30+ years ago not destroying beautiful meadows

45. Rose What do you most value about Bath as a World Heritage Site? Nunn The history, architecture and stunning natural setting 2. What do you think diminishes its value? 14 Jul 3. What are the key risks to the site which should be planned 2016 for? Planned developments in Bathampton Meadows See response to comments 13 4. What are the most important immediate improvements to & 24 in relation to a possible make? Enhance access to the beautiful countryside around eastern Park and Ride site. Bath for walkers and cyclists

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No. Name Organisation Comments Response to comment 5. What are the most important improvements to make in the The Plan covers the entire city. longer term? Valuing and appreciating the whole area rather than just the city centre

46. Bethany What do you most value about Bath as a World Heritage Site? Hobbs Im not sure i do anymore 2. What do you think diminishes its value? 14 Jul Not listening to its residents. I believe that if it builds the new Important to note that the 2016 park and ride on bathampton meadows it should be stripped of inscription is not bestowed its 'award' upon, or in the ownership of, the 3. What are the key risks to the site which should be planned Council. for? Need affordable housing 4. What are the most important immediate improvements to make? The mass amount of student housing being built 5. What are the most important improvements to make in the longer term? To help traffic maybe build a link road for the a46 to a36. Something needs to be done. Need social housing ONLY to be built

47. Suzi What do you most value about Bath as a World Heritage Site? Shingler Unlike any other place in Britain, and the mix of city and countryside so close. 14 Jul 2. What do you think diminishes its value? The mix of shops is not directly 2016 Increasing number of typical high street shops to detriment of associated with the OUV of the smaller local businesses.m site is beyond the remit of this 3. What are the key risks to the site which should be planned plan. for? Protect surrounding countryside from disastrous park and ride 4. What are the most important immediate improvements to make? Cheaper rents and business initiatives for new, small Steering Group considered the

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No. Name Organisation Comments Response to comment and local businesses. transport action (5) and with 5. What are the most important improvements to make in the minor alteration considered it longer term? Protect what is unique about Bath adequately addressed transport 8. Any other comments Don't let the Bathampton park and ride objectives. go ahead. Please!

48. Steve What do you most value about Bath as a World Heritage Site? Henson Bath and its surroundings are a living history of human activity, both ancient and more recent. This unique environment and 14 Jul setting needs to be protected. 2016 2. What do you think diminishes its value? Irrelevant and damaging developments. 3. What are the key risks to the site which should be planned for? Transport management, specifically reducing the through traffic that is forced to enter Bath because of poor alternative routes. The propose east of Bath P&R will not help solve this problem Steering Group considered the and would destroy an essential part of the Bath environs. transport action (5) and with 4. What are the most important immediate improvements to minor alteration considered it make? Halt all considerations for the new P&R. adequately addressed transport 5. What are the most important improvements to make in the objectives. longer term? Develop alternative routes for traffic that Bath is not their destination. 8. Any other comments I am a Bath resident.

49. Richard What do you most value about Bath as a World Heritage Site? Gordon- The architecture and the green setting. Together they make Brown the city unique. 2. What do you think diminishes its value? 14 Jul Developments that are not inkeeping with the historic 2016 architecture and surrounding countryside.

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No. Name Organisation Comments Response to comment 3. What are the key risks to the site which should be planned for? Urban sprawl. The proposal for a park and ride car park at See response to comments 13 Bathampton Meadows. & 24 in relation to a possible 4. What are the most important immediate improvements to eastern Park and Ride site. make? Enabling through traffic to bypass the city centre. 5. What are the most important improvements to make in the longer term? Continued preservation of the architecture and green setting.

50. Vimal What do you most value about Bath as a World Heritage Site? Dhokia Bath isn't merely about Georgian buildings, and the Royal Crescent. it's about history, culture and beautiful green 14 Jul surroundings. In fact, I believe the green belt land around all 2016 corners of Bath add to its world heritage status and should not be underestimated. These green belt lands 'frame' the city and add to its beauty. 2. What do you think diminishes its value? - Large trucks that are continuously ponding up and down London Road and Bathwick Street. - Particularly older diesel trucks which elevate already high pollution levels.

- I have lived in Bath for over ten years and what surprises me is the reduction in bespoke shops on the high streets. We are getting more of the same mainstream stores which diminishes Bath. I think there needs to be more encouragement for small businesses to open up with significantly reduced rents. This will add long term value.

- Student accommodation. There is too much student accommodation taking over the city centre areas. 3. What are the key risks to the site which should be planned

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No. Name Organisation Comments Response to comment for? Ever increasing numbers of tourists, population growth and the need for more affordable housing. The Riverside development is all well and good, but very few people can afford to pay in excess of £500k for a 2 bedroom flat!

Logical park and ride/ rail solutions which do not involve dumping car parks in the middle of ancient meadows. 4. What are the most important immediate improvements to make? Sort out school transportation. This will dramatically ease congestion on the roads in to Bath. It is quite astonishing how traffic dramatically reduces during school holidays. This clearly demonstrates the fundamental need for better school transportation. I live on London Road west and most morning it See response to comments 13 takes me 25 minutes to get to work. During school holidays this & 24 in relation to a possible is reduced to 8 minutes! eastern Park and Ride site.

Create a more logical park and rail solution, and not the ill- conceived park and ride on the Bathamton meadows. Not only will this damage beautiful green belt land, it will also damage Bath and its surroundings. 5. What are the most important improvements to make in the longer term? I personally believe that there should be some form of congestion charge in Bath. This is the only way to stop people using their cars in the centre. However, this can only happen if other transportation methods are improved and appropriate park and ride / rail solutions are invested in. The park and ride at Charmy Down seems to be the most logical solution for a park and ride facility. But, it is not clear why this solution was

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No. Name Organisation Comments Response to comment never chosen. Bath is undoubtably unique amongst UK cities. In order to maintain this, future planning should be carefully thought through. Dumping car parks in ancient meadows is not the long term solution. Evidence to date shows that this solution will not alleviate any congestion on the main roads into Bath and is unlikely to ever be in full use.

51. Jim What do you most value about Bath as a World Heritage Site? Webb Green and pleasant historical surroundings, wonderful views, wonderful walks. 14 Jul 2. What do you think diminishes its value? 2016 A giant 1,400 space car park visible from every hill around and solving none of the traffic problems the city faces. 3. What are the key risks to the site which should be planned for? Destroying a wonderful natural area with a giant car park, visual pollution, increased air pollution, increased noise. 4. What are the most important immediate improvements to See response to comments 13 make? & 24 in relation to a possible Immediately shelve any Park and Ride plans and focus on eastern Park and Ride site. improving public transport, particularly bus and rail connections to towns within commuter range of Bath. Subsidise this with a congestion charge or higher car parking rates into the city centre to cut the number of cars coming in. Improved cycle routes within the city and around. 5. What are the most important improvements to make in the longer term? Ditto above. 8. Any other comments Scrap the Park and Ride plans for Bathampton Meadows immediately. This is by far the biggest threat to the World

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No. Name Organisation Comments Response to comment Heritage Site.

52. Nathan What do you most value about Bath as a World Heritage Site? Baker The ancient buildings and it surrounding untouched countryside 14 Jul 2. What do you think diminishes its value? 2016 Modern development that isn't fitting with the existing architecture and development in the surrounding countryside 3. What are the key risks to the site which should be planned for? See response to comments 13 building and development which is not in touch with Bath's & 24 in relation to a possible theme. The possiblity of park and rides put into the surrounding eastern Park and Ride site. countryside will ruin the landscape 4. What are the most important immediate improvements to make? Stop park and ride in Kensington meadows. 5. What are the most important improvements to make in the longer term? Refuse any building plans like the bus station built a few years ago

53. Jackie What do you most value about Bath as a World Heritage Site? Isard The history, wildlife and protection of wild species and plants are crucial. Meadowland is absolutely vital as years of 14 Jul pesticides and building have destroyed natural wildlife areas 2016 and are now resulting in the decline of one of our most important insects,the Bee! 2. What do you think diminishes its value? Nothing! 3. What are the key risks to the site which should be planned for? Protection of Meadows, wild areas, wildlife, rare species, b-lines 4. What are the most important immediate improvements to make?

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No. Name Organisation Comments Response to comment Not allowing green space to be destroyed or reducing the little protected land we have left to ensure species like bees are not at risk 5. What are the most important improvements to make in the longer term? Protection of all wild areas and wildlife

54. Lee What do you most value about Bath as a World Heritage Site? Wiltshire Our country side. skyline. and our old buildings and history 2. What do you think diminishes its value? 14 Jul knocking down of old buildings.council threatening open free 2016 meadow areas with concrete. turning our city into student accommodation. not listening to us the people of Bath. 3. What are the key risks to the site which should be planned for? taking safe winter grazing ground away from our local farmer.ruining our ancient meadows forever.it was bad enough the bypass cut through it.but it's slowly blending from view.park and ride won't ever blend in. 4. What are the most important immediate improvements to make? flow of through traffic through Bath City. underground or covered link from A36 - A4 ,divert traffic for park and ride. Please consider charm down airfield for the only other p&r east,not in well seen meadows.bring back small train stations Bathford Bathampton corsham 5. What are the most important improvements to make in the longer term? New sympathetic understanding councillors

55. Piu What do you most value about Bath as a World Heritage Site? Bose The beauty of our buildings combined with our open spaces. The whole feel is of the city is open and vibrant and yet it has

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No. Name Organisation Comments Response to comment 14 Jul an element of serenity provided by the surrounding 2016 countryside. 2. What do you think diminishes its value? Not valuing the importance of the natural beauty that surrounds the city. The parks, green spaces and meadows that surround the city are as important as the historic buildings. 3. What are the key risks to the site which should be planned for? Irreversible damage to areas of outstanding beauty that will affect not only the whole feel of the city but also diminish the air quality. The city sits at the bottom of 7 hills so we need our green spaces to counteract environmental pollution that builds up in the basin. Park & Rides on the eastern side of the city will not make any difference to the amount of traffic entering that side at the busiest times of the day or prevent heavy goods See response to comments 13 vehicles from entering the city. & 24 in relation to a possible 4. What are the most important immediate improvements to eastern Park and Ride site. make? Protection of our green spaces and more forward thinking planning. Better and cheaper bus services would remove the need for more carparks and be much more environmental especially if we follow Bristol's electric or 'human waste' powered buses!!! 5. What are the most important improvements to make in the longer term? The area surrounding Bath is as important as the city itself so any improvements need to be sustainable and environmentally sound.

56. Helena What do you most value about Bath as a World Heritage Site? Howcroft The fact it is unlike any other city green and relaxed.

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No. Name Organisation Comments Response to comment 2. What do you think diminishes its value? Badly considered, 14 Jul quickly built additions 2016 3. What are the key risks to the site which should be planned for? See response to comments 13 The park and ride on the Bathampton meadows will destroy & 24 in relation to a possible the surrounding villages on the out skirts of bath. The green eastern Park and Ride site. area separated the villages and adds to the overall beautify of the city. It's views for lots of key viewing platforms and would be a real Shame to loose this beautiful space as you can not claim it back once it's gone it's lost forever. There has to be a more suitable site rather than the historical water meadows for a park and ride. 4. What are the most important immediate improvements to make? Find a more suitable site for park and ride and look into creating a by pass road so the London road has less HGV using it. 5. What are the most important improvements to make in the longer term? Keep the green sites and use the brown field sites ... A bypass road and long term rain and ride systems. 8. Any other comments Please stop the park and ride. Save Bathampton meadows.

57. Louise What do you most value about Bath as a World Heritage Site? Hidalgo The beauty of the city itself and of its green setting, which surrounds it. 14 Jul 2. What do you think diminishes its value? 2016 Any development on the green setting of Bath should not be allowed; it is a vital part of Bath's beauty. In particular, B&NES' See response to comments 13 proposal to build a 1,400 Park & Ride on the Bathampton & 24 in relation to a possible

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No. Name Organisation Comments Response to comment Meadows, which provide a beautiful green corridor into the city eastern Park and Ride site. and can be viewed from vantage points all around, must be put a stop to immediately. It would desecrate the setting of Bath, and is a foolhardy and irresponsible plan which for no gain would destroy forever one of the city's most valuable assets. 3. What are the key risks to the site which should be planned for? The council's own proposal to build big a Park & Ride on Bath's green setting (as outlined above). Traffic into the city is a problem, but this will not help it. The council must be prevented from pursuing this path, and instead be persuaded to come up with traffic control measures that 4. What are the most important immediate improvements to make? Traffic into the city is a problem, but an outdated and environmentally unfriendly solution of building a giant park and ride on green belt land this will not help it. The council must be Cycling improvements are prevented from pursuing this path, and instead be persuaded supported by the Plan. to come up with traffic control measures that work and help get people out of their cars, such as a proper cycle paths and better public transport. 5. What are the most important improvements to make in the longer term? See above - a proper transport policy that works and is appropriate to the 21st century and does not encourage people's reliance on their cars

58. Anonym What do you most value about Bath as a World Heritage Site? ous The green spaces and the surounding countryside 2. What do you think diminishes its value? 14 Jul A view of a car park from Solsbury Hill the countryside you're See response to comments 13

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No. Name Organisation Comments Response to comment 2016 planning to build on is fantastic. Why would you deficate on it? & 24 in relation to a possible 3. What are the key risks to the site which should be planned eastern Park and Ride site. for? Polition crap developments

59. Helen What do you most value about Bath as a World Heritage Site? Sheppar THe green space within and around the city, plus the historic d georgian buildings in the city centre. Both interact perfectly to lead to a site which needs protecting for generations. Without 14 Jul the green spaces the georgian heritage would be lost within an 2016 urban conurbation. 2. What do you think diminishes its value? Development of the green belt. Bath must not begin to merge into other towns and cities surrounding it. It's georgian heritage would then be lost amongst other buildings rather than being framed by ancient and beautiful countryside. 3. What are the key risks to the site which should be planned for? See response to comments 13 The park and ride scheme planned to the East of Bath on & 24 in relation to a possible Bathampton Meadows is a short sited plan which will have eastern Park and Ride site. minimal impact on the traffic problem, and waste millions of pounds better invested in affordable public transport and school transport schemes. It will ruin forever the approach to Bath from the north East and East on the A4 and A46, and also by train on the mainline from London. Many of these routes are taken by the hundreds of thousands of tourists who visit and who bring much income to the city which relies on tourism. The damage to the ecosystem in the meadows will be irreparable, plus the flood risk created will put up insurance premiums as well as potentially causing masses of damage to property when the inevitable flooding ensues. 4. What are the most important immediate improvements to Cycling improvements are

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No. Name Organisation Comments Response to comment make? supported by the Plan. School buses, even for primary children who cannot walk as far. Breakfast club provisions with school bus to school after breakfast. Safe cycle routes and bike parking. Affordable public transport 5. What are the most important improvements to make in the longer term? Congestion charging to reduce/help pay for traffic problem

60. Kate What do you most value about Bath as a World Heritage Site? Shimazu The green setting /Bathampton meadows. 2. What do you think diminishes its value? Inappropriate 14 Jul development in the setting. 2016 3. What are the key risks to the site which should be planned for? Councils own plans for park and ride which would destroy a unique and historical setting. 4. What are the most important immediate improvements to make? A better more inclusive transport plan that uses real buses rather than park and ride, and encourages walking and cycling and most importantly invests in a proper school bus system . 5. What are the most important improvements to make in the longer term? More of the above.

61. Krystyna What do you most value about Bath as a World Heritage Site? Howcroft It has not been over modernized to make room for wider roads high rise buildings the pretservstion if the old buildings the 14 Jul unique stone also the unspoilt green environment in and

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No. Name Organisation Comments Response to comment 2016 around the city. 2. What do you think diminishes its value? Building on green spaces. 3. What are the key risks to the site which should be planned for? Flooding destruction of the continuos river environment for flora and fauna. More cars in the area there will still be the problem of more movement into the city and bottle necks not only in the parking are but also in the surrounding area an improved rail service with parking would be less destructive extra stopping place. 4. What are the most important immediate improvements to make? Consider rail or river ferry. 5. What are the most important improvements to make in the longer term? Not to over load the city restrict some developments in the centre and maintaine and improve what is in the centre and directly surrounding the centre to keep the originality of the city.

62. Andrew What do you most value about Bath as a World Heritage Site? It is assumed that this is a Howcroft The view is amazing and unique reference to a potential Park 2. What do you think diminishes its value? A car park that and Ride facility. 14 Jul would not be used 2016 3. What are the key risks to the site which should be planned See response to comments 13 for? A car park that would not be able sed & 24 in relation to a possible 4. What are the most important immediate improvements to eastern Park and Ride site. make? To be left for future generations 5. What are the most important improvements to make in the longer term? It's perfect how it is 8. Any other comments Please leave for future generations

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No. Name Organisation Comments Response to comment

63. Ana What do you most value about Bath as a World Heritage Site? It is assumed that this is a Howcroft Its Green And beautiful reference to a potential Park 2. What do you think diminishes its value? A car park and Ride facility. 14 Jul 3. What are the key risks to the site which should be planned 2016 for? A car Park 4. What are the most important immediate improvements to make? Perfect how it is 5. What are the most important improvements to make in the longer term? Jeep it like it is

64. Sian What do you most value about Bath as a World Heritage Site? James a beautiful unique compact city that has countryside just 10 minutes from the city centre - making it doubly unique. 14 Jul 2. What do you think diminishes its value? 2016 the congestion and pollution which the local council does not appear to care about - it cares more about visiting shoppers and students than it does about its residents. the focus on driving retail revenue over everything else. 3. What are the key risks to the site which should be planned for? the plans to develop the city centre for even more retail outlets, driving more cars and congestion - but they think this will be ok as they will built car parks on the greenbelt just outside the city centre. soon there will not be countryside 10mins away but just car parks. the council focuses on P&R which will damage local bus services and force more people into cars. 4. What are the most important immediate improvements to make? protect the greenbelt that surrounds the city centre - it's just as

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No. Name Organisation Comments Response to comment important as the centre as it is its setting. get the council to reassess its values - reduction of pollution should be more important than more retail 5. What are the most important improvements to make in the longer term? the council has conflicts of interests in protecting the WH City and generating revenue and is also a major landowner. more oversight of planning of inappropriate developments is required. council should focus on a strategy for sustainable transport into and around the city - stop promoting bath as a 'car friendly city'.

65. Bronwen What do you most value about Bath as a World Heritage Site? Walton The beautiful architecture, gorgeous views out to the country side from the city centre and wide range of entertainment and 14 Jul culture. 2016 2. What do you think diminishes its value? Pollution in the city centre and antisocial drinking in the evenings at the weekend. 3. What are the key risks to the site which should be planned for? Becoming too bland and multinational and loosing it's quirky individuality. Being overtaken by the needs of tourists over local needs. 4. What are the most important immediate improvements to make? Improvements in public transport more busses providing links to the city (as opposed to a park and ride scheme which still encourages car use) 5. What are the most important improvements to make in the

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No. Name Organisation Comments Response to comment longer term? Developing brownfield sites encouraging investment in jobs, green initiatives to help reduce emissions 66. Judith What do you most value about Bath as a World Heritage Site? Jeffrey Bath is unique; nowhere else has such a diverse mix of different micro-environments; history and contemporary in 14 Jul harmony 2016 2. What do you think diminishes its value? Unnecessary development 3. What are the key risks to the site which should be planned for? Destruction of open green space, and onsequent damage to flora and fauna See response to comments 13 4. What are the most important immediate improvements to & 24 in relation to a possible make? DO NOT BUILD THE PARK AND RIDE HERE eastern Park and Ride site. 5. What are the most important improvements to make in the longer term? As above 67. Judy What do you most value about Bath as a World Heritage Site? Klinpikul The beautiful architecture & the green approach from the east n (Bathampton meadows) 2. What do you think diminishes its value? Unsuitable 14 Jul development on this green setting 2016 3. What are the key risks to the site which should be planned for? The setting would be damaged by the council's plans for a Park & Ride 4. What are the most important immediate improvements to make? A good transport plan that uses the good bus services now available, cycle routes & a better school bus system. 5. What are the most important improvements to make in the See response to comments 13 longer term? See point 4 above & 24 in relation to a possible 7. Any other comments Please encourage the council not to eastern Park and Ride site.

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No. Name Organisation Comments Response to comment spoil Bathampton Mmeadows if you can 68. Charlott What do you most value about Bath as a World Heritage Site? e Its wonderful balance of stunning architecture and beautiful Redden landscape. 2. What do you think diminishes its value? Overbuilding in 14 Jul certain areas. Litter. Pollution. 2016 3. What are the key risks to the site which should be planned for? See response to comments 13 Suggestion to build on Bathampton meadows- proposed P and & 24 in relation to a possible R will not solve traffic issues and will permanently damage a eastern Park and Ride site. site of real beauty. 4. What are the most important immediate improvements to make? Protection of sites such as Bathampton meadows. Litter task force or strategies. 5. What are the most important improvements to make in the longer term? Cycling infrastructure and congestion zone for the centre.

69. Lisa What do you most value about Bath as a World Heritage Site? Brown I value the fact that this particular World Heritage city is valued for its stunning green setting as much as for its architectural 14 Jul and cultural heritage. 2016 2. What do you think diminishes its value? Constant attempts to build inappropriately on the green setting and to favour the car above other modes of transport. 3. What are the key risks to the site which should be planned for? Council's determination to destroy the green setting by building a park and ride on Bathampton Meadows. 4. What are the most important immediate improvements to make?

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No. Name Organisation Comments Response to comment Determine and deliver a joined-up transport system that will favour a (non Park and Ride) bus system at a reasonable cost, free or subsidised school buses to confront the congestion caused by the school run, encourage walking and cycling. 5. What are the most important improvements to make in the longer term? As it is clear that the school run is responsible for a great deal of traffic congestion, implement subsidised/free school transport and build more and better cycle lanes. 8. Any other comments The Council has a duty to respect the majority wish of the people of Bath and area to drop the ill-advised plan for a Park and Ride on Bathampton Meadows. It is an expensive and economically wasteful scheme, driven by simple-minded ideology, and it has been demonstrated over and over (by the Council's own consultants and others) that it will not solve any problems. 70. Austen What do you most value about Bath as a World Heritage Site? O'Hanlo Outstanding rural beauty n 2. What do you think diminishes its value? Ugly park and ride developments 14 Jul 3. What are the key risks to the site which should be planned 2016 for? Pollution increase and destruction of ancient lands 4. What are the most important immediate improvements to make? Maintain our landscape 5. What are the most important improvements to make in the longer term? Do not build on the green belt 8. Any other comments Please do not destroy our meadows!!! 71. Penny What do you most value about Bath as a World Heritage Site? Green trees and green spaces all around which enhance the 15 Jul beautiful Georgian buildings.

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No. Name Organisation Comments Response to comment 2016 2. What do you think diminishes its value? Modern buildings and more tarmac roads. 3. What are the key risks to the site which should be planned for? Flooding because of too much tarmac. Action 23 in the plan is included 4. What are the most important immediate improvements to to address flooding. make? Better public transport 5. What are the most important improvements to make in the longer term? Better and more regular train services to and from smaller stations 8. Any other comments Ruining more green meadows with car parks and tarmac would spoil the environs of a beautiful city 72. Edna What do you most value about Bath as a World Heritage Site? Williams The valley setting around mellow stone, historical buildings 2. What do you think diminishes its value? 15 Jul Dirty pavements and pollution. Parking areas within the valley. 2016 Large transit vehicles through Bath. 3. What are the key risks to the site which should be planned for? Higher pollution from vehicle exhaust. Destruction of natural beautiful land and wildlife. Destruction of small local businesses in proximity. Great disappointment and disillusionment of locals and many overseas visitors to the area. This will be "the straw on the back of the camel" with regard to trust in local government. 4. What are the most important immediate improvements to make? Extension of motorway to bypass Bath and London Road. More school bus facilities. Traffic is much reduced in during school holidays. 5. What are the most important improvements to make in the

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No. Name Organisation Comments Response to comment longer term? Traffic tunnel under Bath. Ex Brisbane, Australia and improvement of local train services. 7. If you are responding on behalf of an organisation please list See response to comments 13 the name of the organisation below & 24 in relation to a possible 8. Any other comments eastern Park and Ride site. I live on the London Road, overlooking the Bathampton Meadows and the Toll Bridge. I am able to see both traffic on the lane and London Road as well as the use of the meadows. Building on the meadows will be devastating for many. and create a sense of being "disregarded" by those we have elected to lead us. 73. Dr Chris What do you most value about Bath as a World Heritage Site? Archer- Keeping the built up areas in the city and protecting the Brown countryside around it. That way we allow visitors and locals the opportunity to enjoy the best of both worlds. 15 Jul 2. What do you think diminishes its value? 2016 Uncoordinated development plans that are the result of political dogma rather than considering the people who live here. Lack of real consideration of local ecology rather than putting a sustainability gloss on decisions that encourage car use. 3. What are the key risks to the site which should be planned for? The current administration (both national and local representation). 4. What are the most important immediate improvements to make? Proper inclusion of green initiatives at the heart of capacity planning. Affordable, sustainable public transport. I also hate the habit of the (non-local) Bath MP pitting the residents of Bath (his constituents) against their neighbours only 2 miles away (not his constituents). My example of this is the

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No. Name Organisation Comments Response to comment polarisation of the debate over Batheaston Meadows. 5. What are the most important improvements to make in the longer term? Making the city smarter, greener and taking into consideration the needs of local people.

74. Joanna What do you most value about Bath as a World Heritage Site? Kay The knowledge that I am walking through history and the links with the past. The world class historical sites located in such a 15 Jul small area. 2016 2. What do you think diminishes its value? The convoluted bus gates and number of coaches in the centre of town. I also preferred shopping in Bath when it was full of small boutiques rather than chains but business tax is prohibitive. 3. What are the key risks to the site which should be planned for? Traffic volumes which cause npise pollution and vibrations thats affect keywords architecture - not from cars but from The Plan looks to the Transport lorries, buses and service vehicles that have to get routed Strategy to explore solutions for through town in order to get to Bristol or Trowbridge etc Or to these points. cross town. 4. What are the most important immediate improvements to make? Finding a way to reroute traffic around Bath so that traffic doesn't need to come through. Link roads further out of Bath beyond the greenbelt areas and local villages. Within Bath improve existing car park offerings - can addirionL le els be added. Not park and rides that don't get used.

Greater support for smaller business that can build a unique

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No. Name Organisation Comments Response to comment character for the town centre in terms of retail. 5. What are the most important improvements to make in the longer term? Link roads to provide a detour for vehicles that don't need to go into bath.

75. Justine What do you most value about Bath as a World Heritage Site? Williams Beautiful green open spaces, unique setting provided by surroundings hills and meadows, accessible canal and river, 15 Jul Georgian architecture and modern architecture which is 2016 (largely) complimentary, landmark sites such as Roman Baths. 2. What do you think diminishes its value? The management plan states that one reason for its WHS inscription was (and is) its green setting within the surrounding hills and that there is a presumption against development which would compromise that. However this is under imminent threat by proposals for a park & ride to the east of the City on See response to comments 13 greenbelt land at Bathampton Meadows. The cogent & 24 in relation to a possible objections to these proposals have been presented to BANES eastern Park and Ride site. and local MPs many times. The proposals have no economic or environmental or indeed any other evidence-based justification and if implemented, would be irreversible and severely compromise the WHS status. The longer term proposed link road would undermine it yet further. 3. What are the key risks to the site which should be planned for? Housing needs should be addressed with development on brownfield sites only to conserve the unique setting on the City. Development should be sustainable and in keeping with the City's unique architecture. Transport plans should encourage more safe cycling and walking, but as in 2 above, transport

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No. Name Organisation Comments Response to comment plans should not include a park & ride to the east of the City and certainly not on Bathampton Meadows. 4. What are the most important immediate improvements to make? There are a notable number of empty retail units in the City. More independent businesses should be encouraged with lower rents and improved incentives. Funding which has been set aside for a park & ride to the east of the City should be reallocated to those services which urgently need funding, such as homelessness / drug and alcohol dependency. 5. What are the most important improvements to make in the longer term? All improvements and planning should have conservation and sustainability at their core. This includes housing, transport, business development etc. Given the economic uncertainty following Brexit, BANES needs to preserve the City's WHS status and also use its limited resources on the most vulnerable in our society. It should not discard our wonderful natural heritage or disregard local opposition by wasting huge amounts of public money on a park & ride on Bathampton Meadows or anywhere to the east.

76. Sandra What do you most value about Bath as a World Heritage Site? Dare It's beauty and the way it's been preserved 2. What do you think diminishes its value? too much 15 Jul development, too many tourists, spoiling its ruralness 2016 3. What are the key risks to the site which should be planned for? risks to the site are damaging the environment on the outskirts of Bath and the famous landmarks like Solsbury Hill 4. What are the most important immediate improvements to

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No. Name Organisation Comments Response to comment make? Immediate improvements, affordable housing to buy or rent, better management of roadworks, better and more frequent SMALLER local buses, cheaper fares, buses running on time. Improvements to cycle tracks, pathways and footpaths, cheaper access to local amenities, like the Bath thermal spa (too expensive for most local people I know - this is very unfair as it was us that paid for it so discounts should be much greater - much discussion with friends say they would use it if they could but it's too expensive) 5. What are the most important improvements to make in the longer term? Longer term Improvements - improved Riverside area, more affordable housing, less expensive buy to let type property being built, money for schools and colleges, also hospitals 7. If you are responding on behalf of an organisation please list See response to comments 13 the name of the organisation below & 24 in relation to a possible 8. Any other comments eastern Park and Ride site. Extremely concerned about the proposal for a park and ride on Bathampton Meadows. If you lived here, you would see that it will have a huge impact on local residents, and on heavier traffic on the already overloaded London Road. My view will be ruined, view from Solsbury Hill will be ruined. It's impossible to see how it could work, there's nowhere for the buses to go when queuing for the London road, nowhere for a bus lane on the roundabout, nowhere to claw back the extra road needed. How could this possibly work other than to create more traffic going to park and ride and leaving park and ride. Please, before making this decision, drive from the proposed site to the roundabout and down the London Road, where are the buses going to fit? How is this going to benefit those from

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No. Name Organisation Comments Response to comment the outlying villages and coming off the A46 London direction into Bath, I live next to this road and see tailbacks right back up the hill from motorway direction, frequently, and every day. It will become worse with a park and ride.mPlease note the wishes of the public that have voted 51% against this proposal - democracy says we shouldn't do this. don't ruin our heritage sites! please!? Bus punctuality is beyond the remit of this Plan. Please fine the bus companies that don't run buses on time and have a very poor attitude with their customers. add more bus stops and better local services. run small buses to the other park and rides that already exist. Offer reduced price bike hire and have good car share websites. Put bike hire stations on the outskirts of the City also, if possible.

77. Anonym What do you most value about Bath as a World Heritage Site? ous The protection of its wonderful and unique buildings, style and setting. 15 Jul 2. What do you think diminishes its value? Seagulls are not directly 2016 Seagulls - awful, constant noise and mess. I would not want to associated with the OUV of the stay in the centre of the city and be woken by squawking gulls Site. at 3 in the morning or have to listen to them as I toured the city. 3. What are the key risks to the site which should be planned for? Protecting the environment - particularly avoiding the building of a large car park on Bathampton Meadows which would have a serious adverse effect on the location and general beauty of the WHS setting. Pollution and traffic congestion. 4. What are the most important immediate improvements to make? Get rid of the gulls; develop and clean up the riverside all the

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No. Name Organisation Comments Response to comment way through the city; Reduce pollution and traffic congestion - electric buses and other vehicles for example, and ban HGVs from London Road / Cleveland Bridge route to A36. 5. What are the most important improvements to make in the longer term? Use the river / riverside more effectively.

78. Alex London What do you most value about Bath as a World Heritage Site? Schlesin Road Complete streets of Palladian architecture, all of a single ger Partnership building material. The valley setting. Roman remains, abbey church in perpendicular gothic forming a centrepiece. 15 Jul 2. What do you think diminishes its value? 2016 Traffic...... which, sadly, is proably necessary for the Agreed. Traffic is a Plan priority. economic survival of the city. I am old enough to remember a time when Bath was not an international tourist attraction and had little ecoonomic vibrancy. The buildings were black from years of soot, they were neglected and many were derelict. Even streets near the centre of the city had an air of genteel decay. All very quaint but deadly for Bath`s survival. Read: "The Sack of Bath": published in about 1971 3. What are the key risks to the site which should be planned for? City centre decay as retail is overtaken by on-line shopping. Doughnut-effect is a well documented phenomenon. Secondary shopping areas are already showing signs of "dead" shop fronts, usually masking small, low quality flats. Where viable B&NES should encourage re-instatement of ground floor frontages as originally designed, unless there are significant reasons for preserving a dead shop front. 4. What are the most important immediate improvements to The attributes listed within the make? Plan attempt to do this from a Taking a more enlighted view of "managed change" and World Heritage perspective.

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No. Name Organisation Comments Response to comment having a more realistic view of what we are preserving in Bath. Too often the authority puts value on later changes to buildings. I have known examples of owners being told to retain a formica work surface in a kitchen,(Sidney Place) 1950s partitioning of a drawing room (Camden Crescent) Retention of an Edwardian glazed internal door, described by an officer as a Georgian external back door. (Park Street) MDF wine bins (Edgar Buildings). Retention of vaults as vaults all over the place. 5. What are the most important improvements to make in the longer term? Linking the A36 to the A4(A46) will remove through traffic from the eastern part of the city thus easing congestion on the city centre perimeter. Serious consideration should be given to a new, more high profile use of Green Park Station, developing it as a major exhibition and events venue, like GMEX in Manchester. You have the asset...now use it properly. 8. Any other comments Generally, Built Heritage officers perform a useful and necessary job; however, we sometimes wonder at their priorities. We are preserving a living city not an archaeological site. Vibrancy and managed change can be constructive. Essentially, we are preserving a Palladian style city and that should be our first value in most locations. Removal of thoughtless Victorian and later damage should be given positive consideration. The neo-Marxist view that every period in history has identical value has little place here.

79. Dr Uni. of What are the key risks to the site which should be planned for? Daniel Gloucesters The need to control air pollution caused by road traffic; and the

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No. Name Organisation Comments Response to comment Keech hire potential effect of nearby geological interventions, such as (Countrysid fracking, on the springs. 15 Jul e and 4. What are the most important immediate improvements to 2016 Community make? Research 5. What are the most important improvements to make in the Institute) longer term? It would be useful to see a much more explicit hook-up with the Local Food Plan, especially as some LFP objectives relate to community-led, social enterprise and commercial opportunities linked to land use of green areas in the city. Finding ways to promote multi-functional land use for food production in the WHS could be a positive way to protect WHS green spaces. 8. Any other comments The management plan is comprehensive and well written and provides a wealth of useful data/references. The explicit identification of the challenges of balancing the attractions of the historic city with the needs of the modern, working city is positive. Please let me know if you need any more information. Thank you for the opportunity to respond.

80. Anonym What do you most value about Bath as a World Heritage Site? ous The fact that we currently still enjoy this beautiful Roman and Georgian City in a most magnificent rural setting. The fact that Incremental harm is 15 Jul the City is surrounded by green - the surrounding hills, and the acknowledged in the Plan. 2016 Avon Valley, and that this magnificent preserved jewel nestles in the middle of it - as it always has. The preservation of this rural setting of the City is absolutely key to the preservation of its unique character. Without it, the essence of the City is lost. 2. What do you think diminishes its value? Inconsiderate development, and encroachment on the green belt. "Little by little" encroachment of development along the The Setting is recognised in key

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No. Name Organisation Comments Response to comment Avon Valley floor will destroy this unique city. A "just don't go planning documents. there" approach to the green belt World Heritage Setting is vital if we are to preserve the unique character of the City. 3. What are the key risks to the site which should be planned for? The biggest risk I think is that the importance of the Setting of the City is not fully appreciated and will not be respected by Council planners- that attention is paid only to the city itself in isolation, when it is the setting which makes the City unique. The key risk to be planned for therefore is disastrous planning decisions, which will destroy the setting - and by implication, Planning decisions are taken the City, forever. Lack of independent oversight on the under English planning law. council's ambitions is a real risk - there is currently no effective There is no known prospect of brake on the Council taking unwise decisions which affect the this being amended as future of the Setting, where the Council own and wish to suggested. develop green belt land within the Setting. 4. What are the most important immediate improvements to make? A critical, and immediate improvement would be to change the way decisions which affect the WHS and its Setting are made. Where the Council owns and wishes to develop land in a way which may impact upon the WHS and its Setting, the WHS Management Plan should require the Council to acknowledge the conflict, and remove itself from the decision making process. There is currently no effective way to stop the Council making irreversibly damaging decisions affecting our WHS. Decisions of this sort should be removed to the purview of an independent, UNESCO designated body. 5. What are the most important improvements to make in the longer term? Over the longer term, the City needs to remove itself from the

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No. Name Organisation Comments Response to comment grip of the private vehicle. A wholesale revision of its transport policy - to one which uses all efforts and funds within its power to promote rail and bus infrastructure is key. BANES should, as part of the West of England devolution process look to regaining control of its bus service, and then look to the bus subsidisation models so successful in Europe. It should be pressing for the re-opening of key stations, such as Corsham, to remove the pressure on the roads. A Greener Bath should be our vision - with cycling and pedestrianisation ingrained in our psyche.

81. Andrew What do you most value about Bath as a World Heritage Site? Salter The natural time-established nature of the city while also achieving the facilities of a modern economic and cultural 15 Jul centre. 2016 2. What do you think diminishes its value? Over-crowding and lack of proper modern public transport. Previously the revolting modern developments were a terrible Unclear as to which eyesore but the new developments such as Manvers St are development in Manvers Street superb. is being referred to here. Bath is ridiculously poorly served in terms of public transport. There should be easy hop on hop off electric buses running at frequent intervals to persuade commuters to leave cars at home and enable visitors to get about quickly and easily. 3. What are the key risks to the site which should be planned for? Thoughtless and inappropriate development of sites and buildings. 4. What are the most important immediate improvements to make? Cleaning up the unsightly sites in the city. Maintaining the green spaces and creating more small parks and recreational

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No. Name Organisation Comments Response to comment areas. 5. What are the most important improvements to make in the Noted and will be reported to longer term? the relevant Council The city must be maintained as a cultural and heritage area as department. this is its central appeal. Further development of sophisticated arts and recreational facilities such as the Craneworks project are required to attract and maintain the type of professionals needed to support and develop the information technology businesses forming the city's main revenue stream. 8. Any other comments Why is a US English spell-checker in operation on this page?!?!

82. Claire What do you most value about Bath as a World Heritage Site? Warnes The beauty of the city surrounded on all sides by countryside which is accessible and much-loved by residents and tourists 15 Jul alike. 2016 2. What do you think diminishes its value? A lack of a sustainable transport plan. The Council seem determined to encourage greater car use by proposing a See response to comments 13 further park and ride site on precious Bathampton meadows, & 24 in relation to a possible when no economic or environmental analysis has been eastern Park and Ride site. produced to support it. 3. What are the key risks to the site which should be planned for? Spending scarce resources to Tarmac over the meadows in Bathampton rather than encourage and incentivise sustainable transport is a massive risk. 4. What are the most important immediate improvements to make? Develop innovative plans to take traffic away from the city not bring more into. A new Park and Ride is not the answer - it will

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No. Name Organisation Comments Response to comment make it much worse. 5. What are the most important improvements to make in the longer term? Much greater incentives of cycling and other sustainable forms of transport.

83. Katherin What do you most value about Bath as a World Heritage Site? e A beautiful city, with stunning architecture, yet a lovely rural Moloney feel as it is surrounded by beautiful countryside. 2. What do you think diminishes its value? Traffic congestion, 15 Jul particularly around the schools at pick up/drop off time. 2016 3. What are the key risks to the site which should be planned for? See response to comments 13 Say NO to the park and ride. It won't solve the problem of & 24 in relation to a possible traffic congestion, and will be a huge waste of money to the tax eastern Park and Ride site. payer. Money better spent promoting the use of the 2 existing ones that are not fully utilised. 4. What are the most important immediate improvements to make? Safer school routes, staggered drop off times to reduce congestion, and more crossing patrols. Plus more safe cycle routes into and around the town centre to encourage more environmentally friendly travel. 5. What are the most important improvements to make in the longer term? Improve traffic flow, reduce traffic, encourage cycling in the city by taking measures to make it safer.

84. Caroline Bath you most value about Bath as a World Heritage Site? The Kay Preservation ensemble of a city in its setting Trust 2. What do you think diminishes its value? Inappropriate 15 Jul development: sprawl; cumulative little bits of harm

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No. Name Organisation Comments Response to comment 2016 3. What are the key risks to the site which should be planned for? With the exception of Traffic destination management, better destination management already reflected in the Under-investment in the public realm priorities. Inappropriate development 4. What are the most important immediate improvements to make? traffic management beyond park and rides strengthening of enforcement public realm improvement 5. What are the most important improvements to make in the longer term? Clear leadership for a City-wide strategy within the wider Bath- Bristol area celebrating distinctiveness and Bath identity 8. Any other comments 1) as a member of the WHS Steering group I have played a part in the formulation of the plan so have not responded in detail here. 2) I shall send the World Heritage Site manager an additional 26 Jul submission with detailed commentary on the document itself. 2016 Comments on consultation for World Heritage Site Management Plan Para 3.5 The sentence ‘This natural landscape is appreciated today as much as it was historically…..’ conflicts slightly with the pitch to HLF for the Landscape Partnership bid. Would Suggested wording has been suggest a second sentence, ‘However in these different social added. times we believe more could be done to protect aspects of the landscape quality and to develop appreciation and enjoyment Noted. New number added. by disadvantaged communities.’

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No. Name Organisation Comments Response to comment Para 4.3 (p22) - FOBRA now represents 26 local residents groups. Bath City Centre Action Group (BCCAG) now represents the three large city centre groups TARA, CARA and This is covered later under the Pulteney Estates Residents Association. Action 47 Para 5.5 (p29)- Additional action under Objective 1: we recommend a further action point is added that promotes engagement with (and education of) the councillors who are members of the Development Management Committee to promote rigorous and policy-led decision making where possible harm to the OUV of the WHS from inappropriate large The suggestion will be passed scale development cannot be outweighed by the promoted onto the officer responsible for economic benefit to the city (e.g. Pinesgate). Some concern liaising with the panel. that the CABE review panel will not be sufficiently Bath- specific: perhaps request that CABE include a historic Bath City Riverside is already environment specialist when considering Bath submissions? cited under para 5.5 and it is not considered necessary to cover Para 5.5 (p29) – General write up and Action 4 - Should this in more depth here. include a paragraph on the overall Bath Riverside Enterprise Area key development sites that will come forward in the plan Noted. This footnote and text period; Bath Quays, Hinton Motors, Manvers Street etc, all of has been removed. which are very central and important sites within the WHS. Page 30. Footnote 8 – this statement is refuted by credible data from the Bathampton Alliance; demand only outstrips supply during the Christmas market period. For more information please see the data presented at the Transport Scrutiny Day (more information at: http://bathamptonmeadowsalliance.org.uk) and detailed data available at https://dl.dropboxusercontent.com/u/19620927/Alliance%20Re port%20for%20Scrutiny.pd ) Could change wqord ‘frequently’ to ‘sometimes’.

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No. Name Organisation Comments Response to comment Para 5.7 (p30) Public Realm - A further threat to the public realm is the proliferation of inappropriate commercial signage and general street clutter and its harmful impact on the ability to appreciate the OUV of the WHS: in particular the architectural detail of individual Georgian buildings and group compositions, and the formal symmetry and rhythm of the 18th century town planning. This could be the subject of a new objective along the lines of; ‘support the continuing work to A reference to enforcement has control and eradicate inappropriate and unauthorised been added under section 4.13 commercial signage and general street clutter to allow/enhance the proper appreciation of the OUV of the WHS’. This leads to two suggested actions: 1. Action – support the ongoing work of B&NES Planning Department in the improved control of unauthorised street clutter and signage and encourage expedient enforcement action when necessary. 2. Action – Ensure the Guidance on Commercial Signage and Tables/Chairs in the Conservation Area Engagement with the is widely used and adhered to in wayfinding project is underway planning decisions, and that resources and will be included under are expended on its enforcement. future monitoring on this action.

Wording on the education pack Action 17 (p31) - This action should include engagement with under 5.9 has been updated the current B&NES project to review and improve wayfinding accordingly. signage in the city centre (as per recent workshops)? A proliferation of duplicate signs could be harmful to the OUV of the WHS.

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No. Name Organisation Comments Response to comment Para 5.9 (p32) – the information about education resources is out of date. In 2016 a new education pack Bath – World Heritage Site was produced by Bath Preservation Trust in conjunction with B&NES and is now widely available online as a resource for primary and secondary school teachers. Para 5.11 (p32) Conservation – this section needs to be augmented tod eal with the issue of ‘cumulative harm’. The focus on the very small number of whole ‘Buildings at Risk’ is diverting the reader from a wider issue of smaller incremental and cumulative harmful changes to the city’s Georgian housing stock and assets from other periods. This includes harm from poor and inappropriate repairs, use of low quality materials (such as replacing timber windows with uPVC) and other harmful additions to listed buildings such as visible satellite dishes, inappropriately placed signage etc. The cleaning of New wording will be added Bath stone elevations is also a key issue which must be under 5.11 to refer to the harm conducted appropriately in order to avoid harm to the OUV. from incremental change. The use of a ‘Bath palette of materials’ in repair works is important to ensure visual homogeneity within the WHS (‘natural building materials’ are specifically mentioned as an attribute contributing to the OUV). In particular the use of A local list reference has been cement in the repair and re-pointing of Bath stone buildings added to action 29. and walls is an ongoing problem. Suggest an action point such as ‘ensure, via promotion of appropriate guidance from national and local heritage organisations (and through the planning system where appropriate), that repair, improvement and restoration works to designated and non-designated heritage assets across the city are in-line with best practice conservation principles and techniques.’ In addition the publication of a ‘Local List’ of non-designated heritage assets would assist in strengthening the protection of

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No. Name Organisation Comments Response to comment important buildings in the WHS that are not listed but that make a positive contribution to the city. A ‘Local List’ should be produced by B&NES therefore an action point could be added to: ‘encourage the publication of a ‘Local List’ to provide further heritage protection to those non-designated assets that make a positive contribution to the city and therefore contribute to the OUV of the WHS’. Action 32 (p33) – should the Joint West of England Regional Spatial Plan currently in planning be specifically referred to?

85. David What do you most value about Bath as a World Heritage Site? Price Architecture 2. What do you think diminishes its value? 15 Jul Traffic from A36 having to come into Bath 2016 The ever-expanding Rugby ground obscuring the beautiful The Rugby Ground is included views of Bathwick for most of the year as a major development to 3. What are the key risks to the site which should be planned monitor under Action 4. for? Loss of beautiful vistas 4. What are the most important immediate improvements to make? Ban traffic in the city centre (e.g. Milsom Street) 5. What are the most important improvements to make in the longer term? Trunk Road improvement will be A36 - A46 link included under Action 6.

Widen the pavements on Pulteney Bridge and make it single Covered under Action 10. lane for permitted vehicles, with speed calming measures 8. Any other comments Planning a Park & Ride site on Bathampton Meadows is insane. It is an important flood relief area and there are

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No. Name Organisation Comments Response to comment beautiful views of it from many areas around Bath. If a Park & Ride site is required (which has yet to be proved) it should be at Charmy Down, out of site of the city

86. Karen What do you most value about Bath as a World Heritage Site? Bladwell Its stunning architecture and beautiful surrounding countryside 2. What do you think diminishes its value? poor traffic 15 Jul management 2016 3. What are the key risks to the site which should be planned for? See response to comments 13 A major risk currently, is the threat of a Park and Ride car park & 24 in relation to a possible being sited on the meadows adjacent to the villages of eastern Park and Ride site. Bathampton and Batheaston. This a costly and damaging plan which it has been proven can not resolve the problem of school run traffic and heavy lorries driving in to the city. 4. What are the most important immediate improvements to make? A trustworthy committee to be set up to research genuine solutions to the traffic problems to the east of Bath 5. What are the most important improvements to make in the longer term? protection of the countryside around our beautiful city for future generations to enjoy 8. Any other comments Providing frequent and reliable bus services from towns such as Chippenham, Corsham, Trowbridge, Melksham and Bradford on Avon would enable commuters and visitors alike to come to Bath by bus without having to drive here to catch the bus! Although this is just one part of a management plan for Bath it

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No. Name Organisation Comments Response to comment is considered to be a very important part by a very large number of people from many areas of the city.

87. Susan What do you most value about Bath as a World Heritage Site? Traill The integrity of its architecture, the historic nature of parks and green spaces, the beauty of the valleys and surrounding hills. 15 Jul All these contribute to the World Heritage Site and should be 2016 cared for. The surrounding countryside gives an especially beautiful setting for an especially beautiful and fascinating city. The only Local Nature Reserve within the WHS has an interesting history and rare habitats. 2. What do you think diminishes its value? When the Council tolerates listed and historic walls to be knocked down and historic gardens to be used for modern housing. When the Council considers vehicle and cycle traffic more important than heritage houses and shops, as in the London Road. When the Council agrees to modern extensions to listed buildings and the replacement of historic buildings or their See response to comments 13 gardens with modern buildings of an architecture that does not & 24 in relation to a possible fit with the character of Georgian Bath - there is a lot of this. eastern Park and Ride site. When the Council does not respect the contribution of the beautiful countryside to the WHS, as in its plans to tarmac and floodlight Bathampton Meadows. When the Council neglects the historic and rare nature of green spaces in its economic planning. 3. What are the key risks to the site which should be planned for? The demand for housing is very strong and extensions to historic buildings and in-filling of their gardens and other green

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No. Name Organisation Comments Response to comment spaces risks losing the character and integrity of the WHS. Traffic has always been a problem and there has been no satisfactory solution to it. The London Road has become a point of emphasis now and it is in the process of being trashed by plans that take no account of residents or businesses, ie the life of the spaces through which this traffic flows. The only plans for eastern Bath are to ruin historic meadows, part of the countryside that makes Bath such a gem to visit. These plans will not help the London Road be less congested with traffic or acidic pollution. The pollution is very bad for buildings as well as people. The Council needs to give stronger emphasis to green spaces as part of the WHS and in contributing to the well-being of residents and enhancing the attractiveness of the WHS to visitors. 4. What are the most important immediate improvements to make? Stop the constant infilling of gardens and green spaces and extensions to historic buildings. When more housing is needed, it should not be done in this way. The gardens are an important means of reducing air pollution. The Council should negotiate through traffic, especially HGVs, away from Bath. This is a regional / national issue and as we have Conservative MPs and a Conservative Council, it should be achievable. It has to start now but it is a long term issue. HGVs cause air pollution but also shake the historic buildings and are increasingly too large for the roads, causing risk to other vehicles, to cyclists, and also to pedestrians and buildings. The Council should properly plan parking and not trash Bathampton Meadows.

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No. Name Organisation Comments Response to comment The Council should consider what makes Bath special in its planning for economic growth. This includes independent businesses and shops as well as buildings, the River Avon, green spaces and its Local Nature Reserve within the WHS. The WHS is better planned in this way than as a clone of somewhere else which is what seems to be the favoured option at the moment. 5. What are the most important improvements to make in the longer term? We have a huge amount of change happening now that will affect the long term. They need to be tackled immediately, see above. 8. Any other comments Please take notice of what your residents say, and respect the heritage value in all its aspects.

88. Cheryl What do you most value about Bath as a World Heritage Site? Nield de Its unique and beautiful green setting. This is its Unique Selling Crespo Point; what makes Bath stand out as a World Heritage City, and why it is so popular with locals, visitors and tourists alike. 15 Jul The 'diamond is nothing without its setting.' 2016 2. What do you think diminishes its value? If there is development in the greenbelt/ green setting.This destroys its whole uniqueness. 3. What are the key risks to the site which should be planned for? The greenbelt around Bath should be sacrosanct, and not developed. So the source of present and future risks are therefore any organisation/ body/ business etc. who want to develop/ destroy the greenbelt setting.Rules/ legislation/ policies should be written/ agreed/ passed that prohibit

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No. Name Organisation Comments Response to comment development in the greenbelt, [ even for 'special circumstances'.] 4. What are the most important immediate improvements to See response to comments 13 make? & 24 in relation to a possible Stop immediately any current plans for any developments on eastern Park and Ride site. greenbelt land. [ e.g. BANES' proposals for a Park and Ride at Bathampton Meadows should be dropped now.] 5. What are the most important improvements to make in the longer term? Make it impossible/ illegal etc. for any future Council or developers to develop the greenbelt- [especially Bathampton Meadows]- thereby securing the green setting of Bath for future generations. 8. Any other comments Much of the economy of Bath relies on tourism. Tourists adore the unique green setting. Any destruction of this would be an ' own goal' and ruin the very thing that makes Bath so special and unique. The greenbelt must be sacrosanct.

89. Robin What do you most value about Bath as a World Heritage Site? Dunster The expanses of Green Belt, meadows and parklands that enrich the cityscape. 15 Jul 2. What do you think diminishes its value? 2016 The unscrupulous development ambitions and greedy agendas of the 'moneyed' few and politically ambitious. 3. What are the key risks to the site which should be planned for? Destruction of natural beauty and environmental degradation Diminished morale of local inhabitants Loss of World Heritage status

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No. Name Organisation Comments Response to comment 4. What are the most important immediate improvements to make? More adequate maintenance of existing infrastructure. Upgrade and more efficient maintenance of public facilities including toilets and seating areas. Sensible, informed decision making by local authorities following honest consultative processes regarding traffic flow and pollution. Limiting multiple occupancy housing approvals and inner city student accommodation. 5. What are the most important improvements to make in the longer term? Optimise local train services. Tunnel bypass between A36 and A46 for transportation of goods not destined for Bath.

90. Sharon What do you most value about Bath as a World Heritage Site? Collins Its unique, green setting. There are so many stunning viewing points from the city centre. Also, just a short walk out of the city 15 Jul and you're in the countryside. This is such a valuable, unique 2016 asset to Bath. 2. What do you think diminishes its value? Inappropriate developments in its green setting. 3. What are the key risks to the site which should be planned for? Loss of the green setting. Bathampton Meadows is an intrinsic part of the World Heritage Site's green setting. Its destruction to make way for a 1,400 space Park and Ride site would be an irreversible loss to the city's uniqueness and status as a WHS. 4. What are the most important immediate improvements to make?

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No. Name Organisation Comments Response to comment Develop the 'green' aspects of the city... encourage green modes of transport. Improve cycleways, pedestrian walkways, low cost bus network, school buses and so forth. 5. What are the most important improvements to make in the longer term? More of the above, so we have a city that's easy to travel round by foot, cycle or electric buses and that reduces the dependency on travel by car.

91. Matt What do you most value about Bath as a World Heritage Site? Back The blend of beautiful history and country side. 2. What do you think diminishes its value? 15 Jul Any further development which reduces the green space and 2016 or doesn't keep construction styles and standards inline with the heritage architecture. 3. What are the key risks to the site which should be planned for? Any further park and rides will likely increase traffic, causing further pollution and irreversibly damaging the beautiful countryside around Bath. 4. What are the most important immediate improvements to make? Stop any plans to develop any further park and ride schemes. Encourage better use of existing park and ride schemes. See response to comments 13 5. What are the most important improvements to make in the & 24 in relation to a possible longer term? Stop any plans to build any more park and ride eastern Park and Ride site. schemes. 8. Any other comments Don't damage Bathampton Meadows with a park and ride scheme.

92. Matt What do you most value about Bath as a World Heritage Site?

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No. Name Organisation Comments Response to comment Williams The architecture and green spaces. 2. What do you think diminishes its value? 15 Jul The rampant building works that have increased over time but 2016 most of all the awful proposal to build a park & ride on Bathampton meadows, which has been a natural green space for hundreds of years. 3. What are the key risks to the site which should be planned for? The river Avon is prone to flooding. 4. What are the most important immediate improvements to make? Do NOT let a park and ride be built on Bathampton meadows!

93. Nicolette 1. What do you most value about Bath as a World Heritage To TC email inbox. Boater Site? Acknowledged.

18 Jul  Its compact beautiful built environment , 2016  cultural & historic wealth,  landscape setting, its views and accessible recreational activities this affords

2. What do you think diminishes its value?

 traffic, air quality, Transport is a Plan priority.  lack of respect for the role of the envoronment to quality The Placemaking Plan seeks to of life wider setting, new buildings of dubious address the quality of new architectural merit or insufficiently innovative buildings, although this is a very  high cost of living relative to earnings meaning that subjective area. residents less able to enjoy & contribute to the The cost of living is beyond the enrichment of cultural, historic and natural environment remit of this document.

3. What are the key risks to the site which should be planned

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No. Name Organisation Comments Response to comment for?

 managing the impact of economic and housing growth in a sustainable way especially with respect to the environmental sustainabilty of buildings and transport, This is the democratic political and of flood risk. system in place.  A council administration with a large working majority not just in Full council but also on the Development Planning Committee and relevant Scrutiny Panels, and which is prepared to put a narrow party-political agenda ahead of the long term wellbeing of the WHS site and setting, Transport is a Plan priority and 4. What are the most important immediate improvements to there is a recent Transport make? Strategy in place. Flooding is also covered in the Plan and by  better traffic management with more incentives for a recent strategy. Bath Quays sustainable travel choices and Bath City Riverside are  implementing flood risk management measures actively being addressed by  success in Bath Quays Waterside & Bath City Riverside development proposals. Enterprise Area , i.e. ensuring the riverside is enhanced, better flood defences and delivery of new attractive homes, visionary workspaces and high value added jobs Monitoring is included within the 5. What are the most important improvements to make in the Plan. longer term?

 sustainability of transport,  more robust measures of universal value and environmental wellbeing whilst enabling high value

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No. Name Organisation Comments Response to comment added economic and business growth

8. Any other comments

 Section 4.13 of the consultation document, notes that as the local planning authority, “B&NES Council are the principal steward of the WHS”. However it also observes that whilst “citizens can both help shape policy and comment on development proposals....This process cannot always achieve consensus.’ The continuing controversy over the need for and potential location of a new P&R facility East of Bath provides a graphic example of this, and whilst it remains to be seen whether as the consultation report suggests “the WHS provides a focus around which the parties can largely agree," this does bring to the fore a major risk to the WHS and setting (see above response to question 3).

94. Roger 1) Public realm, public realm and public realm. Make it Houghto distinctive, not just using the same as everywhere else. n Doesn't need to be specially commissioned stuff or "heritage- style". Just shop around for something with a bit of style or Noted. The recently published attractiveness. Doesn't need to cost any more, either. Don't Pattern Book is relevant here. leave the decision to traffic engineers.

2) Enforce policies that are adopted. Streetscape Manual - already watered down by Highways in the consultation stage - is routinely ignored, e.g. "Pattern of laying paving" (4.21), invariably ignored; pedestrian guardrail guidance (4.76), See above reference to the ignored; streetlights attached to buildings (4.110), ignored, etc. Pattern Book

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No. Name Organisation Comments Response to comment 3) Get rid of backing boards on traffic lights. London manages it on all streets of 30 mph and below. Nottingham mandates it too. It even costs less. Having persuaded Kelvin not to fit them in the High Street I'm disappointed (but not surprised) that they continue to be fitted as default.

4) Eliminate through traffic from the centre, not just reduce it. Resist objections from traders, most of whom are misinformed about likely impact and probably don't live in Bath anyway! Reduce on-street parking. Narrow carriageways ('road diet') and re-purpose parking bays (pocket parks, for example: http://www.streetfilms.org/people-parklets-and-pavement-to- parks ).

5) Remove traffic from High Street by making Grand Parade two-way. Restore Orange Grove. Close S and E of Queen Square. Interesting point. Most representatives do tend to be 6) Involve younger people. Is there anyone under 40 (50 even) experienced, older on the Steering Group? And Fobra doesn't represent 90% of professionals. residents.

7) Housing - get more people, esp. families, living in the centre. B&NES should be leading this, not converting its own properties for student housing. Curo's policy, meanwhile, is to convert its Georgian flats into holiday lets. North Quays development has pathetically low level of housing included. Look at restricting new development to permanent residents as in National Parks and, most recently, in St Ives - B&NES has the planning powers.

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No. Name Organisation Comments Response to comment The Pattern Book (volumes 1 & 8) Lighting. Doesn't seem to be in there - or if it is it's not 2) has now been published. prominent. Start by publishing the lighting strategy and background research commissioned by Rhodri. (And the pattern book, of course.)

9) Have traffic-free days - http://www.streetfilms.org/the-rise-of-open-streets-8-years-of- ciclovia-videos-on-streetfilms

10) What happened to the stuff Jan Gehl & co. did in Bath - identifying the need to increase 'dwell' times in city? Need some prototyping too: http://pavementtoparks.org/prototyping

95. Anne Bath’s The Mayor of Bath’s Corps of Honorary Guides membership of Twitchet Corps of Active Guides stands at 85 with the possibility to increase to t Honorary 90. Five years ago, the Guides’ Constitution was reviewed and Noted and these figures will be Guides a new emphasis placed on the core objectives which are to included in the Plan. engender a pride in the City and to offer an interpretation of Bath as a World Heritage Site. The past two years have seen a thorough review of the Guides’ training process putting at the heart of the training a core content of the Guides’ standard 2 hour walk which relates directly to the assessed walk and then set in a context of assessed background knowledge of Bath’s history and heritage. This we feel will raise the quality of the walk. Last year the Guides offered walks to 37,000 visitors, we have been awarded the Queen’s award for voluntary service and we have our sixth successive year of Excellent rating with Trip Advisor. The reason why I mention all this is that the future of the Guides must be maintained in an increasingly

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No. Name Organisation Comments Response to comment crowded market of paid for guided walks in a changing world of internet and smartphone interpretations.

The Guides do not wish to become out dated but continue to be involved as local residents in their desire to serve their City. The Guides also serve the local population by offering walks on topics of interest to residents and this year the Guides have worked with partners in Heritage Services, (World Heritage Day. 20 Guides helped deliver an interpretation of the Polite Society OUV with walks of the upper town, an interpretation of the Assembly Rooms and general promotion of the WH Day), Bath City council with the Festival of Nature offering daily walks throughout the festival on the history of the river and canal and working with Bath Abbey and Downside Abbey on the Benedictine Festival offering walks on 1000 years of Benedictine Heritage, 2015 also included. 2015 the Guides worked with the National Trust for WH Day at Prior Park. 2015 the Guides worked alongside the VAG with a walking interpretation of Jane Austen’s Bath. Noted and agreed. The importance of the Corps of Honorary Guides must not be overlooked in their contribution to the explanation of World Heritage OUV’s.

5.9 Education.

The education and the continued development of knowledge and enthusiasm for the Guides’ important work in offering relatively simple but engaging interpretation through the twice daily (apart from Saturdays) 2 hour walks must be protected, supported and enhanced. We currently work closely with

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No. Name Organisation Comments Response to comment Heritage Services who offer the Corp of Guides support through supporting and developing leadership skills through regular business meetings with Stephen Bird. Heritage Services helps with some finances of the Guides, educational events set around the themes of World Heritage. The Guides are working together with Heritage Services to be able to offer high quality trained “Heritage” Guides who will have a key volunteering role in the Interpretation Centre.

5.13 Research

The Guides use the Records Office. Important information on the Corps of Guides business is archived in the office and reference books and literature is held there. There is an increasing important relationship being forged between the Guides and the Records Office staff as Guides undertake research to deliver specialist local walks. This service must be developed and protected.

5.14 Accessibility and inclusivity Noted. This could form a potential new project under the The Guides have a policy of accessibility for all. We have our Plan’s objective for accessibility. own guidelines on walking with visitors with impaired mobility and vision but it has been impossible to obtain a map from Bath City Council with a drop kerb stone map apart from the commercial area. We have an ongoing request for a useful 'access for all' map to be produced to allow access to the upper areas of the City. We also have an ongoing request to allow the Guides access to a key for Ralph Allen’s Townhouse courtyard but this is yet to be resolved.

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No. Name Organisation Comments Response to comment Children. The Guides have written and published on our shared google documents walks for school children from key stage 2 and above to have a child focused interpretation of the OUV’s, medieval Bath, Georgian Buildings and we also offer a children’s walk of Bath in the Blitz.

Action 44. Management plan progress. The Mayor of Bath’s Guides would like to continue to be included in meetings for progress on the Management Plan as we are an important partner.

Andrew B&NES Points to make: Sharlan Environment  Importance of treed / undeveloped skyline d Team  What we mean by tranquillity – see Cot Area of Outstanding These points are generally Natural Beauty words picked up in the ‘Attributes’, but o Absence of inappropriate noise may need re-visiting when those o Absence of inappropriate of development attributes are refreshed. o Absence of inappropriate of visual clutter o Absence of inappropriate of pollution o A feeling of being ‘away from it all’  Monitoring  Attributes – raise their profile

Page 12 - 2.6

Bath is a university town, with the population swollen

during academic term times by students attending the

University of

Bath University and Bath Spa University. Noted - changed.

Page 13 – 2.7

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No. Name Organisation Comments Response to comment The current condition of the site is considered to be good. There are many elements to be assessed in arriving at this conclusion, for example the condition of the Georgian building stock, of the archaeology, parts of the landscape setting, some of the key views and of the character of the site and intangible elements. (Note: the setting of the World Heritage Site is generally very poorly managed leading to scrubbing up, poorly managed woodland, problems Agreed that the landscape resulting from the proximity of housing at the city edge and would benefit from better reduction in the area of calcareous grassland, likewise many management and a section key views are obstructed by un inappropriate vegetation and under 2.7 has been added. by inappropriate development within the focus of view - I would therefore suggest omitting the landscape setting and view bit from the good category to pointing out the poor or needy category – this is a key premise of the Supplementary Planning Document and Bathscapes bid) also ‘All major buildings and components of the inscription of the property on the World Heritage List (e.g. Roman Baths, Royal Crescent, Circus, Lansdown Crescent, gardens, parks, and public spaces) are in a very good state of conservation and are being closely monitored, as is the landscape surrounding the City of Bath’. (we in the Environment Team would question this Noted, although this is a direct statement with reference to gardens, parks and public spaces quote from the UNESCO which are possibly at risk from a potential drop in funding and Mission Report and as such with reference to the landscape surrounding of Bath see cannot be altered. comment above) Page 12 – Key Facts There are 5 Sscheduled Mmonuments covering 1.4ha (approx. Noted – changed. 13% of the central area).

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No. Name Organisation Comments Response to comment Page 15 - Protection and Management Requirements Is this a ‘fait accompli’ because something about the pressure on the setting is needed in this section reflecting some of the wording in 3.5? Section 4 page 20 onwards General Point – capitalize references to World Heritage and National Trust or the Trust etc also reference to the specific property should be to the World Heritage Site or WHS rather than to WH (eg page 31 Actions 11 and 20 Page 21 The correct title is ‘City of Bath WHS Setting SPD August 2013’ (the ‘study’ was prepared in 2009 and the SPD replaces the study Page 26 3rd paragraph Refer to the newly formed Waterspace Partnership and Waterspace Strategy – for details contact Cleo Newcombe- Jones – also applies to pqge 32 Action 24 Page 29 1st para ------guided by the Core Strategy, the Joint Strategic Plan and some major - - Page 31 Action 18 ------heritage of the WHS and its settingcan be difficult Page 33 Objective 11 Bid for 1.6 m of an overall 2.2 m Action 11 Bathscape (without ant s at the end) bid Action 34 add also ‘- - - to the hills beyond in recognition that the setting is intrinsic to the WHS itself.’ Page 35 Action 41 Towards the end capitalise Action Page 36 Table of Objectives

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No. Name Organisation Comments Response to comment Use consistency of WHS or Site Page 39 Action Plan Action 1 delivery partners should be or should include Environment and Design Action 3 include Development Management as one of the delivery Partners and perhaps broaden Policy to include design ie Policy and Environment Action 17 included in Bathscape HLF bid Action 18 Partners add other partners such as the National Trust and under resources include the Bathscape HLF bid Action 25 should read Environment and Design Team and add the Waterspace Partnership – for timescale appointment due 2016? Action 31 should read Environment and Design Team

The monitoring and management of views is covered in the Bathscape project ‘LOOKING AFTER THE LANDSCAPE’. I have attached a summary of the project below. I think this is a project that would be supported by the partnership even if the bid is not successful and therefore I think it should go in as an Action 31 has been amended. action. It previously read:

Achieving improved land management practice to open up and Support the ‘Bathscape’ maintain historically important views and vistas across the partnership as a mechanism for landscape. Activities will include: agreeing schedule of delivering projects aimed at important views / vistas (guided by work completed as part of conserving the landscape of the the World Heritage Site Setting Supplementary Planning WHS Guidance), their management needs and the development of a process of monitoring views / vistas by volunteers; working And has now been extended to with landowners / managers to foster good practice land include: management principles, priority areas / sites for land

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No. Name Organisation Comments Response to comment management work to maintain historically important views and ‘and of opening up and vistas, investigate landscape management issues for maintaining historically significant non-farming uses including golf courses, race important views and vistas’. course and cemeteries. The project will consider the need for replacement trees / woodland planting relevant to landscape Steering Group (28 July) views where framed by trees / woodland. Bathscape land approved this change. management partners will lead on scoping opportunities / project format, and a strong community input to the project will be vital for its success and local communities volunteers will participate.

96. Ian Henrietta Park Henrietta Park Resident's Association supports the comments Herve Resident's submitted by FOBRA. The reference to OUV was Association The Chair of HPRA and myself, as secretary, drafted the added as an abbreviation. comments included in that document on the subject of Steering Group agreed that Flooding. OUV is replaced in this instance On the revised version I have the following additional with ‘people, historic buildings comments: and archaeology’.

1) The replacing of any words relating to residences, houses and, by implication,residents, with the almost meaningless acronym "OUV" is a very disappointing response. Comments on this are noted. The anodyne nature of the clause makes it now almost The WHS Plan does not have a worthless. The real and known flood risk to residents who specific budget to address such maintain the historic core of the WHS is ignored by this an issue and will look to ensure document. it is adequately addressed in the Local Flood Risk Management 2) Directing the EA report concerning the flood risk to Cleo Strategy and other relevant Newcombe-Jones and her Waterspace study is not documents, as outlined in relevant. This study will not have the resources to even Action 23.

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No. Name Organisation Comments Response to comment consider flood mitigation. I have had several meetings with Cleo and her budget is negligible and her remit does not Flood risk is acknowledged in include flood mitigation or defence. Action 23.

I believe that the flood risk to residents and historic houses in Bath is something the WHS Management Board should acknowledge and include in it's forward planning.

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