January 2005

BATH AND NORTH EAST SOMERSET

LOCAL PLAN

Revised Deposit Draft 2003

Pre-Inquiry Changes August 2004

Further Pre-Inquiry Changes November 2004

FOREWORD

This report is a summary of the Sustainable Development Appraisal for the Bath and North East Somerset Local Plan Revised Deposit Draft 2003, Pre-Inquiry Changes August 2004 and Further Pre-Inquiry Changes November 2004 (referred to as ‘the Plan’). 

Local Plans contain policies and proposals that are used to regulate the development and use of land in the public interest.  The Local Plan is the key document against which planning applications are determined.  The purpose of the Appraisal is to improve the Plan in terms of its ability to deliver sustainable development.  The findings of this appraisal will be made available to the Public Local Inquiry into the Plan starting in February 2005.  The Council has not yet agreed to any of the comments or recommendations proposed in the appraisal.

Sustainable Development Appraisal is an iterative process.  First the Issues Report, the precursor to the Deposit Draft, was appraised with the outcome then informing the content of the Deposit Draft.  The Deposit Draft was in turn was appraised by Council officers in a process overseen by sustainability consultants Riki Therivel and Jake Piper who advised on the appraisal criteria and the appraisal format used, 'screened out' those policies likely to have a minor impact and participated in the three-day intensive appraisal process. 

This document reports the appraisal of the Revised Deposit Draft, Pre-Inquiry Changes and Further Pre-Inquiry Changes produced in 2003 and 2004.  This was carried out as desk exercise by consultants Levett-Therivel, supplemented by several meetings with planning officers to clarify the context and probe the justification for some policies with apparently adverse impacts.  The appraisal includes changes made as a result of comments received in a stakeholder consultation in December 2004 and January 2005.

This document describes the context to Sustainable Development Appraisals, contains a report of the process undertaken, and a summary of the appraisal outcomes.  The workings of the full appraisal itself – a set of matrices evaluating most policies and some other significant components of the plan - is available on request as a technical appendix to this document.

If you have any questions please contact Keith Goodred, Team Leader – Planning Policy, Bath and North East Somerset Council on 01225 477611, or e-mail Keith_Goodred@bathnes.gov.uk

Keith Goodred

Team Leader - Planning Policy

2 February 2005

 

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CONTENTS
	Page
1 – Context & Methodology	4
2 – Summary of Impacts and Issues Raised	7
Section 3 – Comments on Plan Section/Chapters
A  Overall Strategy Section	10
Vision & Strategy
Implementation
Design
B  Living and Working Section Economy, Tourism & Agriculture Community Facilities and Services Sport and Recreation Shopping Energy Services Housing Waste General Development Sites   C.  Environmental Assets Section Green Belt Natural Environment Built and Historic Environment D.  Access Section	10                   15         16
Annex 1 - Matrix Sheet examples	18

 

1          Context & Methodology

National Policy Context

 The planning system was reformed in 2004, replacing Structure and Local Plans with Regional Spatial Strategies and Local Development Frameworks, and making sustainability appraisal, including strategic environmental assessment, mandatory.  This is one of the last Local Plans being produced under the ‘old’ system, with a discretionary Sustainable Development Appraisal.

 The Government’s vision of sustainable development is about ensuring a better quality of life for everyone, both now and for generations to come.  Its sustainable development strategy ‘A Better Quality of Life: A Strategy for Sustainable Development for the UK’ (May 1999) set out a number of key indicators intended to help measure progress in achieving sustainable development and inform policy decisions.  The broad objectives underlying the strategy are:

·        maintenance of high and stable levels of economic growth and employment;

·        social progress which recognises the needs of everyone;

·        effective protection of the environment; and

·        prudent use of natural resources.

 The strategy is under review and a new strategy is expected to be published in March 2005.  It is likely to drop the economic growth objective and to give much greater emphasis to climate change.  Given the alarming implications of the latest climate change research findings, it would be prudent and responsible for the Local Plan to take advantage of any such changes to strengthen its provisions for reducing greenhouse emissions and their causes (notably traffic) so far as this is procedurally possible.

 PPG12 (Development Plans, December 1999) stressed that the planning system and, in particular, development plans can make a major contribution to the achievement of the Government’s objectives for sustainable development.  The Development Plan Regulations require local authorities to have regard to environmental, social and economic considerations in the preparation of Structure Plans and Local Plans.  Policies in the development plan need to implement the land-use planning aspects of sustainable development and must be capable of being addressed through the land use planning system.

Bath & North East Somerset Context (B&NES)

 B&NES has adopted a Sustainable Development Policy which establishes certain goals for achieving sustainable development within the District. These include the need to ensure that: access to facilities, services and goods is not achieved at the expense of the environment; resources are used efficiently and waste avoided; nature is valued and protected; local needs are met locally; culture leisure and recreation are readily available to all; and local distinctiveness is valued and protected.

 Sustainable development is also incorporated into the B&NES Statement of Vision and Values. This states that the authority will “Work towards a better quality of life for present and future generations” by promoting long term social, cultural, economic and environmental health and vitality.

 The Bath and North East Somerset Local Plan will play a key role in implementing those aspects of sustainable development which relate to land use.  It will influence patterns of development within the District by providing land for housing, employment, shopping, community and recreational needs; it will also seek to protect and enhance environmental assets and local character; and it will influence transport and access to facilities.

Appraisal methodology

 As part of the Local Plan preparation process, all strategies, policies and proposals are formulated in the light of the overall Local Plan objectives which, like the Appraisal, are based on sustainable development objectives.  This is a continual and informal process.

 The purpose of Sustainable Development Appraisals, on the other hand, is to appraise each of the Plan’s strategies, policies and proposals against a set of sustainability criteria at particular and clearly identifiable stages of the Plan process

Sustainability Criteria

 The initial stage of the Appraisal process involves the establishment of criteria based on the principles of sustainable development.  It is against these criteria that policies are appraised. 

 The criteria selected for the appraisal of the Issues Report stemmed from Government guidance on carrying out environmental and sustainable development appraisals, principles in B&NES Sustainable Development Policy and Local Agenda 21 Vision for a Sustainable Future, and appraisals undertaken elsewhere.  The criteria that were chosen reflect sustainable development objectives relating to land use, which planning can influence.

 The criteria that follow are based on those used for the previous appraisal but have been amended slightly and now include a criterion relating to 'Culture, education and equality'.

 

·        Air quality ·        Water resources & quality ·        Land and soil ·        Landscape ·        Nature conservation ·        Open space ·        Housing ·        Vitality/viability of centres ·        Built heritage etc.

·        Minerals resources ·        Economy and employment ·        Health ·        Safety and security ·        Culture, education  and equality ·        Use of energy ·        Travel and access ·        Waste production and treatment

 

 To make the appraisal process easier and to provide greater clarity, each criterion is accompanied by a question to be asked when appraising each policy or proposal.  There are also examples of how the policy might be able to satisfy each of the criteria.    An example could be - will the policy maintain and enhance 'water quality' or 'nature conservation'?  Examples of how the policy could satisfy these criterion could include 'reduce emissions to water', 'promote recycling of water', or 'protect wildlife corridors'. 

 Not all policies were appraised at Deposit Draft stage.  Gaps were filled, and new and altered policies from the Revised Deposit Draft and pre-inquiry changes were appraised in January 2005.The appraisal criteria were slightly updated for new appraisals carried out at this stage: the revised criteria are shown in Annex 1.

Recording the Results

 The impact of each policy or proposal is recorded in a matrix.  It must however be emphasised that the matrix is only a tool to assess the impacts of policy.  Conclusions cannot be reached simply by counting pluses or minuses.  It is a process whereby comments and suggestions that should improve the sustainability of plans can be recorded. It is these comments that are of value, as these recommend or suggest changes to the plan that make it more sustainable.  These recommendations can then be taken on board together with other representations received and any other material considerations to further improve the policies in the plan.

2          Summary of impacts and issues raised

Overall assessment

 Overall the Plan is positive for sustainability.  Most of the significant impacts of policies in the plan recorded in the matrices are positive.  The Plan’s particular strengths include:

·        Clear recognition of the value of the built and urban environment of the District (notably, but not only, the historic centre of Bath including the World Heritage Site) and policies to protect and enhance it without preventing desirable or necessary development;

·        Focus on maintaining the vitality of towns and settlements, including, but not only, the city of Bath, and on regeneration where needed, particularly  of Norton-Radstock;

·        Provision of housing to meet local needs;

·        Aim to reduce need to travel and support more sustainable modes;

·        Protection and enhancement of the rural environment.

Challenges

 However, the District faces strong challenges to sustainability, many of them shared with the rest of the region.  They include:

·        Demands for more housing, especially affordable housing;

·        Increases in traffic, car use and car dependence, encouraged by continuing decline in the real costs of motoring relevant to incomes;

·        Loss of traditional employment and a need to provide for replacements;

·        Tourism pressures, especially on Bath’s historic centre;

·        Projected increases in demand for shopping;

·        Loss of rural employment but continued pressure to live in the countryside;

·        Impacts of climate change, which the latest climate change research suggests are likely to be even more severe than previously recognised.

 Thus there are conflicts between development and environment, and between different kinds of development.  The Plan generally seeks to reconcile these within the constraints of the planning system.  A Local Plan has limited capacity to influence these, and it would be a mistake to expect the Plan to achieve fully sustainable results when so many trends and pressures outside its power are pushing strongly in unsustainable directions.

 Positive, proactive planning - However, earlier stages in the appraisal repeatedly called for more proactive and ambitious policies.  For example one comment in the previous summary report was: ‘Are the policies in the plan as sustainable, innovative or challenging as they could be?  Do they encourage excellence?’

 We warmly welcome the ‘Quick guides’ as a valuable way to put more proactive, promotional messages than might be allowed in policy text.  But from a sustainability point of view we would repeat the call for the text of the plan to be as proactive and motivational as possible.  The urgency of environmental problems, notably climate change and gravity of its consequences, dictate stronger interventions.

 Obviation. In the same vein we would recommend more emphasis on obviating, avoiding and reducing environmentally damaging activities as higher priority than mitigating their adverse impacts.  This applies particularly to transport. The changes anticipated to the national sustainable development strategy (see para 1.3 above) should make this easier.  We urge the Council to take advantage of these, even at this late stage in the plan’s preparation.

Issues in appraisal method

 Appraisal standard.  In this final version of the appraisal we have made small changes even to a lot of the matrices we had agreed not to re-appraise, for several reasons arising from the discussions we had with planning staff before the Revised Deposit appraisal.  The first was to improve the consistency of the standard against which we were assessing policies.  The basic standard we are applying is ‘will the policy make things better for criterion X than not having the policy - if the answer is ‘yes’ the appraisal should be +; if the policy will not make a significant difference the appraisal should be 0; if the policy makes things worse, the appraisal should be -.   Some of the earlier appraisal appears to have been done against the yardstick of ‘will the policy achieve sustainability?’ - a much tougher standard against which most policies will score poorly on most criteria even if they are as positive as the planning system allows.  Correcting this has therefore tended to improve some appraisal marks.

 Process.  This appraisal is being done just before the inquiry, rather than while the revised deposit draft was being produced.  A large number of suggestions from the earlier appraisal had clearly been taken into account in the redrafting.  However some important ones had not.  We need to be clear how these reiterated recommendations, and the new ones from the current appraisal, will be taken into account.

 Implementation dependency.  Many impacts of policies are largely dependent on implementation and are therefore difficult to assess.

 Interdependence of policies.  The previous summary report included the comment that: ‘In some policies certain clauses or criteria are included, for example in respect of safeguarding nature conservation or in mitigating traffic impacts, even though these issues are already covered elsewhere in another policy. Although including such specific clauses in policies may increase the importance of that particular issue, there is either a need for a consistent approach throughout the plan or it may be the case that some issues are so important to a policy that they warrant specific criteria.  Whichever way, it is important that this is clarified.’

 The Revised Deposit Draft is clearer and more consistent in its cross referencing. We recognise that pragmatic judgements need to be taken about where a certain amount of repetition is necessary to help users understand and apply the Plan.  We think the balance is about right.  We have removed from the matrices some excessively detailed reference to other policies, so as to concentrate more strongly on the effects of each policy under appraisal.  This often had the effect of changing scores of +, - or ? to 0.

 General comments on plan drafting.  The earlier appraisal included a large number of comments and suggestions on the detailed drafting and laying out of the Plan which were not strictly related to its sustainability impacts.  These were all considered in the production of the Revised Deposit Draft, and some were adopted.  For the sake of clarity and focus we have removed them from this final appraisal except where they have a bearing on the Plan’s sustainability performance.

 Issues around site specific proposals.  We have generally not altered those appraisals of site specific proposals carried out in the Deposit Draft appraisal because the teams that carried them out had more relevant local knowledge than the consultants carrying out the revised deposit appraisal.  However we discussed some major and contentious issues with the relevant planning officers, and the report reflects the outcome.

3          Comments on Plan Sections/Chapters

 The following comments concentrate on major issues; they do not duplicate the many detailed comments and recommendations on individual policies given in the matrices.

A3.  Vision and Strategy

 The plan’s objectives are highly supportive of sustainable development, subject only to one comment: L8 (economy) we would suggest the objective should be to ensure that Bath’s economy meets the needs of its people.  Maintaining the City’s importance as a centre of business is a means to this end.  This change would remove unnecessary conflict between desirable forms of economic development and environmental protection.

 Policy 1 very helpfully sets out a broad list of sustainability criteria. It is good that this policy comes first.  The change from ‘will be expected to’ to ‘will only permitted where it’ is a very valuable strengthening.  If, as the supporting text suggests, this policy is intended to function as a convenient overall sustainability checklist, it would be helpful also to include some further issues covered elsewhere in the plan, such as historic environment, access to open space, promotion of healthy lifestyles and waste reduction and recycling.

A4.  Implementation

 The effects of policy IMP.1 will depend on how it is implemented.

A5.  Design

 The design policies have almost entirely positive impacts, subject in some cases to how they are implemented.  Quick Guide 4B is a good checklist.  However it overlaps considerably with Policy 1.  We suggest that the relationship and demarcation between the two should be reviewed.

B1. Settlement Classification

 Although scoring positively for all of the criteria, Policy SC.1 only classifies settlements and does not directly affect development as such. The classification is based on sustainability criteria, but whilst described in the preamble that is not explicitly part of the policy.

B2. Economy, Tourism & Agriculture

 The overall effect of the policies is to seek to encourage economic activities that will help meet peoples’ needs in locations, and subject to conditions, that will minimise environmental harm.  Policies ET.1A to ET.1D seek to prevent loss of potential employment land.  We particular welcome the emphasis on maintaining a diversity of economic activity including industry and smaller, lower added-value activities which are important for meeting local needs, economic resilience and reducing transport intensity and vulnerability to external market changes.

 However, outside ‘core employment areas’, the effectiveness of these polices will depend on how the two phrases ‘the importance of the development’ and ‘the economic development benefits of the site’ are interpreted.  It is important that both these are interpreted in broad enough terms to include a range of public goods.  A further ‘quick guide’ could help.

B3. Community Facilities and Services and B4. Sport and recreation

 The overall approach of seeking to maintain and improve access to community facilities and services and sport and recreation, and ensure that development substitutes for loss and provides for new demands, are highly valuable.  However the impact of policies on sustainability criteria will frequently depend on implementation.

B5. Shopping

 The sequential approach to major retail expansion in Bath set out in the Further Pre-Inquiry Changes is probably the least unsustainable approach available in the circumstances; however development on this scale is unavoidably going to have major impacts.

B6. Energy, Utilities and Health & Safety

 The policies support sustainable approaches to energy and water, and seek to prevent environmental damage.  Given the likely severity of climate change and the need for a ‘step change’ in action to combat it, we would encourage a more proactive approach, especially to energy efficiency.

B7: Housing

 The policies apply national guidance for concentrating housing in existing settlements, on previously developed land, near amenities and transport, and for securing affordable housing to meet needs.  All this is good from a sustainability point of view.  However the minimum density of 30m dwellings per hectare in HG.7 is unambitious, and the implicit (and we hope unintended) message of HG.7a that densities higher than 50 are exceptions requiring special justification is unhelpful.

B8: Waste

 The policies promote the sustainable waste hierarchy: reduction or avoidance of waste first, reuse next, followed by reprocessing options including composting and recycling, and responsible disposal as a last resort.  WM.11’s prohibition of thermal treatment without energy recovery is valuable; however we would suggest that WM10’s requirement for proven technology may be unnecessarily restrictive of innovative methods with potential sustainability benefits such as pyrolysis and digestion.

B9: General Development Sites

 The appraisal of sites carried out in 2002 (Revised Deposit Draft) has not been repeated and is set out below.  The process for appraising Policy GDS1 was slightly different to the other policies as this policy focuses on specific sites.  The outcomes are largely additional recommendations for the site requirements.  In terms of appraisal methodology the site areas, i.e. Bath, Keynsham etc, and the villages, were divided between the groups, and each group was asked to appraise those likely to have most impact on the sustainability objectives.  Small sites and those with minimal impacts were therefore not appraised.

 All significant sites not appraised before or added in the Revised Deposit Draft and all rounds of Pre-Inquiry Changes were appraised in January 2005 as a desk exercise supplemented by meetings with planning officers to clarify the context and probe the justification for some policies with apparently adverse impacts.  Significant issues and comments relating to these sites are discussed below.

Comments relevant to all sites

1.      Check that general site requirements for all sites are as sustainable as possible, e.g. "taking account of archaeological and nature conservation interests" could be rephrased to "maintain or enhance archaeological and nature conservation interests where possible".

Bath

B1.      Western Riverside

a)      Maximise plantings where possible to help mitigate CO2 emissions

b)     Encourage/require recycling of water

c)      Leave buffer zone between river and development

d)     Require landscape master plan

e)      Biodiversity on site should be at least as good after development as before it

f)       Ensure that planting is with indigenous species

g)      Promote biodiversity along river edge

h)      Link/form wildlife corridors where possible

i)        Check availability of amenity open space in area; provide within site if necessary

j)       Allow opportunity for self-build, flagship sustainable development; encourage appropriate modern design

k)     Promote use of recycled materials

l)        Link to network of cycle/pedestrian routes, including better links to existing bridges

m)    Strongly restrict parking (to car-free level in parts of site?), particularly in eastern end

n)      Require use of current site's hard core in construction

o)     Include recycling facilities/Combined Heat & Power using waste

p)     Specify what is meant by "significant provision" for business development

q)     Rapid Transit System is most important benefit that planners should aim to achieve.  Also emphasise possibility of making this a beacon sustainable development.

B1A.    Land at Newbridge

We believe it would be more accurate to describe this as a ‘park and ride’ than ‘transport interchange’ since the elements which would make it more than a park and ride are currently highly speculative and uncertain.  Its main function would be to reduce the number of cars travelling the last two miles from the edge of Bath to the Western Riverside site.  This would achieve environmental benefits along those two miles.  But provision of unrestricted parking at Newbridge will clearly make it easier for people to drive there relative to other modes.  This is likely to increase car traffic and reduce bus use from the Newbridge site outwards.  This is in turn likely to result in reductions in bus services and/or increases in the subsidies needed to maintain them.

B3.      Rush Hill (Clarks/CIC Ralphs sites)

a)      Link to footpaths into countryside

b)     Promote reuse of materials, particularly hardcore from current site

c)      Consider including cycling facilities to nearby services/shops

d)     Encourage use of recycled materials and recycling centre

e)      Promotion of home-based working (live/work units); In this context consider including a policy in the Local Plan that allows use of part of premises for business purposes.

B4.      Southgate

a)      Consider how to maintain/improve river environment and enhance access to river

b)     Encourage landscaping within development

c)      Centre is not to be gated

d)     Consider opportunities for riverside as open space

e)      Recover hardcore, see B1 etc.

f)       Ensure very good security by design

g)      Opportunity for Combined Heat & Power

h)      Consider providing only very limited car parking on sustainability grounds, but would need improvements to public transport.

i)        Ensure car park is secure by design etc.

B5.      Land West of Swainswick Bypass

a)      Overall negative impact, although roughly 0.5km from village centre of Batheaston and has reasonable accessibility by public transport (A4) within 400m.  However, no employment within walking distance,

b)     Improve cyclepaths and footpaths

B11.    Eastern Part of University of Bath Campus, Claverton Down

As the planning system currently operates, maintaining green belt is one of the strongest planning tools available for promoting compact cohesive settlements, avoiding sprawl, reducing travel distances, and maintaining biodiversity, bioproductivity and access to open space.  We therefore believe that - unless it can be shown that defending a particular piece of green belt does not in fact promote these objectives - there is a sustainability justification for the current national policy of maintaining current green belt boundaries unless there are good specific reasons for altering them.  However we should emphasise that all the following discussion relates to green belt as a tool for sustainable development.  It does not imply a view on whether ‘exceptional circumstances’ exist in planning terms, a question which is outside the remit of the sustainable development appraisal.

The justification offered in the draft local plan (paras C1.10F-K) is that (1) national policy requires university expansion, (2) Bath University is well qualified to contribute to this, (3) it will bring benefits to the city, and (4) the existing campus is the best place for any expansion.  On (1) and (2) the national policy of expansion does not necessarily require or justify expansion of Bath or any other individual university. We have not seen any evidence that Bath has any stronger claim, or greater prospect of funding, than any other university.  On (3) and (4) no reasons are given why further expansion at the University of Bath campus would bring any more benefits to the city than any other development at comparable distance from the city centre.  The generic policies of the draft plan seek to encourage development in settlement centres and to prevent edge-of-town and out-of-town development, in line with national policy and sustainability requirements, and no reasons have been given why the university should be an exception.  Indeed, the main ‘sustainability benefit’ of developing on the campus would be reducing travel, which implies reducing interaction between the University and the city.

Maximising benefits for the city would imply supporting expansion within the city - perhaps by other educational institutions if the University of Bath does not wish it.  The argument that ‘alternative sites within Bath of a sufficient size are not available’ implies that a university can only function with new buildings all concentrated in one location. This is not true of many of the most successful universities which make the greatest contribution to the life of their cities.  In any case we have been given no evidence that options for developing within the existing site have been seriously considered. 

To sum up, if it really the case that the University of Bath could only expand by taking green belt land and becoming more self-contained and bringing less benefit to the city, in sustainability terms this would be an argument for expanding other universities which suffer less severe environmental constraints and could bring more benefits to their host cities.  Overall we do not feel any solid case has been made that releasing green belt land now for possible future expansion would bring benefits that could justify the environmental costs.

 

Keynsham

K1.      Somerdale

a)      Include air quality improvement?

b)     Suggest including 'promote renewable energy sources and/or reduce energy consumption' as a criterion.

K3.      Broadmead Lane

a)      Largely down to implementation.

b)     Nature of function will result in additional and significant freight movement.

Norton-Radstock

NR3.   Former Sewage Works, Welton Hollow, Midsomer Norton

a)                  Positive in terms of improving transport choice due to improvements to pedestrian and cycle links.

NR6.  Former Co-op Dairy, Tyning Hill, Radstock

a)                  Positive in terms of reducing the need to travel as the site is well located.

b)                  Negative impact on Economy and Employment due to potential loss of employment.

NR7.  R/O 63-101 Kilmersdon Road, Haydon

a)         Negative impact on reducing the need to travel as the site is not considered close enough to local amenities.

NR9.  Folly Hill, Chilcompton Road, Midsomer Norton

a)         Questionable positive impact as although the site is being developed there are mitigation measures in places to maintain and improve the boundary.

Villages

V4.      Old Mills, Paulton

NB Area as increased at 25.10.01 Full Council assessed

a)      Need to put in the general site requirements (which will become a policy) that water quality needs to be protected etc.

b)     Perhaps habitat creation should be in the preamble (General Comments relevant to all sites).  On the other hand, the first part of the preamble is just restating other existing policies, so is that needed at all.

c)      Proximity to Tesco is likely to benefit this store at the expense of the town centre. There may be some additional trade in the town centre, but it is unlikely to be significant and the question is whether the proximity to Tesco will actually harm the centre.

V8.      Former Radford Retail System's Site, Chew Stoke

a)      Generally positive impacts.

C1. Green Belt

 The proposed overall approach to safeguarding Green Belt and allowing only limited infilling and/or redevelopment of major existing developed sites is supportive of sustainable development objectives.  Two of the proposed alterations – at Newbridge and University of Bath – raise major sustainability concerns which are discussed elsewhere.

C2. Natural Environment

 The policies give generally strong protection to valuable aspects of the natural environment, and recognise its importance for human wellbeing.  We welcome the stipulation in several of the policies that substitution for assets damaged must be ‘of at least equal value’.  This is the right test.  But officers will need to be clear what it means, and be able to apply it consistently and confidently – including recognising that some assets (notably ancient woodland) are not substitutable.  We suggest using the Quality of Life Assessment approach (an appraisal tool developed by the Countryside Agency, English Heritage, English Nature and the Environment Agency) to make this operational.

C3. Built and Historic Environment

 The approach carefully balances the need to preserve the District’s outstanding built and historic environmental – especially the World Heritage Site – with the need to adapt to changing human needs and avoid ‘theme park’ Bath.  The Public Realm Strategy and the World Heritage Site Management Plan will seek to address some of these issues and should supplement Local Plan policies.  There is a need to be pro-active to explain to business that the need for quality in planning is necessary to maintain the very reason why they want to locate in Bath in the first place.

 BH.4 is perhaps too restrictive and limits the use of buildings for other purposes for which there is demand.  This could result in buildings standing empty rather than being used for a purpose that causes no harm to the building.  As an alternative the policy could safeguard the use of those listed buildings that are still in their original use.

C4. Minerals

 Many policies that had little impact on the sustainability criteria.  Those that did impact generally performed quite well.  For example Policy M.3 minimises the wasteful use of minerals that could be important for the local distinctiveness of the district. There were also policies that protect minerals whilst also encouraging the use of secondary or recycled materials.

D. Access

 The overall direction of the policies is highly sustainable: encouraging walking, cycling and public transport, and constraining car traffic.  Given how damaging traffic and car dependency are for the global and local environment, human health and social inclusion, it would be desirable to go further, for example setting district wide targets for traffic reduction.  However, spatial planning cannot make transport sustainable without broader policy interventions.

 Park and ride is an important example of the problem.  Park and ride has produced benefits by reducing traffic within Bath city itself, but very probably at the expense of inducing more private car traffic, and reducing the viability of alternatives to the car, from the perimeter of the city outwards. The question was asked in the first appraisal whether Newbridge in particular, and park and ride more generally, would increase or decrease traffic overall.  We have not seen any reply to this question or evidence on the point.  Without this, it is impossible to know whether the benefits of park and ride exceed the costs, and therefore dangerous to assume that they do.  We think it would be prudent to study the effects of park and ride on transport behaviour ‘outwards’ as well as ‘inwards’ from sites before committing Bath to any further expansion.

Annex 1
Matrix Sheet Example

Policy:
Appraisal criteria	Overall impact	Commentary	Proposed amendments to policy/action for other policies/other notes

Natural environment:  Will the policy maintain and enhance:

Air quality and Tranquillity
Water resources & quality
Land and soil
Landscape
Nature conservation
Open space (and access to)

Built environment:  Will the policy improve, protect and enhance:

Housing -  meeting needs and affordability
Vitality and viability of centres
Built heritage, archaeology, distinctiveness, townscape
Minerals resources

Social environment A:  Will the policy promote and safeguard:

Economy and employment
Health and healthy lifestyles
Safety and security (including from flood risk)
Culture, education and equality

Resource consumption – Will the policy

-promote renewable energy sources and/or reduce energy consumption
-reduce need to travel -improve accessibility without car use
-reduce waste and/or promote recycling