Transport Report

Transport Report 7th Nov 19

1. Following extensive discussion by the FoBRA Transport Group, I submitted the FoBRA response to the latest B&NES consultation on the Bath Clean Air Plan (CAP). A copy is on the website:

There could be adverse impacts on residential areas surrounding the CAZ due to motorists seeking to escape charges by finding routes which avoid the CAZ, and there is also predicted to be traffic displacement within the CAZ. We have urged the Council to monitor traffic in these areas and take action to mitigate any increase in traffic volumes. Some Associations are considering possible Low Traffic Neighbourhoods.

2. Robin and I, accompanied by Michael Wrigley and Ceris Humphreys, met the Cabinet transport leads Councillors Joanna Wright and Neil Butters on 7 October to discuss a range of transport issues, including: Lib Dem manifesto plans for limiting vehicle access and improving public transport; tackling speeding and rat-running in residential streets; introduction of Low Traffic Neighbourhoods within an integrated traffic flow plan for the city; Bath Clean Air Plan; traffic implications of proposed car park on Rec; status of Bath Transport Strategy and PRMS; and electric vehicle charging systems.

3. Robin, Nick and I met Councillor Sarah Warren, the Cabinet Member for Climate Emergency, on 22 October. The Chairman's report will cover the meeting as a whole, but transport featured in the discussion as the Council reckons that 29% of carbon emissions are produced by transport (most of the rest is from buildings). B&NES aims to achieve "A major shift to mass transport, walking and cycling to reduce transport emissions". FoBRA has long supported such a shift in order to reduce traffic congestion and air pollution in Bath. But it is easier said than done. Cultural change is hard to bring about and the Council has little direct control over public transport.

4. We pointed out that one area where the Council does have full control is parking policy. Reducing non-resident visitor parking in the central area would encourage car drivers to use park-and-ride. Reducing on-street pay-and-display parking in the central area (currently almost 90% of spaces) would encourage those who choose to drive into the centre to go straight to a car park rather than driving round and round looking for a space on street, creating both congestion and pollution. Adam Reynolds' ideas for parking control for the whole of Bath would address commuter parking in residential areas and encourage commuters to use the P&R. A workplace parking levy could also be considered. This has proved very successful in Nottingham and provided funds for public transport improvements.

5. Also on 22 October, Stadium for Bath revealed its latest plans for an arena on the Recreation Ground, which include a reduction in the size of the proposed car park from some 700 spaces to 550. This would still be a very large addition to car parking capacity in the central area which would generate substantially increased traffic within and around the centre, contrary to the Core Strategy ("a largely car-free city centre") and the Bath Transport Strategy ("reduce the intrusion of vehicles, particularly in the historic core"). It would be likely to invalidate the assumptions on which the CAZ was designed. It would encourage more people to drive in by car rather than use buses from the P&R, which would also be contrary to B&NES's goals on Climate Emergency.

6. Stadium for Bath say that the Rec car park would not increase parking spaces in the city but maintain city parking provision at current levels accounting for reductions at other sites such as Avon Street. However, those reductions (amounting to a net loss of some 330 spaces) were anticipated in the Bath Transport Strategy approved by the Council in 2014. This would be an addition of 550 spaces to central Bath parking capacity compared with that proposed in the Strategy.

7. Following a discussion at the May Committee meeting, the Transport and Pollution Priority statement on the FoBRA website was amended to make it clear that while we want to see traffic reduced in the historic centre of the city, this should not be done by displacing traffic to other residential areas. Traffic must be reduced across the city, and rat-running deterred. A copy of the statement, incorporating also some changes reflecting the discussions on the CAP, is at Annex A.

8. It may be helpful to set out the various areas that are referred to in connection with traffic in the city. They are:

a. The 'city centre'. This is defined in the B&NES Core Strategy and Parking Strategy as the area in the map at Annex B. It covers the commercial and civic centre of Bath south of The Circus and north of the river. It makes a useful distinction between this area and the adjacent, almost entirely residential, areas.

b. The 'historic core'. B&NES's Bath Transport Strategy aims to "reduce the intrusion of vehicles, particularly in the historic core of the city". It treats the 'central part of the city' as the area from The Circus to the river and from Charlotte Street to London Street, somewhat wider than the 'city centre' definition above. Oddly, the 'historic core' is not defined in the Strategy, but a starting point would be the area covered by B&NES's Public Realm and Movement Strategy – see the map at Annex C – with the addition of important adjacent open spaces such as the Rec and the lawns in front of Royal Crescent. This is the broad area referred to in the FoBRA Priority statement as the 'historic centre'.

c. The 'central area'. This is referred extensively in the Core Strategy and comprises the city centre and neighbouring locations to the south and east (South Quays and Western Riverside East), ie the future extension of the city centre (map at Annex D). Arguably a proper definition of the central area would include the 'historic centre' as described above.

9. Stadium for Bath says that the Rec is outside the city centre and the historic core. While it is outside the city centre as defined by B&NES (8a above), the Rec, right opposite the Abbey, is on any reasonable view in the historic centre of Bath. The reality is that the Rec is a much more sensitive location in terms of the Outstanding Universal Values of the WHS than the public car parks at Avon Street (within the city centre) or Charlotte Street (outside). It would be helpful for the question of definitions to be addressed in the forthcoming revision of the Local Plan (previously the Core Strategy/Placemaking Plan).

Patrick Rotheram, Transport Lead 25 October 2019

Annex A

FoBRA website – traffic and air pollution October 2019

World Heritage Sites (WHS) are 'places of outstanding universal value to the whole of humanity'. The reality, in the WHS City of Bath, is that the appearance and amenity of the city is badly affected by traffic, with heavy traffic even in large parts of the historic centre. Pollution and vibration from vehicles damage the historic buildings. The traffic is visually intrusive, noisy and smelly. Except in a tiny central area, vehicles have priority over pedestrians, and there is little provision for cyclists. What would be an unsatisfactory situation in any city is an absurdity in Bath.

A comprehensive city traffic management plan is required to reduce traffic in the historic centre, while deterring rat-running in other residential areas. Traffic must be reduced across the city, not just displaced. Through traffic must be removed: an alternative route for HGVs which currently use the A36-A46 route through Bath is essential. The plan should include restrictions on coach access to the city centre and freight delivery management. Park-and-Ride is needed to the east of Bath, and P&R should operate later into the evening, with secure overnight parking and affordable charges.

Nitrogen dioxide (NO2) air pollution levels are showing some sign of reducing, but remain well above the legal limit in parts of the centre, London Road, and elsewhere. 10,000 people live within the worst affected areas. These levels of NO2 pollution are known to cause serious health effects, including early deaths (perhaps 30 a year in Bath). See "Papers" tab on this website for the relevant data: Bath air pollution map; air quality data 2018; NO2 graphs 2018. We are also concerned about the health implications of exposure to particulates (PM10 and PM2.5), although we recognise that particulate levels are in compliance with current legal requirements.

We welcome B&NES Council's decision to implement a Clean Air Plan for Bath. There should be robust monitoring of its effectiveness and of any displacement of traffic, and contingency plans in case the scheme performs significantly differently than predicted. We are not convinced of the effectiveness of the proposed traffic lights at Queen Square: they are likely to result in traffic backing up, leading to increased congestion and pollution in the area. In that event the Council should be prepared to reconsider the option of closing some sides of Queen Square, which would also yield benefits for the public realm in this iconic space.

FOBRA is a member of the Bath Alliance for Transport and Public Realm, which has 21 members including leading business, resident, heritage and other organisations and urges B&NES to develop a transport plan, based on a Vision of Bath as:
'A beautiful city in a green setting, with vibrant public spaces, a historic centre free of all but essential traffic*, clean air, good mobility and excellent transport infrastructure'.

* eg. Deliveries, cleansing, buses, taxis, key business needs, disabled, and access for residents to their homes

Annex B

City Centre – as defined in B&NES Core Strategy and Parking Strategy

Annex C

'Historic Core' – area covered by B&NES Public Realm and Movement Strategy

Annex D

Central Area – as defined in B&NES Core Strategy

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