17 February 2020 – Temporary planning applications

Bath Rugby were granted temporary planning consents in 2015. In summary these increased the height and capacity of the East, West, and South Stands to what they are currently.

This January we became aware that Bath Rugby had filed three new planning applications: 20/00135/VAR, 20/00136/VAR and 20/00137/VAR. Although we were not approached directly by Bath Rugby, they have indicated widely that these current planning applications only seek to extend the temporary consents to 2022 to allow more time for submission of a full application.

PERA does not object to an extension of time as such, and has asked only that certain irregularities and nuisance issues be addressed appropriately in any extended period. PERA’s response may be found on the planning portal under the above application numbers.

30 October 2019 – PERA comments on latest Arena 1865 press release on the development at the Rec. 

The developers of the proposed stadium on the Rec – Arena 1865 – issued a press release on the 22nd October “announcing final revisions” to their stadium plans ahead of a planning submission they speculate they will submit early in the new year. The detailed full press release can be found here.

Following on from PERA’s detailed response to the earlier design disclosures – which can be found here – PERA has responded to the press release as follows:

General: The content in the press release is vague and raises more questions than it answers. We call on Arena 1865 to provide meaningful public disclosures as to how it proposes to amend its proposals to address the many issues that have been raised by the Local Planning Authority and others in the context of their request for an Environmental Impact Assessment Scoping Document

“Overall Height reduction of 5.1m”. We are unclear what this reduction refers to. No details have been given but we surmise this is compared to a design that pre-dates the first consultation in July 2018 and which was never presented at any public consultation. If that is correct it would leave the West Stand almost twice its (temporarily allowed) height – or about 2.3 times the height for which they currently enjoy permanent consent. No elevations or views have been provided, apart from an artists impression. From this rough drawing it isn’t possible to discern any significant reduction in roof height from the last publicised plans. We urge the developer to provide full details of heights and elevations so that all stakeholders can comment appropriately and with full knowledge. We also urge the developer to install a scaffold (as proposed by Historic England) that shows the height and the scale of the development so that all stakeholders can properly assess the impact on this sensitive area of Bath.

“550 space car park providing blueprint for electric vehicle usage in the city”. PERA is opposed to any new car park in the historic city centre (which includes the Rec and the Pulteney Estate). The car park provides no benefit to the local community and has substantial disadvantages to the local area and wider city. It will increase local pollution and congestion on roads that already have high levels of pollution and raises the level of the pitch and hence the height of the stadium by approximately 4m blocking out world heritage views. There is also no data provided to back up the developers assertion that the car park will have no negative impact on congestion or pollution. In fact the car park would be closed on match days, so would not be available to the general public or the fans – showing the car park is an entirely different business venture from the Rugby.

“Mature trees retained along riverside with enhanced public realm design”. We cautiously welcome the retention of the trees along the riverside. However, we would want much more information about the commercial activities along the river, especially those having associated night-time noise and lighting, so we could fully understand the impact on river corridor ecology. In principle, we see no need to move the stadium nearly 50m further onto the Rec to accommodate a commercial plaza for the stadium developers. If this were to happen PERA’s view is that the remainding “rump” of the Rec would not be viable for the many sports and other activities the Rec currently hosts. This loss of historic city centre green space would be a major loss to Bath.

“Enhancements to West, East and North Stands which maintain views to local landmarks including St Mary’s Church, Bathwick and the hills beyond”. The views to St Marys and the Bathwick hills are currently panoramic and visible for the entire length of Grand Parade not just the slither by the Pulteney Bridge which is highlighted in the artists impression. The bulk of the stadium will block out most of the views of the hills from Grand Parade, Parade Gardens and Johnstone Street. We urge the developers to publish full elevations as well as views from all the key world heritage viewpoints.

“State of the art hybrid playing surface available for use all year round”. PERA’s preference is for an environmentally friendly grass pitch at ground level.The average hybrid pitch contain 20 million fibres or 48,000 km of polypropylene. Pollution caused by these fibres is a major concern. Further, the justification the developer has used for raising the pitch (and hence the stadium height) by 4 metres to accommodate the car park, is that a pitch at ground level will flood and take up to 4 months to clean up. Since the flood alleviation scheme became operational in 1974 we cannot recall flooding that has caused games to be postponed for 4 months – we would welcome historic evidence from the developers to back up their claims. The Environment Agency certainly does not object to a grass pitch remaining at the current ground level. The current flood risk on the Rec is 4% . Hardly significant. Without evidence to the contrary we believe the claim that it could be out of action for many months is a smokescreen to justify a car park of huge financial benefit to the developers and the financiers.

” … The stadium… provides huge economic and citywide benefits”. PERA notes there is no detail provided to support this claim. Until such detail is released for critical independent analysis we remain sceptical of the claims and assume the major financial and economic benefit will again go to the developers and the financiers. A recent survey commissioned by Visit Bath and conducted by the South West Research Company estimated that the 3500 p.d. day visitors spent an average of £38 each in the local retail community. Extrapolating this to the typical 15 home games of the season, the maximum extra annual income generated equates to £2m (This figure is probably an overstatement as many Bath fans are local to Bath so the extra 3500 seats will not bring in 3500 new visitors ). In any case this is not the multi million figure portrayed by the developers and is tiny in comparison with the £470m brought in by overnight tourist stays. In fact this extra number will not go to the local businesses, but more likely to the stadium owners through the extra bars and retail outlets planned for the stadium. If the new retail spaces of bars and restaurants are allowed it is likely that businesses in the rest of Bath will lose out as the new stadium sucks in its supporters and other non match day visitor business.

The press release by the developer is very brief and full of PR spin. What is notable is what it doesn’t say rather than what it does – for instance no details are given as to how the stadium will be commercially used for the 350 days a year when Rugby isn’t being played. Further, what has happened to the proposal to apply to build a temporary stadium on the Rec whilst the new stadium is being built.

We conclude that the release is just part of the hyperbole being created by the PR agencies employed by Arena 1865 ahead of their planning application in the new year. If it is not, then we would urge the developers to sit down with PERA now to discuss how our community’s valid concerns can be addressed.

13 August 2019 – PERA comments on Environmental Impact Assessment (EIA) Scoping Report

Many of you will be aware that Arena 1865 recently submitted an Environmental Impact Assessment (EIA) Scoping Report to BANES. This report relates to the work that needs to be done to assess the likely environmental impact of the proposed development on the Rec. Arena 1865 is seeking a Scoping Opinion from the Council which would set a framework for EIA.

An EIA is a legally required process that aims to identify and assess the impacts of a proposed large development. The impacts that fall within the environmental assessment cover a range of different areas including: heritage, landscape/visual amenity, air quality, noise and disturbance, waste, traffic and access, ecology, lighting, and drainage. Needless to say, the exceptional sensitivity and importance of the Rec in its position in the World Heritage Site and adjacent to important heritage buildings within the Georgian city, as well as being adjacent to a main river and having access roads with poor air quality, make a high quality EIA especially necessary in this case.

Arena 1865’s EIA Scoping Report was published by BANES on its planning portal asserting that it was not open for consultation. Notwithstanding this, PERA has submitted comments which are now on the planning portal under application 19/03133/SCOPE. A copy of PERA’s comments can also be found HERE.

The main gist of PERA’s comments is that:

– under the relevant legislation the planning officer can and should consider our comments,

– Arena 1865’s report as a whole is incorrect in various respects and currently lacks the necessary details that need to be provided, and

– certain individual sections of the report lack the necessary details that need to be provided.

It is in the interests of all involved that EIA is of appropriate scope and done effectively. With this in mind PERA’s aim is to ensure that the important issues we have raised are properly considered, especially those that are likely to affect our members most. We believe that the extensive local knowledge of some of our members can be of great benefit in supporting the preparation of a good BANES Scoping Opinion and hope that the parties will welcome our contribution.

We will keep you informed of further developments.

6 January 2019

Following the public consultation held by Bath Rugby in December, the PERA committee now publishes its UPDATED POSITION PAPER on the proposed development. You can also find PHOTOS showing the likely visual impact of the New Stadium in this unique location.

It is unfortunate that our very significant concerns about the development remain. Our concerns divide into three broad categories:

– the huge size and excessive height of the New Stadium, which overwhelms the historic location of the Rec

– the adverse impact the New Stadium will have on adjacent residential areas, including as a result of including a 700-space car park, and

– the siting of a temporary stadium at the Rec while the New Stadium is built, making the Rec unusable by the local community for at least two years.

Very few of the issues we have raised to date with Bath Rugby on behalf of our members have been adequately addressed. The committee must now decide what steps to take to ensure the protection of PERA residents. We will be providing a further update to residents, including the steps PERA  proposes to take next and guidance to residents on the steps they may wish to take in relation to the letter they have received from Bath Rugby about the 1922 covenants.

10 October 2018

Following the consultations held in July 2018 by Stadium for Bath, the PERA committee has been considering the issues raised by the proposals for the new stadium on the Rec.  In doing so, we have taken the time to seek the views of local residents on the proposed redevelopment.

Whilst the views of PERA’s members vary widely, we think it is important for PERA to state its position.  To that end we have produced a summary of the key concerns and issues raised by the proposed new stadium which can be found here.

Further thoughts and comments are welcome from our members and should be submitted to the relevant committee member.  

For an update of the latest developments follow this link: http://stadiumforbath.com/news/ 

19 July 2018

Over the last year Bath Rugby has been engaging with the local residents as well as other groups over its desire to build a new stadium on the Rec. The process is ongoing. For an update of the latest developments use the following link: http://stadiumforbath.com/news/ 

PERA’s position has been clear for several years. While not opposed to improvements/redevelopment of the current stadium, PERA is opposed to any changes that will cause further noise, nuisance or pollution and degrade the utility of the area as being a great place to live. As PERA members we are keen on your views. The PERA committee members responsible for liaison with the Rugby club are: Nigel Websper; Roy Hatch and Sue Shipman. You will find their email details on the committee membership page.

UPDATE: We have recently become aware of a proposal to build a temporary stadium on the rest of the Rec to accommodate Bath Rugby whilst the new stadium is being built. We are very interested in PERA members feedback on this idea. Please send comments to the relevant committee members.

Stadium for Bath has announced dates in July when the public can view their “emerging concepts for the new stadium and riverside”. See http://stadiumforbath.com/stadium-for-bath-to-host-public-consultation-on-emerging-scheme/

We would encourage PERA members to attend and to send us feedback on your thoughts.

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