As well as supporting contributions from other groups working towards similar aims to those of Transition Larkhall, we have produced our own additional comments, shown below.

Transition Larkhall proposes one additional new policy and amendments to six of those proposed in the draft Plan.


In accordance with existing and proposed policies for sustainable development and transport, an over-riding aim of all planning, practices and controls should be to realise The Fifteen Minute Principle within a timescale of five years.
‘Everyone living in a city should have access to essential urban services within a 15 minute walk or bike. The 15-Minute City Project is designed to help access-focused urban transformations be what we need them to be: ambitious, inclusive, measurable and effectively implemented.’

Suggested amendments to BANES Proposed Policies
added in italics

Consultation Reference DM 12 Amendments to Policy CP7
Green Infrastructure policy to include:
A) a designation as relates to the Bath River Line project. Work has been progressing on the Bath River Line: the project is to create a high quality, continuous 10km walking and cycling connection from Newbridge to Batheaston/Bathampton and to improve and better connect the green spaces along the route and manage it as one. The purpose of the designation would be to protect/safeguard the area from built development; to ensure opportunities are taken within development proposals coming forward in the area to plan for green infrastructure and connectivity; and to help identify & facilitate opportunities for the wider network (of GI corridors, footpath/cycle paths etc) to connect into it.
B) a designation for strategic urban cycle routes between the South and East (e.g. London Road) of the city and the centre, which are at least equal to the current level of provision from the West.

Consultation Reference DM 21 Amend Policy B5
to clarify that as a first priority PBSA should be developed on campus and that it will only be allowed on other sites where:
A) a need can be demonstrated (with further detail to be set out in either Policy H2B or an amended Policy H2).
B) the development will provide at least 10% of the accommodation capacity to be available for BANES residents at social rents; with appropriate segregation where necessary.
 In the Central area and Enterprise Zone it will remain the case that PBSA will also not be permitted where it would adversely affect the realisation of the vision/strategy for the city in relation to delivery of housing and economic development. Note: further amendment to Policy B5 is proposed in relation to the University of Bath (see section 4)

Consultation reference DM29 (PAGE 43)
ST1: Promoting Sustainable Travel
It is proposed to strengthen this policy by adding the elements outlined below:
Requirement for all development to be located where there are opportunities to travel by alternatives to private car usage, and with opportunities to reduce travel distance
Requirement for development design to support sustainable travel. This aims to enable schemes to be refused on the basis of poor transport design creating car dependency, rather than just not meeting highways design standards.
Sustainable transport opportunities to be available for first occupiers – early delivery.
Mitigation must maximise opportunities for mode shift before increasing traffic capacity. Opportunities for low-carbon, last mile goods deliveries – dependent on scale/location of development. Developers to demonstrate they have made contributions to modal shift to public transport, where this is not currently adjacent, through negotiations with transport providers and BANES officers.

Page 44

Consultation reference DM 32

ST3: Transport Infrastructure

It is proposed to strengthen this policy by adding the elements outlined below:

Infrastructure to be planned and designed promoting mode shift to sustainable transport as a priority over traffic capacity.

Schemes which increase traffic capacity must demonstrate that opportunities to achieve mode shift as an alternative solution have been exhausted and that they will not lead to an increase in peak-time local traffic of more than 5%. Such schemes must incorporate commensurate sustainable transport improvements.

Add LTN1/20 into the list of design guidance with which proposals should Comply


Consultation reference DM 33

ST5: Traffic Management Proposals

Transition Larkhall is collecting views of local residents to enable
us to take part in the implementation of the Council’s Liveable
Neighbourhood Strategy.  We are concerned with the detail of  the
Council’s intention to ‘prioritise walking and cycling’:  safety of
pedestrians and cyclists is vital if people are going to choose these
modes of travel;  issues such as narrow pavements,  speeding
through-traffic and cars parked on pavements, must all be addressed in
order to implement the Strategy.  Public transport availability and
especially cost should be an integral part of the rebalancing of the
environment towards people’s health and well-being,  without
penalising those who need vehicle access to local schools and shops.

It is proposed that this policy should be amended by adding requirements that reflect the Council’s Liveable Neighbourhoods Strategy. These additional requirements will:

Create attractive places to enhance sense of community, health and wellbeing through re-balancing space towards people and away from vehicles.

Achieve mode shift through discouraging short car journeys and prioritising walking and cycling;

Support people with restricted mobility;

Reduce on-street non-residential parking and provide opportunities for EV

charging, car clubs, social spaces and improved walking and cycling routes;

Retain vehicular access for residents and businesses; and

Be implemented on a trial basis to enable changes to be made in consultation with the council and community.
Discourage a significant amount of non-local through traffic from residential streets while allowing access to all local businesses and amenities.

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Consultation reference DM34

ST6: Park & Ride

It is proposed to amend the policy to:

Change the emphasis from ‘traditional’ park and ride to develop a new model of “interchange” a multi modal connection with opportunities for e-car hire, e-bike hire, access to the countryside, community gain such as solar canopy, alternative uses for social gain outside of peak usage e.g. farmers markets, cafés, pop up venues and festivals all to be explored. A multi modal site, not just car to bus.

Add the requirement to demonstrate that the most suitable and sustainable

available site(s) has been selected.

To expand the requirement to assess traffic impact in order that it also includes assessment of transport benefits.

Particularly for the east of Bath, to investigate and develop smaller scale, ‘satellite’ parking sites along major bus routes.